Update on Hazardous Materials in Construction CAWIC Slides.pdf · Metal Workers 22 Plasterers and...

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© Pinchin Environmental Ltd 2007

Update on Hazardous Materials in Construction

CAWIC

Bruce Stewart, B.Sc., DOHS, CIH, ROHElvira De Gasperis, B.Sc., CRSP

Pinchin Environmental Ltd.January 28 2010January 28, 2010

Outline for this EveningOutline for this Evening

• Ministry of Labour enforcement

• Responsibilities for:• Designated Substance reporting

• Asbestos

• Lead

• SilicaSilica

• Construction in health care settings

• Mould

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Pinchin Environmental Ltd.Pinchin Environmental Ltd.

• Pinchin EnvironmentalEnvironmental, established in 1981, 250 employees

• Part of the Pinchin Group of Companies

• 26 offices across• 26 offices across Canada, more than 450 employees

Hazardous Materials Hazardous Materials ManagementManagement

• Asbestos, lead, mercury PCB etcmercury, PCB, etc.

• Surveys and assessments

• Assistance with regulatory compliance

Ab t t j t• Abatement project management

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IAQ & Mould ServicesIAQ & Mould Services• Investigations for IAQ, mould,

Legionella

• Construction infection control• Construction infection control

• Management programs

Laboratory ServicesLaboratory Services

• Asbestos• MouldMould • Legionella• Odour

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OH&S ServicesOH&S Services

• OHS Management ConsultingConsulting • Program Development

• Auditing

• Technical Services, e.g.• Occupational hygiene• Occupational hygiene

• Confined space

EnvironmentalEnvironmentalAir & Noise ServicesAir & Noise Services

• Odour • Air & noise permittingAir & noise permitting • Stack testing• Pollution abatement• MOE negotiations

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Environmental Due Environmental Due Diligence & RemediationDiligence & Remediation

• Environmental site assessments, building condition reviews g

• Site remediation

• Risk assessment

• Hydrogeology and groundwater management

• Compliance audits & environmental pmanagement systems

• Water testing, pollution prevention

GHG ManagementGHG Management

• Carbon footprints

• Mitigation & offset strategiesMitigation & offset strategies

• Carbon neutral strategy

• Green strategy development

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Building Sciences Building Sciences

• Building condition assessmentsassessments

• Leak and failure investigations

• Designs for repair and project management

E dit• Energy audits

Ministry of Labour Enforcement

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Ministry of Labour EnforcementMinistry of Labour Enforcement• More than 200 inspectors hired in last 4 years,

now 450. • Ministry continues to run enforcement blitzes on

asbestos and Designated Substance reporting. See MOL Construction Sector plan.

• Construction Exposure Incident Report initiated by WSIB, 2009:• Program to record unexpected potentially

hazardous exposures on construction sites (spillshazardous exposures on construction sites (spills, process events, etc.).

• Fatalities and Immediate Response protocol established January 2010 jointly with WSIB, follow-up to Christmas Eve fall accident.

MOL Enforcement of Hazardous MOL Enforcement of Hazardous MaterialsMaterials

• Asbestos a top priority for MOL enforcement.

• WSIB concerned re rising disease claims• WSIB concerned re. rising disease claims (~40% of WSIB construction costs).

• Pinchin trained Central Region inspectors on asbestos, mould training, 2009.

• Other OHS construction issues on horizon:• Musculoskeletal damage (MSD)

• Welding fume

• Lead

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Workers Dying of Asbestos Disease, Accepted Workers Dying of Asbestos Disease, Accepted WSIB Claims (1996WSIB Claims (1996--2005)2005)

Plumbers/ Pipe Fitters & Related 74Insulators 43Labourers 38Electricians 36Electricians 36Metal Workers 22Plasterers and Related 13Foremen 9Carpenter 7Brick / Stone Mason 14Mechanic 5Mechanic 5Welder / Flame Cutter 5Painters 3Other 22

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Examples of Fines under O.Reg. 278/05Examples of Fines under O.Reg. 278/05

• Renovation of Government Building (Kingston)• Owner provided contractor with out of date asbestos

survey, did not report on plaster. Contractor performed renovation and disturbed ACM plaster withoutrenovation and disturbed ACM plaster without precautions. Fines of $80,000 against the City (for failing to report) and $70,00 against the contractor (for work disturbing ACM without Type 3 precautions).

• Townhouse (Oshawa)• Owner of complex arranged work on water pipes without

W k t t d d id t ll d MOLa survey. Work was started and residents called MOL with asbestos concerns. Owner and facility manager fined approximately $60,000 for lack of a survey and for performing Type 2 work without proper procedures.

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Designated Substance Reporting for Projects

Section 30 of the Occupational H lth d S f t A tHealth and Safety Act

List of Designated Substances:List of Designated Substances:

Asbestos Lead Mercury SilicaBenzene Coke Oven EmissionsIsocyanates AcrylonitrileArsenic Vinyl chloride monomerEthylene oxideEthylene oxide

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Duties of Owner or Agent:Duties of Owner or Agent:

• Prepare a list of Designated Substances (lead asbestos mercury silica etc ) present(lead, asbestos, mercury, silica, etc.) present on the project, and include the list in any tender call.

• Ensure contractors and subcontractors bidding on work receive copies of thebidding on work receive copies of the Designated Substance report.

Liabilities of Owner or Agent:Liabilities of Owner or Agent:

“An owner who fails to comply is liable to the constructor and every contractor and subcontractor who suffers any loss or damages as the result of the subsequent discovery on the project of a designated substance that the owner ought reasonably to have known of but that was not on the list...”

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Duties Duties and Liabilities and Liabilities of Constructor:of Constructor:

• The constructor is liable to contractors for failure to inform of Designated Substancefailure to inform of Designated Substance that was on the list prepared by the Owner.

• The Constructor shall provide with "Notice of Project" submitted to the Ministry of Labour, listing of Designated Substances likely to be used, handled or disturbed on the project., p j

Update on AsbestosUpdate on Asbestos

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Friable vs. Nonfriable Asbestos Friable vs. Nonfriable Asbestos Containing Materials (ACM)Containing Materials (ACM)

• Friable:

A t i l th t hA material that when dry, can be crumbled, pulverized or powdered by hand pressure or a material that is crumbledthat is crumbled, pulverized or powdered.

Spray Applied Asbestos ProductsSpray Applied Asbestos Products

• Fireproofing• Acoustic insulation• Thermal insulation• Decorative finish

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Acoustic, Texture PlastersAcoustic, Texture Plasters

Mechanical Insulation Mechanical Insulation

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NonNon--Friable ACM: AsbestosFriable ACM: Asbestos--Cement (Transite) Cement (Transite) ProductsProducts

Flooring Products Flooring Products --Vinyl Asbestos Tile, Vinyl Asbestos Tile, Sheet Flooring and Flooring AdhesivesSheet Flooring and Flooring Adhesives

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Drywall Joint Compound, Ceiling Tiles Drywall Joint Compound, Ceiling Tiles and Plaster and Plaster –– (Potentially Friable?)(Potentially Friable?)

Roofing Felt and AsphaltsRoofing Felt and Asphalts

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Last Dates of Use of AsbestosLast Dates of Use of Asbestos--Containing Containing Materials (to the best of our knowledge)Materials (to the best of our knowledge)

Sprayed F/P and Thermal < 1975

Texture/Acoustic < 1983

Mechanical ≈ 1980

Ceiling Tiles ≈ 1982

Flooring VAT/VSF ≈ 1986

Drywall Joint Compound < 1980/1982

Roof Coatings ≈ 1992

Gaskets Now

Transite Now

The Ontario Asbestos in Buildings RegulationBuildings Regulation

(O.Reg. 278/05)

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O. Reg. 278/05 O. Reg. 278/05 ---- ApplicationApplication• Every building with material which may contain asbestos and

the owner of the building.• Exemption for owners responsibilities for private residences p p p

(4 units or fewer, occupied by owner) (no exemption for any other part of regulation).

• Exemption from regulation for process maintenance covered by Industrial Regulation.

• Repair, alteration or maintenance.

• Construction projects.p j

• Demolition projects. Must remove ACM before demolition.

• Repair, alteration or maintenance of machinery, equipment and vehicles with ACM.

Responsibility of OwnerResponsibility of OwnerBefore Requesting Tenders or Before Requesting Tenders or

Arranging for WorkArranging for Work1. Prior to demolition, alteration or repair shall

have friable and non friable material inspected (if asbestos inventory not adequate).

2. Have report (plans, drawing or specifications) prepared showing location of all ACM which may be handled, disturbed, removed, etc. If report does not exist or suspect material not p ptested it is to be assumed to be ACM.

3. Report must give location, condition and state if friable or non-friable.

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Responsibility of OwnerResponsibility of OwnerBefore Requesting Tenders or Before Requesting Tenders or

Arranging for WorkArranging for Work

4. Furnish report to all prospective t t t t dconstructors, contractors and

sub-contractors. (Must also provide report of other Designated Substances – lead, silica, etc.)

5. If suspect ACM material is found on a project which was not identified in the reportproject which was not identified in the report, stop work, notify MoL, owner, contractor and JHSC, and analyze material or proceed as if asbestos other than chrysotile.

Type 1 OperationsType 1 Operations

1. Removal of disturbance of non-friable materials with hand tools and wettingmaterials with hand tools and wetting.

2. Removal of up to 1 m2 drywall with ACM joint compound.

3. Removal of up to 7.5 m2 ACM ceiling tiles.

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Type 2 OperationsType 2 Operations

1. Minor removal of friable material, less than 1 m2.

2. Removal of more than 1 m2 drywall with ACM joint compound.

3. Removal of more than 7.5 m2 ACM ceiling tiles.

4 Entering into a ceiling space with ACM4. Entering into a ceiling space with ACM debris.

5. Repairing friable ACM.

Type 2 Operation (Minor Friable Removal or Type 2 Operation (Minor Friable Removal or Major Removal of ACM Ceiling Tiles) Major Removal of ACM Ceiling Tiles)

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Drywall Removal Drywall Removal ––Type 2 Type 2 Operation if More than 1 mOperation if More than 1 m22

Type 3 OperationsType 3 Operations1. More than minor removal of friable material (> 1

m2).2 Spray application of a sealant to friable ACM2. Spray application of a sealant to friable ACM.3. Power tool disturbance of ACM without effective

HEPA dust collection.4. Repairing, altering or demolishing all or part of any

building in which asbestos is or was used in the manufacture of products, unless cleaned by 1986.

5. Work on HVAC in building with ACM sprayed fireproofing.

6. Work on kiln, metallurgical furnace or similar, with ACM refractory material.

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Typical Type 3 Typical Type 3 OperationsOperations

Major Work Major Work --Type 3 Operations, Type 3 Operations, Work Areas Under Reduced PressureWork Areas Under Reduced Pressure

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Packaging, Transport, Disposal of Packaging, Transport, Disposal of Asbestos WasteAsbestos Waste

Application of Sealer after Removal Application of Sealer after Removal –– not not Required by Regulation but Industry PracticeRequired by Regulation but Industry Practice

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Air Monitoring Clearance Prescribed after Air Monitoring Clearance Prescribed after Type 3 WorkType 3 Work

Lead inLead in Construction

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1.1. Historic Architectural PaintsHistoric Architectural Paints

• High lead paint in common use until 1940’s; some lead in paint until 1976 when reduced to 0.5%. Homes, apartments, offices, schools.

• Hazard if in poor condition or during renovations• Children and fetus at greatest risk.• Ministry of Labour has no “safe” level of lead in

paint.

2.2. RustRust--inhibitinginhibiting PaintsPaints

• Paint on automobiles, bridges, structural steel, etc.Ab i bl ti t l• Abrasive blasting, power tool disturbance, hot work, produce very high exposures.

• Environmental protection may be important during paint removal to minimize pspread to surrounding surfaces.

• Industrial conversions a concern.

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3.3. Hazards from Hazards from Past Uses of Lead in Past Uses of Lead in Buildings (Brownfield Buildings)Buildings (Brownfield Buildings)

• Soldering operations.

• Electronics manufacturing

• Firing ranges

• Lead sheeting

• May have resulted in significant settled dust t i ti f i HVACcontamination on surfaces, in HVAC.

4.4. Pointing Pointing MortarMortar

• Pointing mortar:• 5-10% lead, commonly added to whiten

mortar, • 45% crystalline silica.

• Restoration work can produce very high lead and silica exposures, contaminate the surrounding area.

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Ministry of Labour Lead on Ministry of Labour Lead on Construction Guideline (2004)Construction Guideline (2004)

• Developed in consultation with CSAO, industry stakeholders.

• Guideline is not mandatory to follow but can be used by MoL in judging compliance with due diligence requirements.

• Pinchin recommends these as a minimum• Pinchin recommends these as a minimum for good practice, look to US OSHA for more detail.

Type 1 Lead OperationsType 1 Lead Operations--All airborne exposures should be under exposure All airborne exposures should be under exposure

limit.limit.

1. Applying lead-based paint (LBP) with brush or roller.roller.

2. Removal of LBP with chemical gel or paste.

3. Removal of LBP using power tool with effective HEPA filtered dust collection.

4. Installation or removal of lead-containing sheet metal, packing, anchors, babbit or similar material.

5. Removal of LBP using non-powered hand tools, other than manual scraping or sanding.

6. Soldering.

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Type 2a Lead OperationsType 2a Lead Operations

1. Welding or hot cutting of LBP coated materials outdoors. (Only a Type 2a operation if short term, not repeated, and if LBP has been stripped prior to hot operation. Otherwise, consider a Type 3a operation.)

2. Removal of LBP by scraping or sanding using non-powered hand tools.

3. Manual demolition of lead-painted plaster walls or building components by striking a wall with sledgehammer or similar tool.

Type 2b Lead OperationType 2b Lead Operation

1. Spray application of lead-containing coatingscoatings.

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Type 3a Lead OperationsType 3a Lead Operations

1. Welding or high temperature cutting of LBP on materials indoors or in a confined space.

2. Burning of a surface containing lead.2. Burning of a surface containing lead.

3. Dry removal of lead-containing mortar using electric or pneumatic cutting device.

4. Power tool LBP removal without HEPA dust control.

5. Removal, repair of ventilation system used to control lead.

6. Demolition or cleanup of a facility where lead-containing materials were manufactured.

7. An operation that may exposure a worker to lead, but is not classified as Type 1, 2 or 3b.

Type 3b Lead OperationsType 3b Lead Operations

1. Abrasive blasting of lead-containing coatings or materials.

2. Removal of lead-containing dust using an air mist extraction system.

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Silica in Construction

Ministry of Labour Ministry of Labour Silica oSilica on n Construction Guideline (2004)Construction Guideline (2004)

• Developed in consultation with CSAO, industry stakeholders.

• Guideline is not mandatory to follow but can be used by MoL in judging compliance with due diligence requirements.

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Silica Materials in Construction Silica Materials in Construction

• Free crystalline silica (silicon dioxide), not silicon or silicone. Only finely divided dust < 5 µm diameter (respirable dust) a hazard.• Sand

• Concrete

• Brick, refractory brick (furnaces, ovens, etc.))

• Stone products – granite, sandstone, slate, quartzite, etc.

• Use of sand as abrasive blast media

Type 1 OperationsType 1 Operations(1(1--10X Occ. Exposure Limit)10X Occ. Exposure Limit)

1. Drilling into concrete or rock that is not tunneling or road constructionroad construction.

2. Milling of asphalt from concrete highway pavement.

3. Charging mixers with silica sand or silica flour.

4. Entry into dry mortar removal or abrasive blasting area while airborne dust is visible, for less than 15 minutes for inspection/sampling.

5. Working within 25 metres of area where compressed air is being used for removing silica containing dust outdoors.

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Type 2 OperationsType 2 Operations(10(10--50X Occ50X Occ.. Exposure Limit)Exposure Limit)

1. Jackhammer removal of silica refractory.

2. Drilling of holes in concrete or rock during tunneling or road constructionconstruction.

3. Use of power tools to cut, grind or polish concrete, terrazzo or refractory materials.

4. Use of power tool to cut silica containing materials.

5. Tunneling (operation of tunnel boring machine, tunnel drilling, tunnel mesh installation).

6 Tuck point and surface grinding6. Tuck point and surface grinding.

7. Dry mortar removal with electric or pneumatic cutting device.

8. Dry method dust cleanup in blasting operations.

9. Entry into blasting enclosures for > 15 minutes.

Type 3 OperationsType 3 Operations(> 50X Occ(> 50X Occ.. Exposure Limit)Exposure Limit)

1. Abrasive blasting with an abrasive

t i i 1% ilicontaining > 1% silica.

2. Abrasive blasting of a surface containing > 1% silica.

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Preventing Infections in Health Care Construction

CSA Standard to Prevent CSA Standard to Prevent Infections in Health Care SettingsInfections in Health Care Settings

• Set to decrease the risk of hospital acquired infectionshospital-acquired infections during construction and maintenance work:

• Fungal infections from spores in settled dust;

• Legionnaires' disease• Legionnaires disease.

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Classification MatrixClassification Matrixfor Preventative Measuresfor Preventative Measures

Construction Activities

Risk Group

Type A Type B Type C Type D

Group 1

I II II III / IV

Group 2

I II III IV2

Group 3

I III III / IV IV

Group 4

III* III / IV III / IV IV

*

Mould inMould in Buildings

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Mould Growth in BuildingsMould Growth in Buildings

• Mould spores present everywhere germinateeverywhere, germinate within 24 hours of wetting, can produce abundant spores within 48 hours.

• Caused by construction floods envelope failurefloods, envelope failure, spills, floods, condensation, etc.

Growth Surfaces iGrowth Surfaces in Buildingsn Buildings

Organic substrate with suitable nutrients, e g :e.g.:• Cellulose:

• Drywall• Wood• Ceiling tiles• Cardboard, building

paperpaper• Soil in carpets• Plastics• Fabrics

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Growth in Air Handling UnitsGrowth in Air Handling Units

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Regulations and Guidelines re. Mould

Ontario Ministry of LabourOntario Ministry of Labour

• Dec 2000 Hazard Alert confirmed mould as workplace hazardworkplace hazard.

• “Mould growth on the interior surfaces of buildings is a risk factor for health problems.”

• Ministry enforces precautions under due diligence requirements (25(2)h), refers employers to professional guidelines.

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Health Canada: Residential Indoor Air Health Canada: Residential Indoor Air Quality Guideline for Moulds (March 2007)Quality Guideline for Moulds (March 2007)

…”After reviewing the most recent scientific evidence regarding moulds and their effectsevidence regarding moulds and their effects on health, the Minister (of Health) recommends• To control humidity and diligently repair any

water damage in residences to prevent mould growth; and

• To clean thoroughly any visible or concealed g y ymould growing in residential buildings.

These recommendations apply regardless of the mould species found to be growing in the building.”

Public Health, Building DepartmentsPublic Health, Building Departments

• Public Health, responsible for public buildings:• Health Promotion and Protection Act

• Building Standards department may act on conditions in rental housing • Municipal bylaws• Residential Tenancies Act 2006 O. Reg. 517/06

• Marijuana grow houses, meth labs: • Municipal Clerk responsible since 2005 (Bill 128) to p p ( )

assess for safety when grow houses (or meth labs) identified. Regional responses vary.

• Electrical Safety Authority allowed to shut off power, will not re-engage power until property passed by CIH, ROH, etc.

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General LiabilityGeneral Liability

• Mould lawsuits have increased tremendously in Canada e gin Canada, e.g.• Owner vs. builder

• Tenant vs. landlord

• Owner vs. consultant

• Owner vs. abatement contractor

• Purchaser vs. vendor/realtor

• Homeowner vs. building official

Canadian Construction Association Canadian Construction Association Mould Guidelines, 2004Mould Guidelines, 2004

• To assist contractors in reducing risk of mould• Background

• Legal

• Insurance

• Health concerns

• Design, construction practices to prevent mould growth

• Assessment of mould

Mould remediation guidelines• Mould remediation guidelines

• Hazard communication

• Demolition considerations

• Choosing a contractor

• www.cca-acc.com

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Consensus Points for Mould ControlConsensus Points for Mould Control

Risk AssessmentRisk Assessment

• Mould growth occurs rapidly after wetting. g p y gAfter 48 hours, must be suspected on susceptible materials.

• Where the water source contains human pathogens (e.g., sewage), abatement practices must be enhanced.practices must be enhanced.

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Health RiskHealth Risk

• All mould growth poses a health risk to occupants regardless of species and mustoccupants, regardless of species, and must be abated.

• Risks must be communicated to occupants:• In workplaces, joint health and safety

committees must be informed, invited to see testing, and receive oral or written reports. g, p

• Duty to warn? NYC Guideline advises that a reacting occupant be referred to a physician and given copies of environmental assessments.

Susceptible Susceptible OccupantsOccupants

• Particularly susceptible occupants (infants, elderly, health care settings, immuno-compromised, etc.) require additional care:• May be a need to relocate reacting or

susceptible individuals immediately.

• During remediation, should re-locate from the u g e ed a o , s ou d e oca e o eimmediate area, and possibly from adjacent areas.

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RemediationRemediation

• Underlying causes of mould growth must be remedied prior to completion of cleanup.

• “Building materials supporting fungal growth must be remediated “as soon as possible”.

• Porous materials supporting mould growth must be removedmust be removed.

Work Practices Work Practices and Oversightand Oversight

• Detailed procedures given for multiple levels of k d di t t f ld thwork, depending on extent of mould growth

(although these vary between guidelines).• Work area isolation and precautions

• Worker protection (PPE and hygiene precautions)

• Waste packaging

Cl i• Cleaning

• Professional oversight, quality assurance measures recommended for medium and large scale remediation.

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Mould Remediation Guidelines (CCA/ Mould Remediation Guidelines (CCA/ Environmental Abatement Council of Environmental Abatement Council of

Ontario)Ontario)

Extent of Mould-Affected MethodMaterial

General Areas: <1 m2 (<10 sf) Level I (Small)

General Areas: 1-10 m2 (10-100 sf) Level II (Intermediate)

General Areas: >10 m2 (>100 sf) Level III (Large)

HVAC Contamination: <3 m2 HVAC, Small

HVAC Contamination: >3 m2 HVAC, Large

Mould AbatementMould Abatement

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Questions?Questions?

Bruce Stewart, CIH, ROH

bstewart@pinchin [email protected]

(905) 363-1388

Elvira De Gasperis, CRSP

[email protected]

(905) 363-1314(905) 363 1314

For more information on services:

www.pinchin.com

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