September/October 2016
Control contamination from airborne lead or other metals to keep employees breathing easy.
By Megan Quinn
When a Scrap Metal Services shredder yard in New Carlisle, Ind., decided to start processing obsolete painted scrap such as old beams and forklift parts, Steve Forystek drove to the yard to do some tests. His goal? Find out if the material, especially the paint, would expose workers to dangerous levels of lead or other airborne hazards.
Forystek, a certified safety professional and certified hazardous materials manager with SMS (Burnham, Ill.), does this type of health check anytime one of its 11 locations changes the way it processes materials or accepts a type of scrap it hasn’t handled before. When material gets crushed, torchcut, shredded, or sheared, tiny particles that might contain lead, mercury, cadmium, hexavalent chromium, manganese, or other metals can become airborne. Those are hazards no one wants to breathe in or take home on his or her work clothes because accidental inhalation or ingestion can lead to illness, he says. According to the Occupational Safety and Health Administration, some of the common ways workers might become exposed to airborne particles of metals such as lead is through torchcutting, welding, or using heat guns, sanders, or scrapers to remove paint from metal. OSHA requires air testing and proper personal protective equipment and work practices, but Forystek says it’s much more than just regulatory duty that drives him to test scrapyards for these hazards. “SMS cares about preventing illness to our employees, and it drives our compliance activities,” he says.
To prevent workers from breathing in or ingesting lead or other particles that can cause serious health problems in large doses, identify potential airborne hazards in your yard, conduct air quality tests to find out how exposed your workers might be, then find ways to reduce or eliminate those hazards. Some scrapyards handle this task by hiring an industrial hygienist or a qualified safety professional. Others conduct their own internal safety audits, update their PPE requirements for certain tasks, or even call for PPE beyond what OSHA requires. Some have even decided to eliminate high-risk jobs, such as torchcutting, from workers’ responsibilities.
What’s at Stake
Chronic inhalation or ingestion of lead or other metals can cause major health impacts, such as kidney, nervous system, and cognitive problems and high blood pressure, OSHA says. When not properly controlled, airborne hazards also could affect your employees’ families. For example, a worker in Cincinnati who dismantled cathode-ray tubes as part of his job sued his former employer in February, saying unsafe working conditions at the electronics recycling facility sickened his two young children with lead poisoning. The facility, which is now closed, had received repeated OSHA citations for not training employees about lead exposure dangers, not providing changing rooms or uniforms to protect them from such exposure, and failing to train employees on how to use respirators. The employee, who wore his street clothes at work, cuddled his children in the same clothes when he got home each day, the Cincinnati Enquirer reported, potentially transmitting lead from his clothing to them.
Though concern for your employees’ health should be paramount, there also are monetary considerations when your facility doesn’t control lead or other airborne metal hazards, Forystek says. For example, OSHA fined an electronics recycler $114,000 in 2015 for employee exposure to lead, cadmium, and other airborne metal hazards. It cited the recycler for employee overexposure to lead in a circuitboard separation area, failure to provide ventilation to reduce lead exposure in the Zorba area, allowing employees to have facial hair while wearing respirators, and failure to fit-test employees who use respirators. The company also had no written respiratory protection program and allowed employees to wear lead-contaminated clothing home. There were no clean changing rooms, no shower rooms, no vacuuming of clothes before entering the lunchroom, and no biological monitoring of employees exposed to lead.
Testing for Hazards
Workers in scrapyards handle metal, electronics, or other scrap materials every day, but that does not mean they are automatically exposed to dangerous levels of airborne hazards, says Terry Cirone, ISRI’s vice president of safety. Simply picking up a piece of metal or moving it around the scrapyard is unlikely to cause an airborne or ingestion hazard, she says. But when that same piece of material goes through a cutting or grinding process or is heated up through torching, it may create emissions or dust that can get in a worker’s mouth or lungs. Because a material’s potential toxicity depends on varying factors such as its chemical makeup and the processes that could lead to the material becoming airborne, it is important to read the safety data sheets, which usually can provide more specifics on the possible hazards and health concerns, she says. One company’s SDS for steel, for example, says the material does not present a possible inhalation or ingestion hazard unless a worker welds, saws, or grinds it. Even then, the process only constitutes a hazard when inhaled in “excessive amounts,” which can cause a flu-like illness called metal fume fever. When workers are exposed to excessive amounts of particles of hexavalent chromium, lead, or cadmium during welding, carcinogens from those metals may cause cancer, their SDSs say.
OSHA decides what it considers a hazard by defining the permissible exposure limit, which is the maximum safe amount or concentration of a chemical contaminant “based on an eight-hour time-weighted average exposure,” Cirone says. For example, no employee should be exposed to airborne lead particles at concentrations greater than 50 micrograms per cubic meter of air averaged over eight hours, OSHA says. (OSHA regulation 1910.1000 Table Z-1 lists PELs for other common hazards.) OSHA also requires employees to observe “good personal hygiene practices,” such as washing their hands before they eat and taking off and properly laundering contaminated clothing before they leave the worksite. Forystek says he asks employees before they eat anything to take off the top half of their protective over-clothing and leave it in a dedicated “dirty” locker area instead of wearing it into the break room. He also requires them to wash their hands “if they are consuming anything,” even water or Gatorade, to prevent them from accidentally ingesting heavy metals along with their food or drink.
OSHA requires employers to do a hazard assessment for each job description to see if there are any factors that might create airborne hazards that are over the PEL. According to OSHA’s “Job Hazard Analysis” handbook, you should do this anytime you add a new job to your operation or undergo any changes in processes and procedures. Review or redo your hazard assessment after an illness or injury occurs on a specific job, OSHA says. In each case, Cirone says employers should consider factors such as the properties of the hazardous material, the rate at which processing materials might create dust or fumes, and the length of time an employee might be exposed to the hazard.
After performing the hazard evaluation, you can do air quality tests to further determine which hazards are present and in what amounts, she says. Those results determine where employees might need to use respirators or other PPE, or whether you need to change your operations to limit employee exposure. You can hire an industrial hygienist or have a qualified safety staff member do the testing.
Gordon Getgen, operations manager of Sullivan’s Scrap Metals (Philadelphia), says air testing, which collects the volume of contaminants in the air a person would inhale over a specific time period, is critical for employee safety. It involves attaching a “goofy-looking machine,” about the size of a juice box, to a specific employee to test the air for all of his or her daily activities. “It draws in what you’re breathing all day, during work, lunch breaks, other breaks, and demonstrates that particular employee’s exposure” to different airborne hazards, he explains. OSHA requires employers to test employees who likely are exposed to the greatest airborne concentrations of hazards such as lead. “In the scrap metal recycling industry, the most typical source of that [lead] exposure is torchcutting operations,” he says. If the initial air testing determines that an employee is below the action level, which OSHA defines as 30 micrograms per cubic meter of air over an eight-hour period, no further testing needs to be done unless you make a major process, material, or personnel change in the scrapyard, he says. Testing might reveal that the employee is at or above that action level, but below OSHA’s permissible exposure level of 50 micrograms per cubic meter of lead over an eight-hour period. If so, you must do follow-up air testing for this employee every six months and conduct blood testing if the employee is exposed at this level for more than 30 days of the year. You must keep testing this employee every six months until two consecutive tests, taken a week apart, are below the action level.
Since OSHA requires that you take measures to reduce or eliminate any employee’s exposure to harmful levels of contaminants, workers who test at the action level—or above—must wear PPE designed to limit or eliminate exposure risks. An industrial hygienist or safety manager can help choose the correct PPE for the individual job, employee, and type of exposure to airborne hazards.
Sullivan’s baseline air quality testing for its facility “has helped us to determine that our operations do not present [an airborne] hazard to our employees,” Getgen says, so it does not routinely test for lead, in part because the facility limits its torchcutting operations. Yet Sullivan’s always resamples if it makes changes to current operations, such as changing the way employees process scrap or accepting a new type of material, he says. Though not required by OSHA, Getgen recommends that regular torchcutters, regardless of respirator use, should be tested at least annually. New torchcutters should undergo baseline testing before performing any work so employers can compare those results to new data each year.
Airborne hazards are a concern for electronics recyclers as well. Kelley Keogh is co-founder and managing partner of Greeneye Partners (Santa Rosa, Calif.), which helps electronics recyclers prepare for certifications such as RIOS™ and R2 and conducts safety audits and training. Even though electronics recyclers work with some different materials than metal scrapyards, workers can be exposed to an airborne hazard the same way: when those items are shredded. Some of the most common sources of airborne hazards for electronics recyclers, she says, include circuitboards, which contain lead and cadmium, and CRTs from old TVs and computer monitors, which contain lead. With CRTs, the lead exposure potential is low if a recycler is temporarily storing them. However, the likelihood of lead exposure increases when the leaded CRT glass breaks or when a processor intentionally grinds it up or cuts it. In facilities where workers dismantle CRTs and break or crush the glass, their facility should conduct a full hazard assessment, then enact precautions accordingly depending on the amount of lead workers likely will be exposed to. Depending on the scope of the operation, “we see everything from [recyclers using] dust masks to full face respirators, Tyvek suits, boot change-out areas, clean rooms, and showers so they know they’re not tracking [lead] out of the area,” Keogh says.
Not all electronics recyclers accept or handle CRTs, but many work with circuitboards, fluorescent bulbs, or batteries. Keogh says these facilities typically do air monitoring and other testing when they start accepting new types of materials or change their processes, per OSHA regulations or certification requirements. Regency Technologies (Twinsburg, Ohio), which has electronics recycling and refurbishing operations throughout the United States, monitors all of its facilities, including areas where they shred electronics, because processing might release heavy metals. Jim Levine, Regency’s president, says it conducts its own air monitoring and industrial hygiene tests “to make sure we’re not operating in an unsafe way.” Regency is R2/RIOS and ISO 14001 certified, and the company also does its own audits and air testing throughout the year to make sure it doesn’t miss anything. Employees use different PPE depending on their task. Some employees use masks and gloves while manually disassembling electronics, and some also wear hard hats or helmets when they work in designated areas that require extra protection to avoid injuries. All workers wear eye protection.
Levine points out that the metal makeup of electronics is changing quickly as new versions of smartphones, flat-screen TVs, and laptops come on the market. Keogh adds that some electronics manufacturers have started complying with a European Union standard that calls for reducing the amount of lead, cadmium, and other potentially harmful metals in electronics. “As we put less toxins in our electronics, we’re reducing the risk to workers,” she says. Yet Levine cautions that the only way to truly protect workers is by enforcing stringent safety rules.
Examine Your PPE Requirements
Taking good stock of your PPE is an important part of protecting employees from airborne contaminants, experts say. Air testing and hazard identification will help you find the best equipment for your environment and task, whether it’s a certain set of gloves, a one-time-use mask, or a respirator with replaceable filters. In some cases, employers might decide to go above and beyond OSHA requirements. At Allied Alloys (Houston), part owner Nidhi Turakhia says the company always requires torchcutters to wear respirators, even though their last air test showed they were not exposed to high levels of contaminants.
Yet the right equipment—even equipment that exceeds requirements—is useless if used improperly, Forystek says. Items such as respirators need to be stored the right way to keep them working as intended and routinely checked to make sure they are in good working order. For example, do torchcutters have a clean place to keep their respirators when they go on break, go to lunch, or go home? If a worker carelessly stacks his respirator on top of his dirty torchcutting gloves, for example, the mask now is contaminated. Low-tech solutions can prevent that, ISRI’s safety team says: Pop the respirator into a clean ziplock bag or other container and place it in a dedicated locker or individual storage unit instead of leaving it out in the open.
Employees who use respirators must undergo a fit test to find the mask that is best for each individual, and they must alert their supervisors if something is wrong with how it fits. Facial hair is another concern. “When you start growing whiskers, it throws off the fit and can let in [contamination]. You have to stay clean shaven,” Getgen says.
Respirators can be uncomfortable and hot to wear, but Forystek says SMS has a strict disciplinary policy when a worker doesn’t wear one in a required area or doesn’t take steps to keep out contaminants. “If you’re not going to wear it properly [or] clean it properly, you get a verbal warning, then the next time a written warning, all the way up to taking three days off [without pay], then termination,” he says.
When workers are exposed to airborne hazards at the permissible exposure level, OSHA also requires employers to provide a changing room with a safe place for dirty uniforms so workers do not wear them home. Facilities must also provide those employees with showering facilities and a changing room dedicated to clean clothes. Laundry service for uniforms and other PPE also is required. Typically, uniform companies will have a standard lead contamination program available, Getgen says, but “you want to contact your uniform company and make sure it is familiar with the scrap industry” so uniform company employees limit their own exposure to hazards when they pick up and launder the clothing.
Eliminating Exposure
While many safety practices focus on lessening employee exposure to airborne and ingestion hazards, OSHA recommends looking for ways to eliminate, not just reduce, these hazards. OSHA calls these methods engineering controls, which are “actions that physically change a machine or work environment to prevent employee exposure to the hazard.” Cirone says engineering controls are a scrapyard’s best bet against contamination, while she considers PPE “the last line of defense.” PPE, she says, is not as effective as engineering controls “because the hazard still exists and you are relying on the employee to properly use the personal protective equipment to prevent exposure,” she says.
Allied Alloys, for example, decided to avoid torchcutting unless absolutely necessary. Turakhia says the dangers of torchcutting, such as working with an open flame and possibly exposing workers to chemicals as the metal heats up, were too much of a liability, and the company knew it easily could process scrap in safer ways. Though the facility doesn’t do much torchcutting anyway—out of its 97 employees, only two are torchcutters—Turakhia says Allied Alloys has decided to process scrap through shearing, crushing, baling, or “anything except for torching unless we have to” because of time constraints, she says.
When torchcutting is necessary, Allied Alloys uses a misting device to keep down dust and metal particles and help keep employees cool in the Texas heat. The employee-designed system—which they use in addition to required PPE, not as a replacement—has been in place for about three years. Word got around about their unique solution: Another area scrapyard has visited their facility to see if they can copy the device, she says.
Sullivan’s employees try to avoid causing airborne or ingestion hazards by taking their low-tech chores, such as routine floor sweeping and vacuuming, seriously: Any amount of dust gets swept up with a mechanical broom and sucked up by a vacuum with a high-efficiency particulate arrestance filter. “You don’t want to let dust build up because you don’t really know what’s in it,” Getgen says. “Why not be safe rather than sorry?”
Megan Quinn is reporter/writer for Scrap.