Building Safety Awareness…W7748 County Hwy. V, Lake Mills, WI 53551-9643

920.648.6343 www.emc-wi.com

Safety and Environmental Concerns During Construction

• Planning Ahead is the Key to a successful project• A Few Factors that can affect your project approach:

– Referendum, Performance Contract, Capital Maintenance Budget

– The Contractor you select– Budgeting in Advance– Wage Rates??...2017– Contract language– Project timelines and duration– Summer project versus occupied building– Recycling goals, LEEDS project– Your District’s appetite for environmental issues– Sensitivity of the building population

Selecting the Right Contractors

Pre-Planning ProcessHow Much Involvement Do You Have?

• Selection of a Qualified Contractor based on the type of project you are undertaking..

• Budgeting Process: Who is making the decision on how much $$ to hold for environmental issues ( unaccounted costs will take away from finished product)

• And more importantly, How did they come up with their $$$

• Realistic project scheduling: Will there be work done in buildings during occupied school days? (Allowances for Fencing, construction barriers, HVAC alterations?)

• What are the recycling, LEEDS and other “green” initiatives and how do they affect project cost and duration (landfill versus abatement)

What is a “Hazardous Material”

• What’s in your contract language?

• AIHA document: “….District is responsible for removal of all hazardous materials?”– Non-friable asbestos? (exterior caulk, roofs , tars,)– Lead paint below State DHS limits?– PCB’s in caulk?– PCB ‘s in light ballasts, electronic ballasts– Mercury in light tubes?– Mercury in poured floors– Refrigerants?– Chemical waste in Science Drains?– Acid Dilution basins?– Soil issues from removed UST’s– Mold?– Bacteria?

What is a “Hazardous Material”

• OSHA's definition includes any substance or chemical which is a "health hazard" or "physical hazard," including: chemicals which are carcinogens, toxic agents, irritants, corrosives, sensitizers; agents which act on the hematopoietic system; agents which damage the lungs, skin, eyes, or mucous membranes; chemicals which are combustible, explosive, flammable, oxidizers, pyrophorics, unstable-reactive or water-reactive; and chemicals which in the course of normal handling, use, or storage may produce or release dusts, gases, fumes, vapors, mists or smoke which may have any of the previously mentioned characteristics

What is a “Hazardous Material”

• EPA incorporates the OSHA definition, and adds any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment. (40 CFR 355 contains a list of over 350 hazardous and extremely hazardous substances.)

• DOT defines a hazardous material as any item or chemical which, when being transported or moved in commerce, is a risk to public safety or the environment, and is regulated as such under its Pipeline and Hazardous Materials Safety Administration regulations (49 CFR 100-199), which includes the Hazardous Materials Regulations (49 CFR 171-180.

Environmental Concerns• There are many….

• Let’s Review Some Basics we that we should all know and then bring out a few better off left for the experts

ASBESTOS• COMMON USES OF ASBESTOS

– PIPE INSULATION

– BOILER BREECH

– BOILER LAGGING

– BOILER DOOR

– FIRE PROOFING

– DECORATIVE / ACOUSTICAL

– CEILING TILE AND MASTICS

– ROOFING

– FOUDATION TARS

– FLOOR TILE AND MASTICS

– ELECTRICAL INSULATION

– ONLY IN OLDER MATERIALS THOUGH, NOT NEW ONES RIGHT?............

– ITS EVERYWHERE!!!!

Who Regulates Asbestos?

• AHERA (Occupied Building Inspections)

– Original inspections are a good starting point only. Many hidden, assumed or previously unknown materials…Must inspect more.

– Regulates friable and materials which will become friable if disturbed.

– Require project design, management and air clearances…(this all takes time)

– Many projects will FAIL final clearances due to construction dust and welding fume OVERLOADS

– Must be independent of abatement contractor

Who Regulates Asbestos?

• WDNR: Manages Asbestos related activities regulated under NR 447– Pre-demolition inspection required for all buildings regardless of

age• Demolition defined as removal of structural member• Exemption for one residential single family home and duplex unless part of

larger project or commercial project

– Pre-renovation inspection required for all work that may disturb asbestos• How do you know what contains asbestos without a survey??

– Inspect jobsites for compliance• Notification for all jobs covered by DNR rules (friable jobs greater than 160

square/260 linear)• 10 working day waiting period for all work• Wet methods, visible emissions and waste disposal• RACM, Category 1 and Category II non-friable and friable

– How do you handle non-friable materials such as foundation tars, exterior caulks, roofing materials on recyclable brick, etc????

Who Regulates Asbestos?

• OSHA

– Materials less than 1% are still regulated by OSHA and many contractors will NOT handle these materials• Drywall and joint compound CANNOT be composited

for OSHA purposes

• Plasters and skim coats often show small percentages

• Exterior caulks may be lass than 1 % eliminating them from AHERA and DNR, but will your contractor want to re-use or recycle them (PEL, wet methods, prompt cleanup and disposal)

•MANUFACTURERS USED TO PUT LEAD IN

PIGMENT IN PAINT TO MAKE THE PAINT

LAST LONGER AND CLING TO SURFACES.

•LEAD IN THE PAINT CAN CAUSE SERIOUS

HEALTH EFFECTS TO SELECT INDIVIDUALS

INCLUDING CHILDREN UNDER THE AGE OF

6 AND EXPECTANT MOTHERS

Who Regulates Lead?

• WI DHS rule ( DHS 163 ) regulates exposures to building occupants

– 0.5% by chip sample

– 1.0 mg/cm2 by XRF

• OSHA rule ( 1926.62 ) regulates exposures to workers in the construction industry

• DNR regulates disposal of materials

Wisconsin Department of Health Services

• Manages Lead Paint related activities for both companies and individuals– Created DHS 163

– Manages Certification Process for subject facilities• Renovator, inspector, hazard investigator, worker, supervisor

– Manages Lead RRP Program for subject facilities• Renovation, Repair and Painting Rule

• All target housing built before 1978 (except Elderly and Studio)

• AND Child-Occupied Facilities built before 1978

– Daycares

– Public or private school with child under the age of 6

– Any building visited by the same child under 6 on at least 2 days a week provided each visit lasts 3 hours and combined annual visit is at least 60 hours per year

– Lead Paint defined as paint containing more than 0.5% by weight by chip sample or 1.0 mm/cm2 by XRF (JULY 2015 change)

DHS Lead Paint RequirementsSubject buildings

• Must sample or assume lead paint is present if disturbing more than 6 square feet- indoor or 20 sq ft-outdoor.

• Disturbance includes removal of component

• Certified Renovator and Company

• Notification to owner/occupant

• Posting of Pamphlet

• Training for all who enter work area

• Lead Safe Work Practices including dust control and isolation of work area with plastic

• Cleaning of work area

• Verification of cleaning by either cleaning verification card or dust wipe sampling

• Documentation of work

• Retention of records for at least 3 years

Is this an abatement company or your GC???

(most often we have no idea if lead is present or not when contracts are let)

OSHA and Lead• OSHA rule (1926.62) regulates exposures to workers in

the construction industry.– Contractors working in buildings outside the scope of DHS 163

MAY still have exposure to lead and could spread lead dust into buildings…• EXAMPLE 1: Elementary with lead below 0.5%

• EXAMPLE 2: HS or MS building

– Contractors MAY request Owner do sampling of paint on surfaces they may disturb, but be advised that OSHA only recognizes chip sampling results (not XRF)

• OSHA trigger task: Manual demolition, hand scraping, sanding (assume 10x the PEL…half face)

• OSHA trigger task: Manual demolition, hand scraping, sanding (assume 50x the PEL…full face)

• OSHA trigger task: Abrasive blasting, welding, cutting, torching (100+ the PEL…supplied air hood)

DNR Lead Regulations

• DNR regulates disposal of materials.

– Waste Disposal:• Intact lead paint on construction and demolition waste can be

landfilled

• Intact lead paint on recyclable metals can be sent to a recycler if the recycler is notified and will accept

• Intact lead paint on concrete CANNOT be crushed, pulverized, or otherwise disposed of as clean fill. Be aware of painted

• Low Hazard Waste Exemption for the ReUse of Concrete Coated with Lead Based Paint (permit to leave lead and place )

– If you remove paint, the debris and paint chips may be hazardous waste. Waste must stay onsite in a steel drum in a secured area. You must perform a test on the “ composite waste” after removal called a TCLP. If lab results exceed DNR standards, waste is “hazardous”

Common Mercury Containing Products Found in Schools

• Boilers & AHU’s• Thermostats• Switches & Relays• Instruments and measuring

devices– Thermometer– Barometer– Flowmeter

• SCIENCE ROOM DRAIN TRAPS (HAVE PLUMBER COLLECT WASTE IN TRAPS)

• INCLUDE BUDGET FOR DISPOSAL IF SCIENCE ROOMS ARE BEING RENOVATED

Wisconsin Department of Natural Resources (DNR)

• Mercury– Bans the sale and use of mercury in the State

– ALERT: Some poured/rubber floors installed in the 1990’s and early 2000 MAY have mercury present in floors

– EMC has tested and found mercury present (totals)at levels both below and above TCLP (disposal)

– DNR mercury disposal level (NR 661): 0.2 mg/l

– Anything above that level must be disposed of as HAZARDOUS WASTE ($6.00 - $8.00 /sq ft)

– Even levels below TCLP can release mercury into the air during removal projects…

– TEST BEFORE REMOVAL

Wisconsin Department of Natural Resources (DNR)

• SDWA (Safe Drinking Water Act)– Regulates use and testing of private wells including schools on

their own well– Certified Well Operator for system on their own wells– Routine sampling on a 9 year cycle

• Bacteria• Lead • Copper• Nitrates• VOC’s• SOC’s• IOC’s

– LEAD AND COPPER IN DRINKING WATER CAN BECOME ELEVATED DURING CONSTRUCTION AND RENOVATION PROJECTS

Wisconsin Department of Natural Resources (DNR)

• Recycling and Waste Management

Common Types of Waste

►Special Waste: Recycle or collect for other special handling

►Oil, filters, absorbents, lubricants, parts cleaners (must recycle – ban includes automotive, trucks, buses)

►Refrigerants (recycle)

►Electronics (recycle)

► Infectious (collect for incineration)

► Medications (collect for treatment)

► Lead Paint (landfill intact, collect non-intact for evaluation)

►Asbestos (collect for special disposal in landfill)

►Water-based cleaners and disinfectants (dilute to sanitary sewer as approved)

Common Types of Waste

►Universal Waste: Containerize, label, keep container closed, monitor for leaks, keep incompatibles separate, contact licensed hauler for proper disposal

►Mercury

►Batteries (NiCd, Lithium)

► Lead Acid batteries

►Antifreeze

► Lamps (fluorescent, CFL, mercury vapor, metal halide)

Do I need to recycle low-mercury (“green end cap”) fluorescent lamps?

• Under federal regulations, the Toxicity Characteristic Leaching Procedure (TCLP) determines if a lamp is a hazardous waste. Lamps that pass the TCLP test for mercury are not hazardous and therefore, are not subject to federal regulation. This test measures the leachability of certain metals, including mercury and organic constituents. Under this procedure, the waste leachate must contain less than 0.2 milligrams per liter (mg/L) of mercury in order to pass the test. Learn more about the TCLP. Some manufacturers of fluorescent tubes produce “low-mercury lamps” that they claim pass the TCLP test for mercury.

• The amount of mercury in a low-mercury bulb can range from 3.5 to 4 milligrams compared to a standard fluorescent bulb which ranges from 8 to 14 milligrams of mercury. These lamps may be identified by green end caps (often referred to as green-tipped lamps), or green etchings on the lamps.

• EPA encourages the recycling of all mercury-containing lamps, regardless of the mercury content. Note that if you do not test your low-mercury lamps and prove them non-hazardous, assume they are hazardous waste and handle them accordingly

Common Types of Waste

►Hazardous Waste: Properly label, containerize, keep container closed, monitor for leaks, store in building where generated, contact licensed hauler for proper disposal► Ignitable (paint thinners, solvents, strippers, etc.)

►Corrosives (certain cleaning solutions, science chemicals, etc.)

►Reactive Chemicals (science chemicals, bleaches, etc.)

►Toxics (photo labs, science, pesticides, metals, etc.)

►PCB’s

• Typically, status as Very Small Quantity Generator

• Do not move or transport waste unlabeled or improperly packed waste (science)

• Storage considerations: Where?, fire-rated, secure, tempered air, exhaust ventilation

• Fee from State!

Hazardous Waste ?

►PCB’s in Caulk

PCB’s in Schools & Other Buildings

• Where do you find PCB’s?

– Fluorescent Light Ballasts

• Prior to 1998 If no PCB’s, Labeled “No PCB’s”

– Electrical Transformers

• Many have been tested and labeled

– Caulking Materials

• Constructed in 1950’s through 1970’s

– Specialty Paints and Coatings

• Typically Industrial or Military Applications

Potential Exposure in Schools• EPA/NYC Study Pre-Remediation Air Sampling

– Building #1: Non-Detect – 142 ng/m3

– Building #2: Non-Detect – 1,005 ng/m3

– Building #3: Non-Detect – 225.9 ng/m3

– Building #4: Non-Detect – 867 ng/m3

– Building #5: Non-Detect – 674 ng/m3

– EPA Target Safe Level varies based on age from 70 to 600 ng/m3

– NIOSH – 1,000 ng/m3

– OSHA – 500,000 ng/m3

Renovation/Demolition

• EPA Currently Recommends testing building materials for PCB’s prior to Renovation or Demolition.

• WI DNR also Recommends testing for PCB’s prior to Renovation or Demolition

• Proper Characterization of Waste???

Disposal Requirements

• Bulk Product Waste

– Materials containing >50 PPM PCB

– FLB Not Labeled “No PCB’s”

• Disposal Options

– TSCA Incinerator

– TSCA/RCRA Landfill

Outside Contractor Notifications

Different Notifications

• Asbestos (EPA – AHERA)

• Confined Space (OSHA/DSPS)

• Hazard Communication (OSHA/DSPS)

• Indoor Environmental Quality (DPI)

• Lead – RRP (Wis. DHS)

• Lockout/Tagout (OSHA/DSPS)

Asbestos Notification Intent

• Schools must notify contractors and short-term workers about the presence of ACBM

1. Prevent ACBM from being accidently disturbed

2. If ACBM will be disturbed, the contractor must use trained, licensed workers and use work practices to prevent exposure and contamination.

Confined Space Notice

1910.146(c)(8) When an employer arranges to have employee of an other employer (contractor) perform work that involves permit space entry, the host employer shall:– Inform about presence of permit spaces

– Inform about hazards associated with spaces

– Inform any precautions or procedures

– Coordinate entry operations

– Debrief at the conclusion regarding any hazards confronted or crated during entry

Hazard Communication Notice

1910.1200(e)(2) – Multi-employer workplaces

– Inform methods to access safety data sheets (SDS)

– Inform any precautionary measures to protect employees during normal operations & foreseeable emergencies

– Inform of labeling system used in the workplace

Indoor Environmental Quality (IEQ)

DPI WI Stat. 118.075(4) School District IEQ Plans

– Inform about the IEQ plan

– Inform about the IEQ coordinator

– Provide a copy of the plan upon request

Lead – WI RRP

Wis. DHS 163.10 Information Distribution Requirements for Renovation Activities

• (d) Renovation activities in child-occupied facilities.

– Contractor must notify the owner and provide the following:

• Pamphlet

• Renovation Activities Information

What is Acceptable IEQ?

• Codes: Appropriate Air Exchanges (ASHRAE) varies depending on use -– Outdoor/Fresh Air & Control

Contaminant Levels (some discussed on next slides)

• Occupant Comfort (ASHRAE)– Temperature, Relative Humidity

– Different Building, Environmental and Personal Factors... GOAL: 80/20 rule – generally if 80% are happy, it’s good.

Potential IEQ Contaminants• Carbon Monoxide (CO) - Poor Combustion• Carbon Dioxide (CO2) - People Exhaling• Dust/Dust Mites, Dirt/Debris, Leaves• Pests (Rodents, Insects, Birds, Bats, etc…) Bacteria• Chemicals (cleaners, pesticides, air-fresheners)• Nitrogen Dioxide (NO2), Nitrite Oxide (NO), Natural Gas

from combustion/exhausts• New Building Materials (off-gassing): Volatile Organic

Compounds (VOC’s), Aldehydes, Formaldehyde, etc...• Human Related (odors, waste, etc…)• Building Related (kitchen waste/trash, etc…)• Environmental (asbestos, radon, sewer gas etc…)• Office Equipment (particulates, ozone)• Mold – Spores are everywhere & just need moisture

Indoor Environmental Quality (IEQ) Plan

• A 2012 DPI Rule requires ALL School Districts to have an IEQ Management Plan.

• IEQ Management Plan Must Include:1. Mission Statement

2. Roles of IEQ Coordinator

3. Communication

4. Reporting Procedures

5. Addressing IEQ Findings

6. IEQ Policies

7. Maintenance and Cleaning Procedures/Training

8. Staff Responsibilities for Maintaining good IEQ

9. Prevention of IEQ Issues

10. IEQ Complaint Form (DPI, EMC or Your Own District)

IEQ Related Services• Proactive Management Plan – IEQ staff training &

ongoing inspections, recommendations, etc….• Professional planning, management/oversight &

documentation of IEQ related projects (mold remediation, HVAC/duct cleaning, construction projects & IEQ, etc…) & IEQ construction planning.

• Assistance with occupant complaint response –visual inspections, sampling/testing/monitoring, lab analysis, reports, etc…

• Assistance with emergency response (fire & water loss events, summer mold on carpets, etc…)– IEQ issues can still happen even doing Proactive

Inspections, but now we know your facilities and have previous documentation and HVAC zone maps, which can aid/speed the response process.

Documentation–Bid Spec. Manual

Documentation-Photos: HVAC/Duct Cleaning: Before & After (Exhaust Duct)

Documentation–Sample Results

Construction IEQ

• PRIOR TO CONSTRUCTION:– Evaluation of construction activities and areas

affected as well as potential contaminants, pathways and building populations.

– Specification Manual preparation for some basic IEQ requirements (barriers, ventilation, cleaning, etc…) to expect, communicate and enforce with contractors.

– Pre-construction meeting to review and discuss IEQ spec./plan with all parties involved.

Construction IEQ

• DURING CONSTRUCTION:– Verify that IEQ spec./plan are being followed

• Barriers?

• Ventilation?

• Low or No VOC products?

• Noise?

• Walk-off Mats?

• Cleaning?

– Who is verifying (Foreman, Custodian, EMC)?

– CHECKLIST (See attached example)

Construction IEQ

• AFTER CONSTRUCTION:

– Time for off-gassing prior to re-occupancy?

– Final cleaning of work areas

– Change air filters

– Activate HVAC systems

– Conduct any testing (Dust, CO2, VOC’s, etc…)

• Acceptable results?

• Re-test if not?

Example: Construction in Health Care(Infection Control Risk Assessment)

• STEP 1 – Identify Type of Construction

– Type A: Inspection & Non-Invasive (No Dust)

• Painting, wall covering, electrical & minor plumbing

– Type B: Small Scale/Short Duration (Min. Dust)

• Access to chases/ceilings, cord/wire/cable installation

– Type C: Removal of Components (Mod. Dust)

• Sanding, floor removal, HVAC/ducting work

– Type D: Major Constr./Demo. (High Dust)

• Complete removal, multiple work shifts…

Example: Construction in Health Care(Infection Control Risk Assessment)

• STEP 2 – Determine Risk Group Affected

– Lowest Risk

• Custodial & Engineering Areas, Office Areas

– Medium Risk

• Cafeteria, Outpatient, Rehab, Radiology, MRI

– High Risk

• Emergency, Recovery, Laboratory, Café. (Food Prep.)

– Highest Risk

• O.R., Intensive Care, Sterilization, Pharmacy (admix)

Example: Construction in Health Care(Infection Control Risk Assessment)

• STEP 3 – Assign a Class of Work Based on a Combination of Construction Activity and Risk

Construction Activity

Risk Level Type A Type B Type C Type D

Lowest Level CLASS 1 CLASS 1 CLASS 2 CLASS 3/4

Medium Level CLASS 1 CLASS 2 CLASS 3 CLASS 4

High Level CLASS 1 CLASS 2 CLASS 3/4 CLASS 4

Highest Level CLASS 2 CLASS 3/4 CLASS 3/4 CLASS 4

Example: Construction in Health Care(Infection Control Risk Assessment)

• CLASS 1

– No significant dust

– Keep doors closed to work area

– Immediately clean work area when done

• CLASS 2

– Seal doors with tape or plastic flaps

– Block off air vents and isolate HVAC system

– Mist work area and materials to control dust

Example: Construction in Health Care(Infection Control Risk Assessment)

• CLASS 2 (cont.)

– Wet mop and HEPA vacuum work area

– Utilize walk-off mats at entry/exit

– Wipe surfaces with disinfectant

• CLASS 3

– All CLASS 2 items PLUS…

– Physical barriers

– Seal all penetrations (pipes, conduit, etc…)

Example: Construction in Health Care(Infection Control Risk Assessment)

• CLASS 3 (cont.)

– Negative pressure in work area with HEPA unit

– Wipe/HEPA vacuum personnel, tools, waste

– Clean HVAC & air ducts prior to completion

• CLASS 4

– All CLASS 3 items PLUS…

– Decontamination area

– Full body covers (suits, shoe covers, etc…)

– Testing Recommended

Example: Construction in Health Care(Infection Control Risk Assessment)

• STEP 4 – Identify the Potential Impact of the Project in Surrounding Areas

– Take precautions as needed to protect

• STEP 5 – Review Traffic Flow and Debris Control to/from Work Area

– Take precautions as needed to address

• CONSIDER - Should some of these steps be included as part of your next project?

Construction Safety Considerations

• OTHER CONSIDERATIONS:

– MSDS (SDS) Management

• Chemicals brought into your buildings by other trades

• What is your plan to obtain MSDS sheets?

– Soil Contamination

• Former UST sites properly closed?

• Neighboring contamination

• Building on top of old foundations/buildings is commonplace in certain locations

– Fire Safety Plans

Construction Safety Considerations

• OTHER CONSIDERATIONS:

– Evacuation routes

NEW CONSTRUCTION PLANNING• GLASS IS EVERYWHERE!!!

DURING CONSTRUCTION

• Life Safety Standards

• Effective Signage

• Exit Lighting, Dead-end Corridors

• Traffic flow patterns (emergency personnel, busing and parent drop-off)

• Evacuation drill changes

• Staff needs to be trained on plan

You Must Review the Plan

REVISED EVACUATION/SHELTER POSTINGS

• Must be posted in all occupied areas

• Must be Readable & Understandable

Safety and Environmental Concerns During Construction

• Planning Ahead is the Key to a successful project• Should I do a Phase 1 or 2 prior to determining

budget for my project ?• How do I obtain accurate budget?• Planning ahead can avoid construction delays and

cost overruns• How do you protect the occupants during the

process• Dust, debris and other issues left behind for you

after the contractors leave• Unknowns can change “finished” product and have

significant impact on final product presented to public

Securing Safer Futures…W7748 County Hwy. V, Lake Mills, WI 53551-9643

920.648.6343 www.emc-wi.com