Summertime IAQ Checklist

June is National Safety Month! For 25 years, the National Safety Council (NSC) has been celebrating National Safety Month as an annual reminder to “keep each other safe from the workplace to anyplace.”

The topic for this week is: Address Ongoing COVID-19 Safety Concerns.

Public spaces are preparing their returns to normal operation as we finally turn the corner on this pandemic. After a year of reduced capacities and heightened awareness of air quality in closed spaces, property managers need to make sure their air handling maintenance is ready.

Using our 30 years of experience with indoor air quality, Emilcott has compiled a checklist to help you verify that your building’s air quality is in peak shape for summer openings.

When is EHS Online Training Not Enough? A Conversation with Bruce Groves, CIH and former OSHA Officer

Proponents of online training argue that it is cheaper and easier to implement in a world of busy schedules than classroom training. Why WOULDN’T you opt for online safety training?

Many people feel safety is nothing more than common sense. My experience has been that it is much more than common sense. You really have to learn how to identify hazards and how to protect yourself.

Safety training requires individual engagement, and it is most successful when there is good group interaction. For example, effective safety programs are a series of problem-solving scenarios. When you have a group of employees trained as a group, this gives everyone an opportunity to interact and solve problems not as a class full of individuals but as a team. Safety often requires a group of people to figure out how to respond to an emergency where you have to not only solve the emergency you are facing, but you have to make sure everyone is protected during the process. There is no cookie-cutter approach. You are essentially helping people practice good communication and teamwork in addition to using their experience and training in order to have the best outcomes.

For example, something as small as a fuel spill could create a hazard for fire in an environment, as well as a toxicity issue. To understand how to control the spill and reduce the hazards, someone has to exercise good judgment and decision-making quickly. Having rehearsed this in a group setting is preferable to individual learning.

What about online training over some of the newer platforms like Zoom where there can be interaction rather than just playing a video?

I think this type of online training can work in certain circumstances. Especially as we have seen technology like Zoom and Webinars being adopted by employers, instructor-led training over an interactive platform can be very effective. However, you do want to make sure your trainer places a limit on the amount of attendees so that the instructor can go through the curriculum, have sufficient Q&A, facilitate discussions and even breakout rooms, and especially lead problem-solving scenarios.

What I do not think is sufficient is the pre-recorded online training, or what is often referred to as “asynchronous” or on-demand training.

If online training isn’t sufficient, why hasn’t OSHA disallowed it?

There is a conflict between OSHA requirements that call for a set amount of time for training, whether it is online or classroom. OSHA requires many classes like the 40-hour training, the 30-hour training, and the 8-hour refresher. It was originally designed for a training course that had a maximum amount of hands-on demonstration, group exercise, problem solving… which was regularly scheduled into classroom training. These requirements weren’t necessarily developed with the technology options in mind that exist today.

Unfortunately, the push to substitute online training for classroom training still requires the person to sit in front of a computer for a specified amount of time. Even if you can complete a module in seven minutes, you still have to sit and wait until the next module starts. This is not only less engaging but also misses out on the opportunity for group discussion and scenario practice.

Are there any types of training where you would consider online training effective?

Certain administrative aspects of safety, such as hazard communications, can be taught effectively online. We have also seen where blended training works well. Here the classroom portion of many training courses like forklift training, electrical safety, and fire protection can be taught online as long as they are supplemented by hands-on, face-to-face training in order to determine competence.

Blended training works with online training. Unfortunately, many people just use online training without any sort of practical aspect, which is where safety training falls short.

What happens if an employer does not provide sufficient health and safety training?

OSHA clearly requires training at many levels. It is the employer’s responsibility to determine what training is required for each employee depending on their job responsibilities. They also must determine the competence expected from that training. Most importantly, the employer must determine the employee successfully passed the course and shows competence in doing their job.

The lack of training or inadequate training could receive a citation from OSHA. Depending upon the standard, the fines can range from up to $7,000 for serious citations to $70K for willful citations (doublecheck.) Serious citations are violations that could lead to serious injury or death (e.g., electrocution, falling, exposure to toxic chemicals or viruses). A willful violation is typically a serious citation where the employer knew there was a training requirement and wantonly disregarded the step to train their employee.

Have you ever responded to an emergency that was caused because people weren’t trained correctly?

Yes. I was called in to negotiate with OSHA on behalf of a client that was being investigated for a fatality at a job site. Workers at this facility had to clean large diesel fuel tanks. They had to enter these tanks, and they were used to having diesel fuel in these tanks. In this one case, someone had placed chemicals instead of the diesel fuel in the tank. Unfortunately, there were no standard procedures that were followed and employees had not received ample training to prepare them to enter a tank.

A person entered the tank with chemicals and immediately fell to the bottom of the tank and died. The company had not conducted an adequate hazard assessment, nor did the worker have the appropriate PPE. There were no instruments to measure air quality, and there was no way to rescue the guy when he went down.

Ultimately, we developed standards, protocols, and training to rectify this situation, but not before it cost a life. With the appropriate training, the individual might have been spared.

Bruce Groves is the CEO of Emilcott Associates, an environmental health and safety consulting firm with offices throughout the east coast.

Please reach out to if you need assistance developing and implementing proper safety training programs.

Understanding Your Ventilation System

By: Allen M. Chung, CIH and Paul Linnartz

As people start to return to office buildings and public areas after a year of “pandemic life,” there will undoubtedly be a heightened awareness of air quality in closed spaces.

SARS-CoV-2, the virus that causes COVID-19, is known to spread through aerosolized respiratory droplets at close range. Airborne transmission from exposure to very small droplets is unlikely over long distances but possible in certain indoor spaces. General ventilation typically addresses common contaminants often found in commercial environments, but many of these commercial systems have not been designed to protect occupants from the SARS virus.  Understanding a facility’s general ventilation system is an essential step toward improving indoor air quality as well as moderating the risk of COVID-19 at your facility.

To moderate the spread of COVID-19 in an indoor space, a recent article published by the National Center for Biotechnology Information (NCBI) recommends the following:

  • increasing air exchange rates above current conditions
  • using high‐efficiency filtration for recirculated air (MERV 13 or higher)
  • verifying that sensitive areas, such as bathrooms and rooms where infected patients are cared for in hospitals and senior homes, are negatively pressurized relative to adjacent areas
  • managing airflow direction and speed to prevent the spread of aerosols across occupants
  • considering additional technological controls, such as UV germicidal irradiation and portable air purification, in areas and situations where typical building‐level controls are not sufficient


Ventilation effectiveness is measured in terms of Air Changes per Hour (ACH). By running the recirculated air through high-efficiency filtration (MERV 13 or higher), possibly adding UV germicidal irradiation, and/or portable air purification units, more “clean” air is provided to the indoor space. The amount of clean air needed can vary widely depending upon building design and occupancy. ASHRAE, which sets ventilation standards and guidelines, recommends ACH levels up to 3x/hr for offices, 6x/hr for schools, and 8x/hr for restaurants.


Do you know what your ACH rate is?


Evaluating air exchange rates (ACH), checking negative pressure at sensitive areas  and mapping airflow direction and speed in your facility can determine whether your ventilation systems promote healthy indoor environmental conditions. This can be a complicated process.  Please reach out to if you need assistance.  Let’s work to end this pandemic!

Interview with Nupur Patel: Noise Monitoring

What is noise monitoring?

A facility that generates a lot of noise can be harmful to the workers if they are exposed to the noise. At Emilcott, we are often called in to measure and monitor this noise to make sure it doesn’t exceed certain thresholds that could be harmful to workers. We use a sound level meter that measures sound levels in work areas, which allows us to map sound levels across a facility’s floor plan. We’ll also equip individual employees with dosimeters (used to measure noise exposure over a period of time – often 8 hours), and measure their personal exposure as they go about their day-to-day activities. This allows us to see exactly how much noise they exposed to under normal circumstances.


Why is it important to measure noise?

Over time, exposure to loud noises can cause irreversible damage to ones hearing. There are short term and long term affects when it comes to excessive noise exposure.


How long before effects take place?

Noise is interesting. For example, when we monitor airborne hazards (for example, chemical exposure), there are are standard limits and amounts of time that people can safely be exposed. However, exposure to very high decibels (if you hear something really loud) can have an immediate affect on your hearing. It doesn’t necessarily have to be over a certain period of time.


Does this impact only workers, or are those in the area also affected?

We do noise monitoring mainly for the workers within the facility (OSHA only regulates worker safety), but noise does travel. Still, there is a drastic difference between a loud noise within the building, compared to when you’re across the street.


Does every site need noise monitoring or are you called in for specific noise issues?

If a facility has a reason to be concerned about noise exposure, then Emilcott is called in for a site walk-down. From this qualitative assessment, we are able to identify if they need some sort of monitoring.


Are some facilities noisier than others?

Noise exposure can occur on a variety of sites. We see the majority of noise surveys and noise dosimetry in manufacturing facilities, but construction sites have many sources for noise exposure as well.

The Importance of a Quality Fit Testing Program

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 take 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. Whomever 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 equipment themselves is also 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 on our website with a question.

6 Indoor Air Quality Tips for Buildings at Risk of Having Poor Air Quality

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 air flow. 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 air flow 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 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 ventilations 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 in 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

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.


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!

Mid-year Regulatory Submissions Reminder

Just as we all take a deep breath after getting the CRTK submissions on March 1 — now it is time to get started gathering the information for the next round of submissions.  We’ve pulled together our Spring and Summer submission list.  Similar to our 1Q2017 Regulatory Submission Reminder , we detail information about the regulations that require submissions from mid-April through July 2017 along with specific dates to help you ensure that everything is submitted on time! 

For more information and for a more comprehensive outline of each submission and what is required, including links to government pages, download our FREE ebook “ Spring/Summer Regulatory Submissions Reminder”.

Please feel free to call us at 973-538-1110 to speak to an EHS Consultant regarding any further questions you may have or for help with your regulatory submissions or safety compliance. 

UPDATED: When Dust Is Not Just Dust: New silica guidelines you need to know now

* UPDATE: The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has now delayed enforcement of this new standard to begin on September 23, 2017 as opposed to the original date of June 23, 2017.  

Silica is the second most common mineral in the crust of the earth.  Silica can be found in materials like sand, concrete, brick, block, stone and mortar. Overexposure to dust that contains crystalline silica can cause scar tissue to form in the lungs, which reduces the lungs ability to function. The resulting disease is called Silicosis.  It is an incurable lung disease that sometimes causes bronchitis and puts victims at increased risk of tuberculosis, and may lead to lung cancer.

All this disease, from breathing in dust that is not just dust.

The hazards of breathing crystalline silica have been known by stone cutters and quarrymen for eons. In the 1700’s Bernardino Ramazzini (considered the father of occupational medicine) wrote about stone cutter “maladies” of cough, asthmatic afflictions, and consumption resulting from breathing in rough, sharp and jagged splinters of stone. 

In 1938, the US Secretary of Labor started the “Stop Silicosis” campaign after hundreds of workers died from silicosis while working on construction of the Gauley Bridge tunnel. 

In the 1990’s, the Department of Labor recognized that worker exposure to crystalline silica still caused a significant health hazard and once again rolled out a campaign to raise awareness and highlight safe work practices “It’s Just Not Dust”.  The source of exposure to airborne crystalline silica today is not predominately in tunnel construction, it occurs with the increased use of dry cutting, drilling and grinding of concrete and masonry material in construction along with the popularity of stone surfaces in residential and commercial buildings.

In 2016 OSHA published a detailed new standard for OSHA’s new standard for Crystalline Silica. And now compliance dates are approaching with June 23, 2017 for the Construction Industry and most of General Industry scheduled for June 23, 2018.

How are you set for June 23, 2017 compliance with the Construction Industry requirements your business must follow in order to protect your employees against the effects of crystalline silica.

Here are six questions to ask:

  1. Are your site work protocols and equipment aligned with the new “Safe Methods for Working with Silica” issued by OSHA?
  2. Are you confident any recently performed a worker exposure to crystalline silica measurements reflect the new exposure control methods issued by OSHA in regulation §1926.1153 Respirable crystalline silica.
  3. Do you have a respirator program for your employees wearing respirators (even dust masks?)
  4. Have your employees wearing respirators been medically cleared to wear these respirators?
  5. Are your employees receiving training about the dangers of crystalline silica?
  6. Do you have records of your training?

If you answered no to any of these question and your employees are potentially exposed to crystalline silica, you may not be in compliance the latest OSHA standards.  Contact Emilcott today or check out our full compliance checklist.  We offer comprehensive solutions to:

  • Write programs customized to your business that comply with the OSHA standard
  • Provide training on using the methods recommended by OSHA in specified exposure control methods
  • Help you meet the requirements on communicating the hazards of silica to be in compliance with OSHA hazard communication regulations
  • Train your employees at their work site on your schedule
  • Provide on site exposure assessments for silica.

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