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HVAC Systems with David Tomsey

With over eighteen years of experience in environmental, health, and safety consulting, David runs Emilcott’s Indoor Environmental Quality practice. He was one of the original leaders who developed our proprietary Greenlight system for real-time air monitoring on construction sites. His experience includes performing hazardous materials surveys, perimeter air monitoring system development and implementation, remedial investigations; performing soil and water investigations, and survey design.

What is an HVAC system? How does it work?

An HVAC system cleans air through a series of filters. This means it basically circulates air through a building to provide comfort to all occupants. Comfort can be thermal (through heat) as well as through cool air. Simply put, it is an air exchange system regulating temperature and contaminants that can be found in the air of an indoor space.

HVAC systems remove moisture all year-round, but they are especially important during the summer months. Without an HVAC system, excessive moisture creates an environment for mold growth.

What is the importance of a clean HVAC system?

As people return to work, it is important to do a deep cleaning of buildings’ HVAC systems, especially those turned off during the past few months.

The Minimum Efficiency Reporting Value, also known as MERV, is a measurement scale used for tracking the effectiveness of air filters. Typically, it has been recommended that a building’s MERV number is an 8 or 9. But since the emergence of the coronavirus, the recommended MERV number is now 13 to prevent viruses from forming in the air space.

A lot of buildings will shut their systems down overnight but typically not when temperatures are high outside. It is now recommended that all places keep their HVAC Systems running 24/7 for a greater air exchange rate. Usually, the system is responsible for just filtering indoor air. In today’s world, it is wise to bring in the outdoor air and kill the virus with heat and sunlight.

What issues arise when HVAC systems are not taken care of?

When HVAC systems are not cleaned and used properly, there is a greater chance that indoor aerosols are lingering for a longer amount of time.

Dirt and debris (when not eliminated from the air) harbor environments for bacteria and viruses. A well-functioning system reduces airborne concentrations of viruses.

A properly operated system helps individuals fight colds, flus, and viruses. With the correct amount of humidity in the air, the human body is operating in optimal circumstances. Otherwise, our bodies have to work a lot harder to keep us healthy.

How do you know when you need help?

Buildings that need this type of service include office and retail spaces, healthcare facilities, hospitals, and hotels, among other types of public places. When someone comes to help you with this issue, they should test for general indoor parameters, particulates, dust, and volatile organic compounds (VOCs.) They will also want to ensure there are no issues with odors or allergic reactions as systems are put to use. This type of testing gives clients an understanding of the state of their indoor space.

Emilcott works with other people in order to evaluate the HVAC system at hand. If it is found that people are having issues with odors or allergic reactions, Emilcott can come and investigate.

If you have questions about your HVAC system or any Emilcott services, call us at 800-866-3645 or email us at info@emilcott.com.


How to Recognize Heat Illnesses

As the summer progresses, employers need to remember how dangerous hot and humid temperatures can be. Working outside in 90-degree weather without proper protection can cause discomfort, heat stress, or even deadly heatstroke.

Symptoms of heat stress range widely:

  • Heat rash is a skin irritation caused by excessive sweating during hot, humid weather. In high humidity, the sweat does not evaporate quickly from your skin’s surface. The clothing rubs will rub against the wet skin, causing irritation that can result in a rash.
  • Heat cramps are involuntary muscle spasms within the large muscles of your body. These typically occur in the thigh, core, and arm muscles.
  • Heat syncope is a fainting or dizziness episode that can occur due to dehydration or lack of acclimation.
  • Heat exhaustion is the body’s response t loss of water and salt, usually due to excessive sweating. Symptoms include heavy sweating; extreme weakness or fatigue; dizziness; clammy, moist skin; muscle cramps; elevated temperature, and fast, shallow breathing.
  • Heatstroke is a medical emergency. As the body temperature rises, the sweating mechanism fails, and the body cannot cool down and control its temperature. Beware! This severe reaction can happen quickly – the body temperature can rise to 106 degrees within ten to fifteen minutes! Without emergency treatment, heatstroke can cause death or permanent disability. Symptoms of heatstroke include hot, dry skin; profuse sweating; hallucinations; throbbing headache; high body temperature; confusion or dizziness; and slurred speech.

If you notice that you’re starting to experience any of these symptoms, the first thing you need to do is take a break. Move to a cool, shaded area and drink plenty of non-alcoholic, caffeine-free liquids. If it’s possible, take a cool shower or dip an article of clothing in cold water and place it on your body. If you are suffering from heat rash, DO NOT apply wet clothing. Instead, dry off and remain in a cool area until the sweating ceases. Resume work only after your body has cooled to a normal temperature.

Employers need to keep a close eye on workers – especially in the heat. When employees are subjected to conditions that could induce heat stress, employers need a successful heat stress program in place. OSHA has many resources to help create and develop heat illness prevention plans, but an Emilcott favorite is the OSHA-NIOSH Heat Safety App.

The OSHA-NIOSH Heat Safety App is a great resource to help employers and employees plan outdoor activities based on the heat. It can be downloaded onto any smart device and features:
• Area-specific heat indexes and associated risk levels
• Precautionary recommendations
• Hourly forecasts
• And more!

Emilcott’s team of professionals includes skilled Health and Safety Officers with experience in construction and hazardous waste sites. If you would like your current program evaluated or need help preparing your workforce for possible heat hazards, please reach out to info@emilcott.com or call us at 973-538-1110.


Understanding Your Ventilation System

By: Allen M. Chung, CIH and Paul Linnartz

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

Certain viruses, such as SARS-CoV-2, are known to spread through aerosolized respiratory droplets at close range. Airborne transmission from exposure to tiny 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 commercial systems have not been designed to protect occupants from contagions like the SARS virus. Therefore, understanding a facility’s general ventilation system is an essential step toward improving indoor air quality (IAQ) as well as moderating the risk of spreading disease at your facility.

To help you moderate the spread of contagious diseases in an indoor space, the National Center for Biotechnology Information (NCBI) published an article that 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 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.  If Emilcott can be of any assistance, reach out to info@emilcott.com.


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.


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 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.


6 IAQ 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 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

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!


When Dust Is Not Just Dust: New Silica Guidelines You Need to Know

* 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.

7 Considerations for Your Next Site-Specific Health & Safety Plan

(OSHA 29 CFR: 1926.21, 1925.65, 1910.120)

1. Do you have the right programs, processes and defensible data to prove you are actively guarding the health and safety of your workers?   

Under the exclusive remedy provision of workers compensation laws, most workers do not sue their employers.  This worker compensation protection, however, does not cover third parties who then become the targets of plaintiff attorneys’ looking to claim damages. 

2. Are you comfortable with the level of liability you would assume in the event that a worker was injured on a construction site?

Have you reviewed your professional liability coverage?  Certain locations (e.g., New York City) have experienced significant increases in claims for worker injuries on construction sites.  As a result, many insurance companies have dropped or limited their professional liability coverage for those companies that directly or indirectly manage or provide oversite of health and safety activities on a construction project.  Even if you feel you have no responsibility, liability exposure may be significant if you are sued as a third party.

3. Are your employees apprised of their obligation under OSHA’s multi-employer workplace policy?

In the event a worker is injured or killed on the site because he or she failed to take proper precautions, the first liability is with the company who employed the worker.  However, OSHA has redefined the definition of employer to include other companies or agencies that are also working on the construction project.  For example, OSHA has identified engineering firms as a Controlling Employer because of their oversite role on a project.  This not only exposes an engineering firm to OSHA citations but lays the groundwork for being named as a contributing third party in the accident.  This OSHA policy is complicated and requires a prescriptive company procedure to manage the conduct of employees working on a construction site.  It is critical to proactively prepare your staff for situations like this and others is step one in managing your liability on the site. 

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=28265

4. Is the construction site in proximity to high density populations? 
Residences, roadways, shopping areas, pubic venues?

With certain contaminants and toxins, weather conditions can carry dusts, vapors and gases up to 2 miles away from the site of origination.  Even if a smell or toxin is not considered harmful at the concentration levels at which it is sensed, it can cause alarm and create public unrest that has the potential to disrupt operations unnecessarily.  Having a means to collect data to measure potential contaminants potentially emitted from a construction site, provides strong defensible position that people are not being harmed from construction activities.

5. Is the construction site in proximity to vulnerable populations like schools or hospitals?

Routine operations such as excavation and site preparation create dust.  While not all dust is harmful, air quality continues to be a major concern for vulnerable populations (sensitive receptors).  Proactively monitoring dust in the air continuously and maintaining transparency with the public can prevent complaints and claims of disease coming from toxic exposures.

6. Are you comfortable with the level of liability you would assume in the event that an outside group claimed they had been exposed to a toxin from your site?

Lawsuits pertaining to public exposure to toxins require the defendant (the company) to prove a negative.  In other words, you must show that the plaintiff was not exposed or that their injury did not result from toxic exposure originating from your construction site.  Proving a negative is extremely difficult unless you have sufficient environmental data covering the specific timeframe when the plaintiff claims exposure.  Real-time monitoring provides that level of data necessary to guard against this type of claim.  Furthermore, real time data allows you ensure that any toxic release is identified immediately, managed, and documented as such before it reaches toxic levels.

7. Does your firm have a core competency in health and safety that can continuously manage both worker health and public health with technology?

Leading environmental and engineering firms have begun to bundle health and safety with engineering and construction management for a comprehensive, turnkey approach to public and worker health and safety.  Ensuring your staff has the technology and the training necessary to deploy equipment, oversee multi-employer safety, and monitor toxins in real time can not only create efficiencies but also provide third party credibility and even outsource liability in certain cases.

If you have specific questions or concerns about these issues, please feel free to reach out to discuss your specific needs at info@emilcott.com.


Portable Space Heater Safety in the Workplace

There are no federal workplace safety rules that prohibit portable electric space heaters in the workplace and statistics regarding commercial property damage caused by space heaters are not readily available. However, the U.S. Consumer Product Safety Commission estimates that more than 25,000 residential fires every year are associated with the use of space heaters—resulting in more than 300 deaths. In addition, an estimated 6,000 people every year receive emergency room care for burn injuries associated with contacting the hot surfaces of room heaters, mostly in non-fire situations.

So, as the cold weather sets in, employers may be considering if they should permit portable space heaters or actually discourage their use—even outright ban them. However, some work areas can just be cold. This is a frequent problem with older buildings or those areas near entries or doors.  Adding to the challenge, there are many employees with medical conditions that require extra warmth above what is normally considered comfortable and a space heater can fulfill that accommodation without heating up everyone else’s workspace.

The good news—like so many other hazards, portable space heaters can be used safely if proper care and precautions are implemented. Any employer permitting the use of portable space heaters should highly consider a written policy to spell out exactly what is proper care and sufficient precautions. It could possibly prevent fires, injuries and even death.

Firstly, OSHA rules do require that electrical equipment must be used according to manufacturer specifications on the unit’s label and in the user manual. Therefore, only employer-purchased and issued space heaters with adequate safety features should be used.  Generally, regardless of the types of space heaters, the following applies:

  • Choose only thermostatically controlled heaters to avoid wasting energy or overheating
  • Most heaters come with a general sizing table, so select heaters of varying sizes to fit the size of the areas that needs heating
  • Position heaters on a level surface away from foot traffic
  • All space heaters must be kept away from any combustible material
  • Heaters should have a tip-over automatic shut down feature and a grounded three-pronged plug
  • Require that space heaters always be turned off when the area is not occupied—possibly unplugged at night
  • Plug heaters directly into a wall outlet and in plain sight
  • Remind employees that nothing should ever be placed on top of or touching the space heater
  • Heaters missing guards, control knobs, feet, frayed cords, or otherwise damaged must be taken out of service
  • Discontinue use of the heater if the heater causes the electrical circuit breaker to trip

It is not recommended that unvented combustion space heaters, such as those fueled by propane, natural gas, and kerosene, be used for heating inside areas. They introduce unwanted combustion products into the environment—including nitrogen oxides, carbon monoxide, and water vapor—and deplete air in the space. Check for local regulations banning unvented kerosene and natural gas heaters.

Office Safety is covered under the OSHA General Duty Clause. Good office “housekeeping” and safety policies can prevent injuries. If you have questions about office safety policy, Emilcott can help.


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