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Hygieneering, Inc.
News & Updates
July 2022
Featured Service
WRITTEN OSHA SAFETY & HEALTH
MANAGEMENT PROGRAMS
Recently, Hygieneering assisted an international client with EHS due diligence services in the purchase of a medium sized manufacturing plant in the Chicagoland area. One of the deficiencies noted in the due diligence process was written OSHA program documents and implementation of associated compliance tasks. The deficiency was severe, with many required written OSHA programs not existent or significantly inadequate for compliance purposes. The following topics were identified in the due diligence compliance gap assessment process as needing development/updating:
Programs
Hazard Communication
Lockout Energy Control
Bloodborne Pathogens
Emergency Evacuation Plans
First Aid
Fire Prevention Plans
Hearing Conservation
Hot Work
Personal Protective Equipment
Respiratory
Fall Protection
Confined Space
Electrical Safety Arc Flash
Forklift
Elevated lift
Cranes
OSHA Standard
29 CFR 1910.1200
29CFR 1910.147
29CFR 1910.1030
29CFR 1910.38
29CFR1910.151
29CFR1910.39
29CFR1910.95
29CFR1910.253
29CFR1910.132
29CFR1910.134
29CFR1910.29
29CFR1910.146
29CFR1910.304
29CFR1910.178
29CFR1910.66
29CFR1910.179
To address this need in a cost effective manner, Hygieneering provided an EHS professional on site. This allowed us to make the programs site specific and address multiple topics at once. The basic scope of services was as follows:
 
  1. Hygieneering lead a pre-project planning meeting to discuss needs, expectations, and project deliverables with the management team. A prioritization list of OSHA topics was presented with an action plan of how each program would be addressed and how we would direct our efforts.
  2. Hygieneering provided written daily and weekly updates to our main contact for the project that summarized activities performed and milestones.
  3. Draft written programs were provided for client review and feedback. We worked with the client to finalize each document.
  4. In addition, an OSHA training matrix was prepared to support associated worker safety and health training requirements identified in the individual written OSHA programs. This training was implemented under a separate contract following the completion of all the written programs.
 
This is merely one example of why clients turn to Hygieneering EHS Professionals to up their OSHA Written Program Documents. Other clients desire a 3rd party review to ensure OSHA compliance and others just need assistance with an ever changing work environment. A general recommendation is to conduct a review and update of your OSHA written programs on an annual basis. Have you looked at your written programs lately?


Contact Kevin Konkey today to make sure your business is safe & compliant!
630.706.6681 | KKonkey@hygieneering.com 

Learn more about this service and others by visiting our brochure page.
Project Spotlight
Ambient Air Monitoring

Hygieneering conducts property line nuisance dust assessment for clients to evaluate ambient dust concentrations leaving their property. Sampling is focused on single sources, as snapshots of contaminant concentrations are collected over several short (24-hour) periods of time. The particulate matter (PM) data collected from these studies are compared to the National Ambient Air Quality Standards (NAAQS) established by the United States Environmental Protection Agency (USEPA). Under the Clean Air Act, the USEPA established NAAQS for conventional pollutants, including particulate matter (PM). The NAAQS includes both primary and secondary standards for PM, such as 35 ug/m3 (24-hour) for PM 2.5 and 150 ug/m3 (24-hour) for PM 10. Primary NAAQS are health-based standards intended to “provide public health protection, including protecting the health of “sensitive” populations such as asthmatics, children, and the elderly. Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.” (US EPA, 2018a)

The NAAQS standards were developed to assist in evaluating air quality on a regional basis and were not intended for single source emission limited for properties. However, there are no quantitative PM limits that are directly applicable to these data. Therefore, NAAQS levels are used only for reference or benchmark comparisons to assist in site recommendations and data evaluations for Hygieneering clients looking to improve and evaluate dust emissions from their operations or site.

At the state level, 35 Illinois Admin. Code Section 212 addresses emissions of particulate matter. The only standard applicable to fugitive emissions of particulate matter from this source are found at 35 IAC 212.301, which states: “No person shall cause or allow the emission of fugitive particulate matter from any process, including any material handling or storage activity, that is visible by an observer looking generally toward the zenith at a point beyond the property line of the source.” Hygieneering conducts visual observations while onsite to comply with this code.

Conducting the fugitive dust study involves the use of TSI DustTrak DRX weather-resistant enclosures that are set to data log for 24-hour periods, particulate matter size 2.5 and 10, as used by the USEPA for National Ambient Air Quality Standards. The DustTrak DRX units provide real-time dust monitoring that simultaneously measures both mass and size fraction. The DustTrak DRX monitor uses light-scattering laser photometers that provide real-time aerosol mass readings and data logs. The instruments subdivide the concentration of dust by particle size with the following breakdown: Total, PM 10, Respirable, PM 2.5, and PM 1. Hygieneering can also conduct ambient air monitoring for respirable crystalline silica including all three (3) forms (quartz, cristobalite, tridymite) using active sampling methods for 8-hour periods to determine if silica dust is present, and leaving the site, per clients request. Other requests include the use of weather stations that can collect, rainfall amount, temperature, and most important wind speed and direction during the sampling periods. Typically, two (2) to four (4) dust monitoring enclosures are set up around the property line and monitored over several days, during dry periods with little to no rain, to get representative data collection for this type of study.

Hygieneering has been assisting with dust monitoring with clients in many industries including mining, construction, general industry, and even in healthcare during renovation projects. If you have a demolition project, renovation work, or need to assess your operations fugitive dust emissions, this type of study may be valuable for your company.

Hygieneering Celebrations
July Birthdays
Happy birthday to the following team members who celebrate in July!

Jodi Bates 7/12
Jim McIntyre 7/30
Company Anniversaries
Congratulations to the following people who are celebrating milestones this month at Hygieneering! Thank you for your hard work and dedication throughout the years!

Jeff Clark - 15 years
Association Participation
ASSP Wisconsin
Annual Golf Outing
Hygieneering, Inc. sponsored and participated in the ASSP Wisconsin Chapter Annual Golf Outing on June 14, 2022. The event gathered over 150 EHS professionals.

Association of Subcontractors & Affiliates (ASA) Chicago
51st Annual Golf Outing

Hygieneering, Inc. sponsored and participated in the Association of Subcontractors and Affiliates (ASA Chicago) 51st Annual Golf Outing on June 17, 2022.

Safety News
Supreme Court Restricts EPA's Authority to Mandate Carbon Emissions Reductions
In a 6-to-3 decision, the Supreme Court ruled that the Environmental Protection Agency does not have the authority to regulate the carbon emissions of power plants. Those rules never actually went into effect, but the ruling is still a win for the West Virginia officials, as well as coal mining companies who brought the case against the EPA. Critics of the decision, meanwhile, including the court's three-member minority, argued that the ruling upends nearly a century of regulatory law and bodes poorly for the country's future efforts to write necessary rules in a fast-changing environment.

Read the EPA's response to the ruling here.