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One of the simplest things managers can do to prepare employees for success in a hazardous environment is to provide access to the proper personal protective equipment (PPE).   Selecting the right equipment is essential, and knowing how to put on and take off (‘don’ and ‘doff’) that equipment is critical for the health and safety of the staff.

A good fit testing program follows OSHA standard and guidelines. Due to the fact that fit testing can be life-saving, there are strict rules in place that should be followed when teaching the proper “donning and doffing” technique. Here are some questions we thought might help you prepare your staff for this critical training.

What exactly is “fit testing”?

Fit Testing is the test of the actual skin to mask fit to make sure no particles or contaminants are getting through your respirator. The goal is to make it air-tight so you are breathing clean air.

Is it a one-time test?

No. Individuals need to be tested annually. Interestingly, facial features are constantly changing. Therefore, the mask that fit you a year ago might not be the right fit this year. This is why when fit testing occurs, you are not allowed to have any facial hair. Other features like scars, plastic surgery, dentures, and certain oral surgeries are reasons to fit test again.

How does the process work?

There are seven steps when it comes to fit testing, each of which takes about seven minutes to do. There is a sensitivity test, exercises, and the rainbow passage you must read after every yearly test. The rainbow passage is a passage used by OSHA that goes through all the movements and motions of your mouth. It is essentially a speech pathology passage. Exercises include jogging in place, bending over, and moving your head side to side and up and down.

How do I choose a fit test company?

Fit Testing, while simple, is not something that should be shortchanged. Whoever is providing the testing protocol should plan on spending at least 15-30 minutes per person.  They should also provide proof that they follow the steps outlined in OSHA guidelines.  Having fit testers that also use the equipment themselves is also a good practice since they have personal experience using this equipment.

Are there different types of Fit Tests?

Yes. There are two types of fit tests: quantitative and qualitative. Qualitative fit testing relies on your sense of taste and smell. Qualitative tests do not measure the amount of the irritant sprayed, it only tests whether or not your mask is protecting you from leakage. Quantitative tests are normally used for half-mask respirators. They only cover your nose and mouth. During this test, a machine is used to measure the amount, if any, of leakage into the mask.

What if my staff is too busy to leave our location to receive their fit testing?

Emilcott can arrange to come onsite to fit test for larger numbers of employees. We even have a bus that can provide fit testing to employees in the field.

How do I sign up?

You can call and make an appointment with us at 973-538-1110 or contact us at info@emilcott.com with a question.

Are your building occupants complaining of symptoms like itchy eyes, coughs, allergies, and headaches? Have you noticed a persistent and unusual odor in your building lately? You’d be surprised at how common it is to have poor indoor air quality—and how often it is caused by a distinct source with an easy fix. In our 30 years of air quality testing, we’ve seen all kinds of problems due to poor air handling maintenance: from HVAC filters that haven’t been changed in years to pigeons roosting near the air intake and leaving feathers and droppings to forgotten insulation and trash inside the AHU after a contracting job. These problems are not unusual, and they’re not going away.

Air quality concerns and problems aren’t going away either. In fact, they seem to be on the rise, especially with growing reports of poor outdoor air quality across the globe.

To mitigate these growing concerns, we’ve compiled 6 important air quality tips that we recommend all property managers consider when building issues arise:

#1: Confirm adequate ventilation and airflow. When evaluating operations and activities in the building, are functions and spaces properly located and ventilated? For example, printers can often give off fire particulates, and kitchenettes and bathroom exhausts can create unpleasant odors. Making sure adequate ventilation and airflow are present relative to the purpose of the space can go a long way toward staving off complaints.

#2: Revisit your building’s cleaning services. Are the building cleaning schedules adequate? How frequently are you preventing dirt from entering the building at the doors and windows? Does the housekeeping schedule provide adequate removal of dust and particulates? Do they vacuum the carpets and dust the shelves with regularity? Simple spot checks on these services can often provide clues as to the efficacy of cleaning services.

#3: Create a water intrusion policy. Do you have a formal policy or procedure for responding to water intrusion? Timely and appropriate response (within 24-48 hours) can eliminate the potential for mold. Be specific in your plan and consider differences in policies, procedures, and timing regarding the source of the water intrusion (e.g., rainwater vs. toilet backup.)

#4: Develop a procedure for complaints. Do you have a standard operating procedure for responding to complaints? When a complaint occurs from a building occupant or a visitor, do you have a standard operating procedure for investigating and responding to the complaint? Often when complaints are ignored, there can be the perception that building air quality has worsened because no one is actively managing it…so make sure that you are proactively managing it!

#5: Maintain your HVAC filters. Have the HVAC filters been regularly and properly maintained? Filters must be changed on an appropriate schedule. We have found that even filters that have been changed quarterly create the potential for dust-related allergies and/or bacterial and fungal growth, which can aggressively impact building occupants. And remember – not all filters are the same so it is important you use filters that are of good quality.

#6: Visit the air handler. When was the last time you visited the air handler? Beyond filters, consider checking that water and dust are not accumulating inside the air handler. The entire AHU from outdoor air intake to discharge into the building, supply ducts, and return ducts all warrant inspection to identify problems.

So what do you do if you find you have a more serious air quality problem? Indoor air quality should always be evaluated relative to outdoor air quality. If outdoor air quality is good, increasing ventilation may be sufficient. However, when outdoor air quality is an issue, active management of air inside the building envelope is critical.

In an age where air quality is increasingly challenging to manage, proactive measurement and maintenance of indoor air quality – as suggested in our 6 tips above – can be critical to maintaining employee health and wellness.

EPA Implements New Rules for Hazardous Waste Generators

New Jersey and Pennsylvania have adopted the EPA’s Hazardous Waste Generator Improvements Rule. This revised rule for hazardous waste generators became effective May 30, 2017 for states that do not have an EPA authorized RCRA program (Iowa and Alaska) and for states (such as New Jersey and Pennsylvania) that have adopted the rule by reference.

• Other Authorized States run the RCRA program in their state and, thus, will go through the state adoption & authorization process for this new RCRA rule. Authorized states will have to pick up the more stringent provisions, typically by July 1, 2018 (or July 1, 2019 if state law change is needed).

What Does This Mean to Your Site’s Operations?

• The new rule allows for Very Small (formally “Conditionally Exempt Small”) and Small Quantity Generators (SQG) to have an episodic increase in hazardous waste production without resulting in a change in hazardous waste generator status. There are notification, marking, labeling, storage, and recordkeeping requirements associated with this provision.
• Additional notification requirements are in effect for Small and Large Quantity Generators.
• In addition to determining the type of waste that has been generated, hazardous waste generators will have to determine the physical and health hazards of the waste. Hazardous waste container marking requirements include identifying the physical and health hazards of the waste.

Key changes to the Hazardous Waste Generators requirements:

• Reorganization of the regulatory requirements placing all of the generator requirements in 40 CFR Part 262. The regulation has been reorganized, and the rules are easier to find.

• New for Small Quantity Generators
  • Conditionally Exempt Small Quantity Generator (CESQG) will now be designated as a Very Small Quantity Generator (VSQG).
  • Creation of the “episodic event” provision which allows SQG and VSQG to generate a volume of waste (that would have previously moved them to a higher-level generator category) with certain limitations. The generator category would not change as a result of an “episodic event”. Note: An increase in production resulting in an increase of waste generation does not qualify as an “episodic event”.
  • VSQG under the ownership of a Large Quantity Generator (LQG) may transport their waste to the LQG for disposal. Note – there are DOT requirements and NJDEP hazardous waste transporter requirements which are not considered as part of this ruling.
  • New rules require SQG’s to submit a notification to the EPA every 4 years beginning in 2021. The notification serves as verification that the SQG is still in operation.
• New for Large Quantity Generators
  • LQG’s need to notify the EPA or their authorized state if the facility is closing.
  • LQG’s must create and submit a Contingency Plan quick reference guide for emergency responders. The content requirements are found in 40 CFR 260.262. Note: LQG’s with existing Contingency Plans do not need to create a quick reference guide until the next Contingency Plan revision.
• Hazardous waste container markings requirements now include identification of the hazards of the contents (this can be accomplished with GHS markings and/or DOT markings) in addition to marking as “Hazardous Waste”.

Clarifications to the Hazardous Waste Generators requirements:

• 3-day rule for moving waste in Satellite Accumulation Areas to a Central Accumulation Area has been clarified to mean 3 calendar days.
• New rules clarify that a hazardous waste generator can only have one generator category per month. If an activity makes a generator a LQG at a given moment, they are a LQG for the entire month.
• New rules clarify that solid and hazardous waste determinations must be made at the point of generation before any dilution, mixing, or other alteration of the waste occurs.
• Storage areas for hazardous waste that do not meet the definition of satellite accumulation areas are called “central accumulation areas” (CAA). The new rules clarify that there can be more than on CAA and that “central” does not mean that it is in the center of the facility.
• New rules clarify that SQGs and LQGs must identify the RCRA waste code(s) associated with their waste. Hazardous waste determination has always been a requirement for generators; however, many relied on disposal vendor to identify the waste code. The new rules clarify that this is a requirement of the hazardous waste generator.

HOW CAN EMILCOTT HELP?

Emilcott can assist with getting your operation aligned with the Hazardous Waste Generator Improvements Final Rule. Every day Emilcott’s experienced professionals help hazardous waste generators understand the new requirements, and how the rule affects their operations. This is your opportunity to learn more about what you can do to comply with the new rule.

Emilcott can provide a broad range of technical support related to RCRA Compliance:

• Training: Client-needs specific training for site-wide RCRA Awareness for waste generators and shipment manifest signers.
• Program Development: Update site programs and implementation methods to reflect new requirements.
• Prepare RCRA Regulatory Submissions: Biennial Reports, Notifications, and Status Updates
• Gap Assessments: Identify potential gaps in compliance related to program implementation or operational changes.

Please give us a call – we can help you meet your goals!