2 OSHA Policies Regarding Mold Fred Malaby, CIH, CSP Industrial Hygienist NEAIHA/NECOEM Meeting, September 28, 2007
3 Executive Summary OSHA has no standard for mold exposure OSHA has no enforcement directive for mold exposure Most Compliance Officers use (a)(1) to require employer to clean up surface mold The OSHA website has several publications related to mold and mold remediation
4 Mold in the Workplace
5 Possible Citation Strategies Mold in the Workplace General Duty Clause of OSH Act Employer must provide employment and a place of employment free of recognized hazards that are causing or are likely to cause death or serious physical harm to his employees (a)(1) All places of employment, passageways, storerooms, and service rooms shall be kept clean and orderly and in a sanitary condition.
6 Serious Physical Harm Impairment of the body in which part of the body is made functionally useless or is substantially reduced in efficiency on or off the job. Such impairment may be permanent or temporary, chronic or acute. Injuries involving such impairment would usually require treatment by a medical doctor. Illnesses that could shorten life or significantly reduce physical or mental efficiency by inhibiting the normal function of a part of the body.
7 General Duty Clause Citation Language Employees were exposed to various species of fungi, including Aspergillus versicolor, Aspergillus ustus, and several Penicillium sp. due to water intrusion at the Longview Post Office. Fungi were identified in locations including, but not limited to, ceiling tile in the basement adjacent to the gallery door, and in leachate from a concrete wall in the civil service/training room. Exposure to fungi can cause a variety of respiratory disorders including allergic diseases such as asthma and pneumonitis. Mycotoxins have also been linked to symptoms such as sore throats, headaches, fatigue, dermatitis and generalized malaise. Abatement Note: Feasible methods of abating this hazard include, but are not limited to, effectively repairing the roof in order to stop leaks into the building, replacing water- damaged ceiling tiles, use of a mild bleach solution to clean contaminated surfaces, and applying fungicidal paints, where appropriate.
8 Puerto Rico Language employees were exposed to the hazard of working in an environment with levels of airborne microorganisms over the acceptable level. The concentration of microorganisms in the air was over the acceptable exposure indicator level of 1,000 colony forming units per cubic meter of air (CFU/m3). The exposure to high levels of microorganisms can cause alergies and respiratory conditions. All samples were taken on Special Education Record Room - the sampled exposure level was 1,046.1 CFU/m3 of the combined fungi and bacteria levels in the air, 46.1 CFU/m3 over the acceptable exposure indicator. 2.CLA - the sampled exposure level was 1,045.3 CFU/m3 of the combined fungi and bacteria levels in the air, 45.3 CFU/m3 over the acceptable exposure indicator. 3.Occupational Therapy Area - the sampled exposure level was 1,003.4 CFU/m3 of the combined fungi and bacteria levels in the air, 3.4 CFU/m3 over the acceptable exposure indicator. 4.Fiscal Component office - the sampled exposure level was 1,670.4 CFU/m3 of the combined fungi and bacteria levels in the air, CFU/m3 over the acceptable exposure indicator.
9 (a)(1) Usually cited as Other Than Serious This is used to require the employer to clean up the moldy area. It is not used to require extensive building modification.
10 Mold Remediation
11 Caveat Data stated here is not based on a particularly good review method Difficult to mine our Management Information System and identify cases. These contractors may have been performing asbestos or lead remediation when inspected
12 Some Cited Items Hazard Communication Respiratory Protection Reverse Polarity/GFCI Stairways Ladders (b)(2) Competent Person
13 Anticipated Rulemaking Efforts
15 Indoor Air Quality Standard Federal Register, 12/17/01: OSHA is withdrawing its Indoor Air Quality proposal and terminating the rulemaking proceeding. the portion of the proposal not related to environmental tobacco smoke (ETS) received little attention during the rulemaking proceedings As a result, record evidence supporting the non-ets portion of the proposal is sparse.
18 Guidance Documents Safety and Health Information Bulletin: A Brief Guide to Mold in the Workplace Mold Quick Card Fungi & Mold
www.osha.gov Preventing Mold-Related Problems in the Indoor Workplace A Guide for Building Owners, Managers and Occupants OSHA 3304-04N 2006 Employers are responsible for providing a safe and healthful
OSHA 3142-12R 2004 Lead in Construction Employers are responsible for providing a safe and healthy workplace for their employees. OSHA s role is to promote the safety and health of America s working men
March 2007 Connecticut Department of Public Health Environmental Health Section Environmental & Occupational Health Assessment Program 410 Capitol Avenue MS # 11EOH, PO Box 340308 Hartford, CT 06134-0308
United States Environmental Protection Agency A Brief Guide to Mold, Moisture, and Your Home Indoor Air Quality (IAQ) EPA 402-K-02-003 (Reprinted 09/2010) This Guide provides information and guidance for
Managing Water Infiltration Into Buildings A systemized approach for remediating water problems in buildings due to floods, roof leaks, potable water leaks, sewage backup, steam leaks and groundwater infiltration.
Safe Work Practices for Handling Asbestos About WorkSafeBC WorkSafeBC (the Workers Compensation Board) is an independent provincial statutory agency governed by a Board of Directors. It is funded by insurance
Fungal Air Testing, Investigation and Reporting Requirements for Extensively Mould-Contaminated Buildings The following are the fungal air testing, investigation and reporting requirements for owners seeking
Managing Water Infiltration into Buildings A Systematized Approach for Remediating Water Problems in Buildings due to Floods, Roof Leaks, Potable Water Leaks, Sewage Backup, Steam Leaks and Groundwater
UNIVERSITY OF FLORIDA ASBESTOS OPERATIONS AND MAINTENANCE PLAN Administered by: Environmental Health and Safety Building 179 PO Box 112190 Gainesville, Florida 32611 Introduction The following document
City of Philadelphia Mold Remediation, Water Damage and Use of s This document provides direction for remediation of building materials in City facilities with potential, visible or laboratory verified
Guidelines on Assessment and Remediation of Fungi in Indoor Environments New York City Department of Health and Mental Hygiene November 2008 1 Table of Contents Preface...1 Acknowledgements...2 Introduction...3
Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities Prepared by: National Institute for Occupational Safety and Health (NIOSH) Occupational Safety and Health Administration
IUB Water Damage Restoration Guideline Purpose The IUB Water Damage Restoration guideline was developed to ensure that all water intrusions are handled in a professional manner which includes the latest
Approved Code of Practice Management of Exposure to Asbestos in Workplace Buildings and Structures Health and Safety at Work (Jersey) Law, 1989 ACoP 8 Revised 2015 Cover: Magnified image of asbestos fibres,
Guidance on Preparing Workplaces for an Influenza Pandemic OSHA 3327-05R 2009 Occupational Safety and Health Act of 1970 To assure safe and healthful working conditions for working men and women; by authorizing
www.osha.gov Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards OSHA 3186-06R 2003 This informational booklet provides a general overview of a particular topic
Water Incursion Standard Operating Procedure Purpose: To provide a standardized procedure in the event of water incursion into any Penn State University facility. References: A Brief Guide to Mold, Moisture
Guide to Prevention and Control of Infectious Diseases in the Workplace 2007 A Joint Initiative BC Government and Service Employees Union BC Public Service Agency Acknowledgements This booklet has been
Common Name: IODOFORM CAS Number: 75-47-8 DOT Number: None ------------------------------------------------------------------------- HAZARD SUMMARY * Iodoform can affect you when breathed in and by passing
EMERGENCY RESPONSE: If you are a victim of a wildfire, we're here to help. We provide complete demolition services, erosion control, smoke mitigation, restoration services and re-build in all of El Paso
Controlling and Preventing Household Mold and Moisture Problems: Lessons Learned and Strategies for Disseminating Best Practices A Report to Congress U.S. Department of Housing and Urban Development April
Health and Safety Executive ASBESTOS Approved Code of Practice Management of Exposure to Asbestos in Workplace Buildings and Structures The Health and Safety at Work (General) (Guernsey) Ordinance, 1987