Environmental Realty of Mercury Contamination in Grassy Narrows

Written by Abimbolo Badejo, Staff Reporter

Grassy Narrows, a First Nation community of 1,600 residents, landed on the world radar due to a tragic mercury poisoning accident, made possible by lax laws regarding environmental pollution in the 1960s. Affected policies have been amended to prevent further occurrences but solutions to the poisoning effects are yet to be addressed effectively.

Government officials discovered Mercury contamination in the English-Wabigoon River in the 1970s, caused by a chemical plant at the Reed Paper Mill in Dryden Ontario. The river flows beside two First Nations communities (Grassy Narrows and Whitedog), which depend on this river as their source of livelihood. The contaminated river poisoned the fish, and this caused a shutdown of the associated fishing industry, resulting in mass unemployment for the residents. In addition, various health defects ranging from neurological disorders  to digestive disorders have been observed among the residents (spanning three generations) with no encouraging end to the defects in sight.

Studies and Plans

Since the discovery of mercury contamination in the river in the 1970s, no major action has been taken besides the establishment of a Disability Board  in 1986, which was saddled with the duty of compensating affected residents; many of whose claims for compensation were denied. After decades of delay, pressures from concerned groups (First Nations and environmental Groups) finally elicited a somewhat response from the Ontario provincial government and the Federal government. The government of Ontario stated in June 2017 that it has secured  $85 million to  clean up the contaminated water and land, while the Federal Government has agreed to put a trust fund in place to ensure the establishment of a treatment center focused on ailments related to the mercury poisoning. The treatment facility is expected to cost about 88.7 million dollars, as estimated after a feasibility study. 1,2

Dryden Paper Mill

Mercury in the Environment

Mercury exists in nature in either the elemental, inorganic or organic forms. The organic form of mercury (Methyl mercury) is of greatest concern in the health industry.  Elemental mercury is transformed into the organic form in the aquatic environment by microbial activity, which is in turn bioaccumulated in the flesh of aquatic organisms  along the aquatic food chain. Biomagnified toxic methyl mercury in the aquatic apex predators is transferred to consumers via efficient absorption from the digestive tracts into the blood stream and eventually through  the blood-brain barrier. Excess concentrations of methyl mercury in the human body, with concentrations above 0.47 µg/day (per kg in adult body weight) and  0.2 µg/day (per kg in a child’s or pregnant mother’s body weight), results in deleterious neurologic effects in humans of any age. Additional health defects such as impaired vision, blindness and digestive disorders have been reported.3,4

Similar tragic occurrences of environmental mercuric contamination have been reported in some parts of the world. Between 1932 and 1968, a chemical plant in Minamata, Japan released mercury into a lake which resulted in the death of over 100 people. This occurrence was highly significant, coining the name “Minamata Disease” for syndromes associated with mercury poisoning, such as brain damage, paralysis, incoherent speech and delirium. Another memorable tragedy was reported in Iraq in the early 1970s, where methylmercury compounds were use in seed treatment in agriculture. Wheat grains that were treated with this toxic compound were planted, harvested and made into flour for human consumption. Bread made from the poisoned flour resulted in high mortality rate among the consumers. Occupational exposure is not left out of the list as reported in Ghana in the 1960s. Elemental mercury is used in artisanal gold mining,  where gold ores from near-surface deposits were mixed with the elemental mercury before heating to release the toxic mercury vapour into the environment, leaving the gold behind. Breathing in the mercuric vapour can lead to severe pneumonitis in humans. 5

Clean-up of Mercury Contamination

Clean-up of mercury contaminated sites, such as Carson River Mercury site and Sulphur Bank Mercury Mine in Clearlake California, have been reported by the United States Environmental Protection Agency (US EPA) . The technology used include ex-situ and in-situ treatment methods. The most common method reported is the excavation and disposal of mercury contaminated soil or sediment, as hazardous waste meant for landfill or treated at an approved thermal treatment facility.  The excavated land is backfilled with clean soil and ecologically restored. An in-situ treatment method can be the stabilization / solidification of the toxic substance by sealing in the contaminant with a mixture of cement and Sulphur containing compounds. This method is made possible using an auger-system to mix the soil and cement to immobilize the contaminant. Contaminated sediments can be sealed by a method called “capping”, where a layer of sand and gravel  is poured over the sediments to prevent contact further with the contaminant. These methods and technologies have been used effectively at various mercury contaminated sites in the United States. More information can be found here: https://www.epa.gov/mercury/what-epa-doing-reduce-mercury-pollution-and-exposures-mercury

Ideally, post remediation monitoring  should include restriction of the sealed-off area to public access, absolute cessation in the consumption of food sourced from the contaminated areas and an active reduction in all processes that release mercury into the environment. In situations where the mercury is an unavoidable  component of an industrial waste such as dental amalgam production wastes or battery chemical wastes, a preventive-control suggestion will be to discharge the liquid waste into a holding reservoir to allow mercury-settling into sludge, which can be collected and treated or appropriately disposed.

Since there is an immense need for more research in sustainable and environmental-friendly extensive mercury spill clean-up, more attention should be focused on proactively preventing further occurrences  by adhering strictly to the controls that have been put in place to manage all operations pertaining to the use of mercury.

References

  1. https://www.cbc.ca/news2/interactives/children-of-the-poisoned-river-mercury-poisoning-grassy-narrows-first-nation/
  2. https://globalnews.ca/news/5189817/grassy-narrows-liberals-mercury-treatment-facility/
  3. Pirkle, C.M., Muckle, G., Lemire, M. (2016) Managing Mercury Exposure in Northern Canadian Communities. CMAJ, 188 (14) 1015-1023
  4. Bernhoft R. A. (2011) Mercury toxicity and treatment: a review of the literature. Journal of environmental and public health, 2012, 460508. doi:10.1155/2012/460508
  5. Bonzongo JC.J., Donkor A.K., Nartey V.K., Lacerda L.D. (2004) Mercury Pollution in Ghana: A Case Study of Environmental Impacts of Artisanal Gold Mining in Sub-Saharan Africa. In: Drude de Lacerda L., Santelli R.E., Duursma E.K., Abrão J.J. (eds) Environmental Geochemistry in Tropical and Subtropical Environments. Environmental Science. Springer, Berlin, Heidelberg

VelocityEHS acquires Industrial Hygiene Software company Spiramid

VelocityEHS, a Chicago-based environment, health, safety (EHS) software company, recently announced it has acquired Spiramid, developer of the a system for managing industrial hygiene (IH). The acquisition adds Spiramid’s occupational safety & health software to the VelocityEHS’s EHS platform. The software, now called VelocityEHS Industrial Hygiene, gives organizations the capabilities to efficiently run an industrial hygiene program.

VelocityEHS is launching its new Industrial Hygiene solution at a time when IH is at an important crossroads. The need for workplace programs that anticipate and prevent workplace hazards is growing, while the number of certified industrial hygienists and investments in traditional programs has been on the decline.

“We’re excited to launch our powerful new Industrial Hygiene product. It’s a perfect fit for people working on the frontlines and has great synergy with our market-leading Chemical Management capabilities. Its simple design cuts through the complexity of IH tasks,” said Glenn Trout, president and CEO of VelocityEHS. “While there’s no substitute for a well-trained, well-resourced team of industrial hygienists, the reality today is that a growing number of EHS generalists are being called upon to do sampling and run IH programs that fall outside the scope of their training and traditional responsibilities. Whether you’re a veteran hygienist or new to the role, we believe our new IH solution will provide significant value.”

The software gives companies with sophisticated programs the ability to see, in one place and in real time, what’s happening across their enterprise. It gives staff hygienists new reporting tools — like dynamic risk matrices — to help them determine where and why to deploy resources, as well as to demonstrate the value of IH when talking with leadership stakeholders. For companies without a Certified Industrial Hygienist, it provides a framework for managing exposure risks and meeting a wide range of IH tasks.

“The goal of any industrial hygiene program is to help as many people in the workplace as you can. I am proud to see our IH software, which we have spent years perfecting, added to the VelocityEHS platform, which serves the industry’s largest EHS software community,” said Dave Risi, co-founder of Spiramid.

Managing IH can require the collaboration of many stakeholders, including people sampling in the field, IH consultants, outside laboratories, and program managers. VelocityEHS’ Industrial Hygiene software is a central management hub, facilitating the workflow and hand-off of responsibilities from party to party. For instance, users can more easily plan and control all aspects of IH, from selection of chemicals and analytical methods, to selection of laboratories and access of sampling results, with options to share information with the right stakeholders. The solution lets users send chain of custody forms directly to labs and receive the analytical data electronically, inside the product, eliminating the need for manual input and helping to avoid errors by making the information readily accessible.

Other features include an in-product database of CAS Registry Numbers, OELs and laboratories, plus easy tools for tracking and managing of similar exposure groups (SEGs), qualitative assessments, sampling plans, medical surveillance, surveys, samples and equipment. It is the smartest and most efficient way to track a high-volume of complicated sample data and to manage risk assessments and mitigation programs.

The new IH software, together with VelocityEHS’ Chemical Management and Industrial Ergonomics solutions, provides industrial hygienists with the comprehensive resources they need to promote healthier workplaces.

Demystifying Occupational Hygiene

Written by Abimbola Badejo, Staff Writer

At the recent Partners in Prevention 2019 Health and Safety Conference, Ontario, Canada; organized by Workplace Safety and Prevention Services (WSPS) Ontario, Canada, Dave Gardner of Pinchin Ltd. delivered a presentation on Demystifying Occupational Hygiene. Mr. Gardner is Senior Occupational Hygiene and Safety Consultant with Pinchin Ltd. Below is a summary of his presentation.

WHAT IS OCCUPATIONAL HYGIENE?

Occupational hygiene has been defined by the United States Department of Labour Occupational Safety and Health Administration as “that science and art devoted to the anticipation, recognition, evaluation, and control of those environmental factors or stresses arising in or from the workplace, which may cause sickness, impaired health and well-being, or significant discomfort among workers or among the citizens of the community.1.   Simply put, the goal of Occupational hygiene is to ensure the safety and protection of a worker at his or her workplace, provided the worker follows a set of guidelines  that have been put in place to safeguard his/her health and safety.  

Typical occupational hygiene principles include written standards, procedures and practices; workers training as part of a knowledge management program; logical thinking on the part of the creator; a combination of actions with words learned from the written standards; and total compliance with associated regulations.

WHY IS OCCUPATIONAL HYGIENE PROGRAM IMPORTANT?

An Occupational Hygiene program is of great importance as its negligence leads to occupational injuries and diseases. Occupational diseases are considered more significant due to factors associated with it; which include

  • Diseases caused by exposure to either chemical, physical or biological agents at the workplace
  • Sources such as exposure to airborne asbestos particles, confined spaces, noise, construction projects, etc.
  • Categories namely Long Latency Illness, Noise Induced Hearing Loss (NIHL), Chronic Exposure and effects and Acute Exposure and effects
  • Observable effects which are not seen until after a long duration of exposure
  •  75% of fatalities in diseases, attributed to occupational origins

The Ontario Workplace Safety and Insurance Board (WSIB) reported that approximately 130 thousand claims were filed, and about $940 million benefit costs were released, between 2008 and 2017. Occupational diseases with long latency are mostly serious and these account for only three percent of the occupational diseases with benefits.

Based on these factors (and those not mentioned), reviews have been made by the Human Resources and Skills Development Canada (HRSDC) and Labour Canada. These reviews include updates made to the Occupational Exposure Limits (OEL) of chemicals, training workers on the safe usage of materials and the equipment at the workplace, thorough knowledge of the materials and substances used at the workplace, compulsory and proper use of Personal Protective Equipment (PPE), alertness of workers to the state of their own health and compulsory medical check-ups in relation to workplace risk assessment.

CASE FOCUS: SUMMARY OF RISKS AND SURVEYS REPORTED FOR WORKERS IN THE CONSTRUCTION INDUSTRY

A survey made by the Center for Construction Research and Training regarding occupational diseases in the construction industry reported that the workers in this industry are:

  • twice as likely to have chronic obstructive lung diseases, five times more likely to have lung cancer, thirty-three times more likely to have asbestosis
  • inclined to suffer a 50% increase in Lung Cancer related deaths
  • predisposed to noise induced hearing loss (NIHL) (50% of workers)
  • susceptible to elevated levels of lead in their blood (17% of workers)
  • exposed to the allowable 8-hour exposure limit for Manganese during welding processes. This was observed with workers involved in boiler making (75%), iron-working (15%) and pipe-fitting (7%)).

In addition, a nationwide report has disclosed that 40% of WSIB costs are for construction occupational diseases, more construction workers die from a combination of occupational diseases and traumatic injuries and that 2 to 6 construction workers are more likely to develop occupational lung disease and NIHL.

As observed, most of the occupationally related diseases can be prevented by simple tasks such as hand-washing, proper use of PPE and correct compliance to defined regulations.

LEGISLATIONS GOVERNING OCCUPATIONAL HYGIENE

To ensure the protection of workers in various Canadian industries, regulations and guidelines have been put in place; some of which require compliance by either the employee or the employer. The legislations and related codes/standards guiding occupational hygiene in workplaces include:

Some of the provided regulations and guidelines are specific while others are general in application. The key to correct interpretation is to apply the correct regulation to the right workplace situation.

An example of a proper legislation application: Silica is an inert substance and an irreplaceable material in most products and buildings in the world today.  As the second most abundant mineral on the planet, silica is used in numerous ways. Getting the substance to the usable state requires processing, which exposes the worker to the respirable crystalline form. The regulation (O. Reg 490/09), listing silica as a designated substance, does not apply to the silica infused products but to the respirable fractions which the processing worker is exposed to. The regulation specifies an occupational exposure limit (OEL) for respirable crystalline silica as 0.05 mg/m3 of air (cristobalite silica) and 0.1 mg/m3 of air (quartz and tripoli silica) for an 8-hour/day or 40-hour weekly exposure. This regulation, however, does not apply to the employer or some other workers on a construction  project; but the employer’s responsibility will be to protect the worker’s health in compliance to section 25 (2)(h) of the OHSA, requiring employers to take every reasonable precaution in the circumstances to protect a worker.

FUNDAMENTALS OF OCCUPATIONAL HYGIENE

Before initiating an occupational hygiene program, a clearer understanding of basic terms is ideal.

Industrial Hygiene: this is an exercise devoted to the anticipation, recognition, evaluation, and control of those environmental stresses arising from the workplace, which may cause the impairment of a worker’s health.

Toxicology: the study of how chemical, physical and biological agents adversely affect biological systems. The adverse effects include irritation, sensitization, organ failure, diseases or cancer.

Disease, dose and exposure: Disease / response is caused by an agent dosage. Dosage is measured in relation to the exposure of the worker to an agent. Mathematically, exposure is calculated as the agent concentration multiplied by duration of exposure (concentration x time). Therefore, sampling surveys are simply estimating the exposure of the worker to a specific concentration of the agent. Exposure routes may be through inhalation, ingestion, contact or skin absorption.

Threshold Limit Values (TLV): TLVs are general concentration limit values for specific chemicals, to which a healthy adult worker can be exposed.  However, TLVs does not adequately protect all workers as their susceptibility levels to various chemicals are unique to them. TLVs are used by regulators as guidelines or recommendations to assist in the control of potential workplace hazards.

Time-Weighted Average (TLV-TWA): TWA concentration for a conventional 8-hour/day or 40-hour/week , to which a worker may be repeatedly exposed.

Short-Term Exposure Limit (TLV-STEL): This is a 15-minute TWA exposure that should not be exceeded.

Ceiling (TLV-C): This is a concentration that must not be exceeded during any part of working exposure

Air Monitoring: This is a process of sampling the air in the workplace, on a regular basis. The monitoring  may be qualitative (risk assessments, hygiene walkthroughs and training) or quantitative (air, noise and wipe sampling) in perspective.

RISK ASSESSMENT

The first focus of an occupational hygiene program is to conduct a risk assessment of the workplace processes.  A risk assessment shows that 20% of the activities or tasks  carried out, leads to 80% of  risks. Carrying out a risk assessment, focuses on the adverse effects of  a hazardous agent and the associated level of risk if a worker is exposed to it. Approaches to risk assessment include Critical Tasks Analysis (where stepwise task and risk inventories are made with the focus on worker’s safety), Process Safety (where the focus is on the process, controlling the risk to keep the worker safe) or a combination of both approaches. Risk assessment, therefore, is done  as thus:

  1. Making a list of the agents the worker is exposed to,
  2. Identifying the routes of entry,
  3. Identifying a relative risk level (low, medium or high),
  4. Documenting the control in place and its effectiveness.

Table 1. Requirements of a Hazard Reviewer. Scores are used to dictate the skill level required to assess and develop control strategies.

Risk
Score
Risk
Level
Minimum Requirements
<10 Low to Medium low Any trained employee
>10 to <20 Medium Health and Safety Department or a contracted Health and Safety Consultant
20 & above High Certified Health and Safety Professional or Industrial Hygienist (CRSP, CSP, CIH, ROH)

DEVELOPING AIR SAMPLING STRATEGIES

A preliminary survey is initially conducted using simple and common tools such as human senses (sight, taste, hear, smell, taste and gut-feelings), video camera, photo camera, tape measure and a notebook. Optional tools include velometer and smoke tubes.

Next, all knowledge and processes related to the hazardous agents are sought out using the central dogma of risk assessment (Recognition, Evaluation and Control).

The sampling itself should be done using standardized and validated methods (NIOSH, EPA, ASTM, etc.).

The extent of sampling should be determined, whether personal (breathing zone) samples or area samples.

Next, the duration of sampling should be determined, which could be  a whole day, full-shift, partial shift, single samples, sequential samples, grab or composite samples.

The worker to be sampled should be with the worker with the  highest exposure potential or a group of workers with similar exposure due to the similarity of their tasks at the workplace.

The amount of samples taken should also be determined.

The time of sampling should be determined (day or night shift, winter or summer season, etc.)

Documentation should be made at every sampling point; and this should include start and stop times, environmental conditions, chronological log of work tasks, quantified conditions during production, duration of shifts and break periods, use of PPE, engineering controls, housekeeping habits and the state of workplace ventilation.

PROGRAM DEVELOPMENT

Occupational hygiene programs are made with several guidelines governing it. According to the province of Ontario, all control programs must provide engineering controls, work practices and hygiene facilities  to control a workers exposure to a designated substance; methods and procedure should be put in place to monitor airborne concentrations of designated substances and measure workers exposure to the same; training programs should be organized for supervisors and workers on the health effects of the designated substance and the respective controls required. A typical Occupational Hygiene program, therefore, should  include the following:

  • Version history
  • Purpose / objectives
  • Scope and application
  • Distribution
  • Definitions and abbreviations
  • Roles, responsibilities and accountabilities
  • Program management (Resources, commitment and program coordinator)
  • Risk assessments
  • Exposure monitoring plans
  • Occupational hygiene surveys (sampling strategy development, analytical services, documentation and reporting )
  • Occupational hygiene controls
  • Training
  • Related document / appendices
  • Quality assurance
  • Maintenance of standard operating practices (SOPs)
  • Annual summary report.

CONCLUSION

An occupational hygiene program is an important component of workplace management. This ensures the protection of workers’ health, which leads to better and greater productivity at the workplace.  The foundation of occupational hygiene programs is to understand the principles that govern the program and knowing how to apply the principles to various situations at the workplace. Proper application and effective controls will assist in achieving the goal of establishing a safe environment for workers to operate.

REFERENCES

  1. https://www.osha.gov/dte/library/industrial_hygiene/industrial_hygiene.pdf

Meat Packing Plant facing major fines for exposing workers to hazardous chemicals

The U.S. Department of Labor’s Occupational Safety and Health Administration (U.S. OSHA) has cited 7 S Packing LLC – operating as Texas Packing Company in San Angelo, Texas – for exposing workers to releases of hazardous chemicals. The company faces $615,640 in penalties.

The U.S. OSHA determined that the meat-packing facility failed to implement a required Process Safety Management (PSM) program for operating an ammonia refrigeration unit containing over 10,000 pounds of anhydrous ammonia. The employer also failed to provide fall protection, guard machines and equipment, control hazardous energy, and implement a respiratory protection program.

The PSM Covered Chemical Facilities National Emphasis Program focuses on reducing or eliminating workplace hazards at chemical facilities to protect workers from catastrophic releases of highly hazardous chemicals. PSM standards emphasize the management of hazards associated with highly hazardous chemicals, and establishes a comprehensive management program that integrates technologies, procedures, and management practices to prevent an unexpected release.

The company has 15 business days from receipt of the citations and penalties to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance.

Global Crisis, Emergency and Incident Management Platforms Market 2019

Persistence Market Research recent market report on Global Crisis, Emergency and Incident Management Platforms estimates that it will be worth $102 billion (USD) by the end of 2024.

A 2017 market analysis by Persistence Market Research on the market in North America predicted the year-over-year growth the Global Crisis, Emergency and Incident Management Platforms to increase at a CAGR of 7.2%. through to 2023. The 2017 report estimated that the North America market accounted for a relatively high market share and be valued at more than US$ 20 Billion in 2017. The report estimated that the North American regional market would continue to remain dominant in terms of value during the forecast period (2017 – 2024).

The latest market report from Persistence Market Research predicts that the global market or crisis, emergency & incident management platforms will be fragmented across various systems and platforms. Among which, the demand for web-based emergency management software, geospatial technology, emergency notification system, hazmat technology, seismic warning systems, and remote weather monitoring systems is expected to gain traction throughout the forecast period. These systems are also predicted to be demanding greater incorporation of communication technologies. Through 2024, satellite phone, vehicle-ready gateways, and emergency response radars will be the most dominant type of communication technologies used in working of any crisis, emergency & incident management platform.

Likewise, the report also expects that during the stipulated forecast period, professional services such as consulting and emergency operation center (EOC) design & integration will be in great demand. By the end of 2024, crisis, emergency & incident management platforms will be actively adopted across industry verticals such as BFSI, energy & utility, government & defense, and telecommunication and IT.

A regional analysis of the global crisis, emergency & incident management platform market indicates that North America will dominate by accounting for over US$ 36 Billion revenues by 2024-end. Adoption for such platforms will also be high in Asia-Pacific, and the region is expected to showcase a 6% value CAGR.

Leading providers of crisis, emergency & incident management platforms in the world include Honeywell International, Inc., Lockheed Martin Corporation, Motorola Solution, Inc., Rockwell Collins, Inc., Siemens AG, Iridium Communication Inc., Guardly, Environmental System Research Institute, Inc., and Intergraph Corporation.

Get Rid of Outdated Hazmat Compliance Materials

Written by Hazmat University

Spring is in the air! And along with that comes the pleasant and incessant urge to clean closets, declutter the house, and scrub the whole thing down!  Something that we may overlook, however, is that Spring is also a perfect time to do a Hazardous Materials refresh – and it doesn’t involve washing walls!  

Spring Clean and Keep Current Hazmat Compliance Materials

Spring is also an ideal time to do a Hazardous Materials refresh. Many people avoid this kind of clean-up because they don’t know what they should keep and for how long. But hazmat compliance is dependent on maintaining current knowledge and current practices. Now really is an excellent time to make sure that your hazardous materials are current, relevant, and not overly burdensome for the people that need them to properly do their jobs.

Out With The Old, Hold On to the Current

Do you have a tendency to hold on to outdated materials, forms, or labels? If you are, stop immediately. Hazmat compliance materials are detail-oriented to begin with, so the simpler, clearer and less cluttered, the better. You’ll be happy you did it. Outdated materials present the danger of actually being used by someone and causing an issue. Good riddance, old subsidiary risk labels!

Which Important Documents Should You Keep?

As regulations for shipping dangerous goods increase in complexity, there’s no reason to keep information laying around that could increase your risk for non-compliance, including stopped shipments, supply chain delays, fines and more.

The industry makes sweeping changes all the time, making it all the more important to only have up-to-date regulations on hand. If your printed copies of 49 CFR, IATA DGR, or the IMDG Code are outdated, it may be time to move on to online resources. An example of an online resource is Title 49 CFR   “e-CFR” which is available online, and the Government Publishing Office maintains it so that it is always up-to-date.

Compliance is dependent on maintaining current knowledge and current practices, and this is a perfect time to ensure that your hazardous materials

  • regulations;
  • policies;
  • practices;
  • employee training;
  • training content;
  • training records;
  • packaging closure instructions;
  • internal audits;
  • emergency response provider product information;
  • and more

are current, relevant, and not overly burdensome for the people that rely on them to properly do their job. Hazardous materials transportation compliance is detail-saturated to begin with, so the simpler you can make it, the better – and you’ll be happy that you did.

Making sure you discard old training and compliance documents is crucial, especially if you have new or inexperienced hazmat employees. Remembering all the regulations for various shipping transportation processes can be difficult. That’s part of the reason why it’s crucial to stay up-to-date on regulations.

It’s also critical that hazmat employees have access to transportation regulations at all times in case they need to refer to them. Remembering the most essential aspects of hazmat compliance becomes second nature for most employees, but that happens over time.

Stay Up-to-Date with Hazmat University

Everyone involved in the transportation of hazardous materials in commerce is required by law to be aware and comply with the appropriate regulations. Hazmat University offers several training programs for shipping and handling hazmat by air, ground, and sea. Courses include initial training for novices, recurrent training for those with more experience.

Now we can take a breath of that fresh spring air, and just maybe we have inspired you to clean out those closets too! Happy Spring from the Bureau of Dangerous Goods!

What is the Cost of An Asbestos Test?

Written by Robert B. Greene, PE, PG, CIH, LEED AP, GLE Associates Inc.

The presence of asbestos can be hazardous to workers and building occupants during renovations and even in the course of daily business, and the only way to know if it is a problem is to test for it.

What Is Asbestos and Why Is It a Problem?

Asbestos is a heat-resistant silicate fiber that is frequently present in building materials. Contrary to common understanding, it is still used in building materials today and can be present in any building of any age.

It becomes a problem when asbestos-containing materials are disturbed and the fibers enter the air. The fibers lodge themselves in the lungs of anyone who breathes them in and can cause mesothelioma, lung cancer, and other acute and long-term health problems, up to and including death.

How and When Should You Test for Asbestos?

An asbestos test (also called an asbestos survey) should be conducted prior to any renovation or demolition activities in any building of any age. In fact, an asbestos survey is required by law prior to these activities for any building materials which may be disturbed.

You should also be concerned about the ongoing presence of asbestos in older buildings, where asbestos-containing materials may have deteriorated over time. This can cause them to release asbestos fibers into the air, creating a hazard for building occupants. An asbestos survey is a relatively inexpensive way to ensure your buildings are safe for tenants and employees.

How Does an Asbestos Test Work?

A qualified asbestos company will bring in an experienced team to collect samples of potential asbestos-containing building materials. The samples will be sent to a lab for testing, and a report will be generated based on the results.

How Much Does an Asbestos Test Cost?

An asbestos survey is a relatively inexpensive precaution and may be mandated by law prior to even small renovation projects. The cost to conduct asbestos testing will vary widely based on a number of factors, including:

  • The type of facility. The more complex the building, the more time it will take to collect an adequate number of samples from all the relevant types of materials. It will also cost more to have more samples tested in the lab. For example, an asbestos survey of a hospital would be much more expensive than the same size open warehouse.
  • Type of survey. For example, a survey for a renovation of a small portion of the building, affecting a limited number of building materials, will generally cost substantially less than a building demolition survey which will affect all of the building’s components and materials.
  • Square footage. A larger facility will likewise require more time and a larger number of samples, all else being equal.
  • Facility use. If the facility is currently in use, the cost of testing will increase to account for accommodations and protections necessary for the safety and comfort of your occupants. In some cases, such as hospitals, extra care will be required to minimize disruption and ensure safety, which can further increase the cost.
  • Accessibility. If asbestos surveyors have to crawl into tight spaces, remove walls or ceiling materials, climb to high spaces, or use ladders and scaffolding to reach potential asbestos-containing materials, those factors will increase the cost of testing.

It’s hard to know exactly what your cost for an asbestos survey will be without a qualified quotation.


About the Author

Robert B. Greene, PE, PG, CIH, LEED AP has served in the engineering, environmental consulting, construction and remediation arenas for more than 36 years, including president of GLE since 1989. He has managed numerous consulting and contracting projects for public and private sector clients throughout the United States with construction and environmental remediation costs exceeding $100 million.

In 1987, the governor appointed Mr. Greene to the Florida Asbestos Committee, which was responsible for developing state asbestos regulations. He has also served as an expert witness for litigation for environmental and construction related issues.

United States: U.S. EPA Takes Action Under TSCA Identifying Chemicals For Agency Scrutiny

Written by by Lawrence E. Culleen, Arnold & Porter

Prioritization of Chemicals

In its continuing quest to meet regulatory deadlines imposed by the 2016 amendments to the Toxic Substances Control Act (TSCA), the United States Environmental Protection Agency (U.S. EPA) has published a list of 40 chemicals that must be “prioritized” by the end of 2019. The announcement marks the beginning of the Agency’s process for designating the 40 listed chemicals identified as either “high” or “low” priority substances for further the U.S. EPA scrutiny. At the conclusion of the prioritization process, at least 20 of the substances likely will be designated as high priority.

A high priority designation immediately commences the U.S. EPA’s formal “risk evaluation” procedures under the amended statute. The risk evaluation process can lead to “pause preemption” under the terms of the 2016 amendments and new state laws and regulations restricting the manufacture, processing, distribution, and use of a chemical substance undergoing a risk evaluation could not be established until the evaluation process is completed. The U.S. EPA commenced its first 10 risk evaluations as required under the amended law at the close of 2016. The Agency is required to have an additional 20 risk evaluations of high priority substances ongoing by December 22, 2019. If the U.S. EPA’s risk evaluation process concludes that a substance presents an “unreasonable risk” to health or the environment under its “conditions of use,” the Agency must commence a rulemaking to prohibit or limit the use of the substance under Section 6 of TSCA.

The Agency’s announcement of the list of chemicals to undergo prioritization provides the makers and users of the listed substances an important, time limited opportunity to submit relevant information such as the uses, hazards, and exposure for these chemicals. The U.S. EPA has opened a docket for each of the 40 chemicals and the opportunity to submit information for the U.S. EPA’s consideration will close in 90 days (on June 19, 2019). The U.S. EPA will then move to propose the designation of these chemical substances as either high priority or low priority. The statute requires the U.S. EPA to complete the prioritization process, by finalizing its high priority and low priority designations, within the next nine to 12 months.

The list of 20 substances to be reviewed as high priority candidates consists entirely of substances previously identified by U.S. EPA in 2014 as “Work Plan” chemicals. Thus, the list contains few chemicals that should be considered complete “surprises.” However, the inclusion of formaldehyde may raise concerns in certain quarters given the scrutiny that has been given to the U.S. EPA’s previous struggles with assessing the potential effects of formaldehyde. The Agency has attempted to address these concerns by stating “Moving forward evaluating formaldehyde under the TSCA program does not mean that the formaldehyde work done under IRIS will be lost. In fact, the work done for IRIS will inform the TSCA process. By using our TSCA authority EPA will be able to take regulatory steps; IRIS does not have this authority.” Also included in the listing are several chlorinated solvents, phthalates, flame retardants, a fragrance additive, and a polymer pre-curser:

  • p-Dichlorobenzene
  • 1,2-Dichloroethane
  • trans-1,2- Dichloroethylene
  • o-Dichlorobenzene
  • 1,1,2-Trichloroethane
  • 1,2-Dichloropropane
  • 1,1-Dichloroethane
  • Dibutyl phthalate (DBP) (1,2-Benzene- dicarboxylic acid, 1,2- dibutyl ester)
  • Butyl benzyl phthalate (BBP) – 1,2-Benzene- dicarboxylic acid, 1- butyl 2(phenylmethyl) ester
  • Di-ethylhexyl phthalate (DEHP) – (1,2-Benzene- dicarboxylic acid, 1,2- bis(2-ethylhexyl) ester)
  • Di-isobutyl phthalate (DIBP) – (1,2-Benzene- dicarboxylic acid, 1,2- bis-(2methylpropyl) ester)
  • Dicyclohexyl phthalate
  • 4,4′-(1-Methylethylidene)bis[2, 6-dibromophenol] (TBBPA)
  • Tris(2-chloroethyl) phosphate (TCEP)
  • Phosphoric acid, triphenyl ester (TPP)
  • Ethylene dibromide
  • 1,3-Butadiene
  • 1,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta [g]-2-benzopyran (HHCB)
  • Formaldehyde
  • Phthalic anhydride

The U.S. EPA has signaled that it has received a manufacturer request for a EPA to undertake a risk evaluation of two additional phthalates which, if administrative requirements for such request have been met, the Agency would announce publicly in the very near term.

The 20 low priority candidate chemicals were selected from the U.S. EPA’s “Safer Chemicals Ingredients List”—a list of substances previously evaluated and considered to meet the U.S. EPA’s “Safer Choice” criteria for use in certain common product categories, such as cleaning products.

Other Recent and Impending U.S. EPA Actions Under TSCA

Given the numerous deadlines that are looming under the amendments to TSCA, it is critical that chemical manufacturers and processors of chemicals and formulations remain aware of the recent and upcoming actions under TSCA that can significantly impact their businesses. The following provides a short list of important actions of which to be aware.

Active/Inactive TSCA Inventory Designations. EPA released an updated version of the TSCA Inventory in February 2019. The Inventory is available for download here. This version of the Inventory includes chemical substances reported by manufacturers and processors by their respective reporting deadlines in 2018. The updated TSCA Inventory (confidential and non-confidential versions) includes 40,655 “active” chemical substances and 45,573 “inactive” chemical substances. Once the current 90-day “transition period” has concluded, it will be unlawful to manufacture, import or process in the US any substance that is listed as “inactive” without first providing notice to the U.S. EPA. Thus, prior to the expiration of the “transition period” on May 20, 2019, manufacturers and processors of chemical substances that are not listed as active on the February 2019 TSCA Inventory must take steps to activate the substance by filing a Notice of Activity (NOA Form B) for any chemical substance that they currently are manufacturing or processing, or anticipate manufacturing or processing within 90 days of submission.

Final TSCA Section 6(a) for Methylene Chloride in Paint and Coating Removers. EPA has released its long-awaited TSCA Section 6(a) rule restricting the use of methylene chloride in paint and coating removers. The final rule prohibits the manufacture, processing, and distribution of methylene chloride in paint removers for consumer use. The rule prohibits the sale of methylene chloride-containing paint and coating removers at retail establishments with any consumer sales (including e-commerce sales). The U.S. EPA declined to finalize its determination that the commercial use of methylene chloride-containing paint and coating removers presents an unreasonable risk. Therefore, distributors to commercial users, industrial users, and other businesses will continue to be permitted to distribute methylene chloride-containing paint and coating removers. However, given recent efforts by store-front retailers to “deselect” such products for consumer sales, it remains unclear how distributions to commercial users can or will occur.

The U.S. EPA simultaneously released an advanced notice of proposed rulemaking related to a potential certification program for commercial uses of methylene chloride-containing paint and coating removers. The U.S. EPA has similar programs in place for certain pesticides and refrigerants, and the United Kingdom currently has in place a program to certify commercial users of methylene chloride-containing paint and coating removers. The U.S. EPA is seeking comment on whether a certification program is the appropriate tool to address any potential risks that could be posed by the commercial use of methylene chloride-containing paint and coating removers.

Upcoming Draft Risk Evaluations. The U.S. EPA is expected to publish within days or weeks the highly anticipated draft Risk Evaluations for the remaining 9 of the 10 initial substances to undergo TSCA Risk Evaluations under the amended law and which have been under review since December 2016. The Agency will accept comments on the drafts for a limited period.

Proposed Rules for 5 PBT substances. The U.S. EPA is required to issue no later than June 2019 proposed TSCA Section 6 regulations for 5 persistent, bioaccumulative and toxic (PBT) substances that were identified during 2016 as priorities for regulatory action. The Agency must propose expedited rules intended to reduce exposures to the extent practicable.


*Camille Heyboer also contributed to this Advisory.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

About the Author

Lawrence Culleen represents clients on administrative, regulatory, and enforcement matters involving federal agencies such as the U.S. Environmental Protection Agency (EPA), the US Department of Agriculture, the US Food and Drug Administration, and the Consumer Product Safety Commission. Mr. Culleen has broad experience advising clients on US and international regulatory programs that govern commercial and consumer use chemicals, pesticides and antimicrobials, as well as the products of biotechnology and nanoscale materials. Prior to joining the firm, Mr. Culleen held significant positions at EPA serving as a manager in various risk-management programs which oversee pesticides, chemical substances, and biotechnology products.

Disagreement on Human Health Impacts from former Wood Treatment Facility in Edmonton

On February 26th, the Alberta Environmental Appeals Board (AEAB) issued a Report with recommendations related to Orders issued by the Alberta Environment Ministry for the remediation of a former wood preservative facility in Edmonton.

The site had been owned by Domtar Inc. and had been used to treat wood with preservatives from 1924 through to 1987. The property was purchased by a Cherokee Canada Inc. in 2010. Cherokee planned on remediating the site and developing a residential neighbourhood.

The AEAB report deals with a dispute between Cherokee and the Alberta Environment Ministry on whether the property that housed the wood treated facility is remediated and if it poses a hazard to human health. The AEAB report concludes “there is no immediate risk to these residents and other people.”

The Board also concluded the Alberta Environment had no basis for issuing Enforcement Orders against Cherokee. The Board stated that more clean-up of the site is needed, but none of it is an emergency as claimed by the Alberta Environment Ministry.

John Dill, a managing partner at Cherokee, stated in an interview with Global News: “I’m pleased that the decision confirms that the site is safe for the neighbourhood and its residents. We’re anxious to put an end to any further uncertainty by following the process that’s been set out, suggested by the board and minister.”

If Cherokee had not appealed the Order and won, it would have faced a very significant cost in removing and disposing of the contaminated material. The company estimated the cost to conform to the Orders to be in the at least $52 million.

March 7th Alberta Environment Press Release

On March 7th, the Alberta Ministry of the Environment and Parks released the results of analytical tests performed on soil samples taken at the former wood treatment plant along with findings from a human health risk assessment. The risk assessment concludes that contamination at the site is hazardous to human health.

Officials from the Alberta Ministry of Alberta and Parks conducted sampling at analysis of the soil at site of the former wood treatment plant at various times between 2017 and 2018. The sampling program consisted of sampling surface soil and subsurface soils at more than 1,039 locations at the property and collecting/analyzing over 1,457 soil samples.

The results from the analysis of the soil samples indicate 183 samples have levels of contamination that exceed human health guidelines for dioxins and furans. Of these, 96 per cent are located in fenced-off areas. A number of other contaminants of concern for human health are identified in these reports. Remediation of those locations remains the responsibility of the companies previously ordered by Alberta Environment and Parks to clean up the site.

Google Maps view of the Site and Surrounding Properties

Dr. Deena Hinshaw, Chief Medical Officer of Health for Alberta stated: “Our highest priority is the health and safety of residents, and we will continue to work towards minimizing any potential health risks to local residents. While these reports show that there are hazards in the areas, these risks are being addressed through the protective measures already in place until remediation of the soil is undertaken.”

Human Health Risk Assessment

Alberta Health issued the finding of the Human Health Risk Assessment. It made a preliminary comparison of the rates of cancer, miscarriages and birth defects in the surrounding neighbourhoods. This initial analysis found no difference between rates in the area near the former Domtar site compared with other parts of the province, with the exception of three types of cancer.

Among people who had lived in the area for 10 or more years, there were:

  • 34 cases of breast cancer in women (16 to 31 cases would have been expected)
  • 14 cases of endometrial cancer in women (three to nine cases would have been expected)
  • 22 cases of lung cancer in men (six to 14 cases would have been expected)

No differences in any childhood cancers were found compared with other parts of the province.

This data on its own does not indicate why there are higher rates for these three types of cancer in the area. Many factors could contribute to an increased risk of cancer, including but not limited to medical history, medication use and tobacco use. Alberta Health will, therefore, be working immediately with federal experts to conduct a field epidemiology investigation to try and identify what population health factors might have contributed to higher rates of these three cancers.

The Alberta Environment press release states, as a precautionary measure, women who have lived in the area for 10 or more years should talk to their doctors about the risks and benefits of starting breast cancer screening at the age of 40. This is a precaution until the results of the field epidemiology study are available.

History of the Site

The site itself had been used as a wood preservative plant by Domtar Inc. from 1924 until 1987. The plant manufactured “treated” wood products such as railway ties and telephone poles. The wood products were treated with chemical preservatives, such as creosote, to prolong their lifespan.

Between 1987 and 2008, the plant was decommissioned and Domtar conducted a partial remediation of the property including soil testing. Contamination remains in the subsurface including creosote, polycyclic aromatic hydrocarbons, dioxins and furans.

Cherokee Canada Inc. bought the site from Domtar in 2010 for $1.8 million. The purchase of the property is made with the company fully aware of the contamination at the site and with the acknowledgement by the Alberta Environment Ministry of a remediation plan to clean-up the property prior to redeveloping it for residential use.

Between 2011 and 2016, Cherokee Canada Inc. works on its remediation plan. Part of the plan consists of constructing a berm with contaminated soil from the site and covering it with clean soil. Cherokee Canada Inc. claims the berm structure contains contamination and that natural attention of the organic contaminants in the soil will occur over decades.

A 2013 environmental risk assessment conducted by Cherokee Canada Inc.
concludes that the constructed berm should not lead to any adverse health or environmental outcomes. The Alberta Environment Ministry approves a remediation certificate for a parcel of the site and allows for construction of a residential housing development on the parcel.

By October 2014, the contamination berm is nearly complete. The Alberta Environment Ministry claims that it was the first it had heard of the berm’s construction. The company says the province knew about the project all along and even had representatives on-site from time to time.

In 2016, the Alberta Environment Ministry conducts its own environmental testing at the site and claims that there is evidence of naphthalene in most of the samples, and that the substance is not contained.

Late in 2016, Cherokee sues the Province of Alberta for $126 million, claiming Alberta Environment acted in bad faith by “recklessly” changing its position on the remediation plan after the company had already spent considerable money.

Also in 2016, Alberta Environment issues an Enforcement Order that requires Cherokee to conduct further environmental testing. It also issues an Environmental Enforcement Order against both Cherokee and Domtar requiring further environmental testing in other parcels at the site.

In 2018, the Alberta Environment Ministry said third-party testing at the site found chemicals dangerous to human health. It imposed five enforcement orders on Cherokee, requiring the company to remediate any contamination.

Cherokee appealed the decision, arguing it had already undertaken remediation efforts (as had Domtar), including isolating and protecting contaminated soil from exposure.

The February 26th, 2019 decision by the Alberta Environmental Appeals Board vindicated Cherokee as the Board stated the Orders were inappropriate.

Cherokee Canada Inc.’s Position

In response to the Alberta Environment’s March 7th announcement, Cherokee issued its own press release. In the release, the company claims that Alberta Environment March 7th publication provides unsubstantiated information to community members about potential health risks. It also states that the issue of health risk and the appropriate standards and scientific criteria for remediation for certain chemicals of concern were addressed in by the Environmental Appeals Board in 2018.

The press release also states “We are concerned that the Ministry’s approach is a veiled attempt to influence the Minister’s response to the Board’s independent Report and Recommendations or to attempt to discredit the Board’s findings.”

March 13th Alberta Environment Orders

On March 13, Alberta Environment and Parks Minister Shannon Phillips released her decision on the appeal of the orders issued to Cherokee Canada Inc., 1510837 Alberta Ltd. and Domtar Inc.

In the the newest order, the minister directs the both Cherokee and Domtar to undertake the work on the site within specific periods of time from the issuance of the order. This work includes:

  • Temporary dust control plans (within seven days)
  • Dust control plans (within 60 days)
  • Site delineation (sampling) plan (within 90 days)
  • Site delineation(sampling) (within 150 days)
  • Site modelling identifying all current and historical sampling (within 180 days)
  • Human health risk assessment (within 210 days)
  • Site-specific risk assessments (within 210 days)
  • Reclamation and remediation plans (within 240 days)
  • Long term site monitoring plans (within 240 days)
  • Completion of residential reclamation components (within 280 days)

The minister also issued two environmental protection orders:

  • An order to Cherokee Canada Inc. and 15120837 Alberta Ltd. to conduct sampling and remediation within the neighbouring community and for the berm to the south of the community to address the presence of dioxins and furans.
  • An order to Domtar Inc. to conduct sampling and remediation within the neighbouring community and for the Greenbelt to the south of the community to address the presence of naphthalene, dioxins and furans.

A spokesperson for the Province of Alberta pointed out the AEAB’s recommendations “did not take into consideration the new testing results and health outcomes issued by the chief medical officer of health, as this information was not before the board at the time of the hearings (see below).

Brownfield Redevelopment in New York City and Community Air Monitoring – What you need to know

Written by Paul R. Pickering, Aeroqual Ltd.

Brownfield cleanup in New York City

As New York City’s need for space grows, existing stock of land must be used more effectively. Brownfield cleanup and redevelopment represents one of the best opportunities to engage communities and reclaim land for development in many cities. In 2018, the Mayor’s Office of Environmental Remediation (MOER) announced 1000×21, the most aggressive land cleanup and revitalization goal of any city in the world. This OneNYCinitiative seeks to remediate and redevelop 1,000 lots in NYC by the end of the de Blasio administration in 2021.


A vacant lot in Mott Haven, NY before remediation. Photo: OneNYC

Remediation air quality challenges

Any time a remediation or construction project involves earth-moving, it has the potential to release particulate (dust) and volatile organic compounds (VOCs) contaminants that exist below the surface. VOCs will readily transition to the gaseous, breathable phase, when exposed to air. Particulate emissions must be controlled to prevent impacts to the respiratory system. Negative impacts range from mild lung irritation to chronic lung disease. 

Regulations to protect community

To protect workers and the surrounding community, construction and demolition projects that involve excavation need to follow a stringent Community Air Monitoring Plan(CAMP), as specified by the New York State Department of Health (NYSDOH). If the excavation activities are occurring on a remediation or cleanup site, additional requirements are outlined in a guidance document known as DER-10. NYSDOH and DER-10 specifically apply to sites in New York. However, agencies and authorities in other states may also recognize these guidelines. They have been known to apply or refer to them for projects in their designated territories.

What is DER-10?

In 2010, the New York State Department of Environmental Conservation (NYSDEC) issued Division of Environmental Remediation (DER)-10 Technical Guidance for Site Investigation and Remediation, known as DER-10. This is the source document the NYSDEC refer to for authority to oversee remediation projects. It was designed to help parties and consultants (environmental and engineering) in developing and implementing investigation and remediation projects at contaminated sites.

DER-10 extensively (over 225 pages) describes the A to Z requirements for remedial site investigations, cleanups, post-cleanup monitoring and site closure. It presents detailed technical guidance for each of the investigative and remedial steps undertaken at contaminated sites. DER-10 covers procedures for assessing the environmental conditions at the site, including air monitoring during remediation activities.

What is CAMP?

Appendix 1A of the DER-10 outlines requirements for the implementation of a CAMP. This air monitoring plan is prescribed by NYSDOH. It involves direct-reading air monitoring instruments placed at defined locations around the perimeter of a remediation, construction or demolition site.

A CAMP requires real-time air monitoring for total VOCs (also referred to as total organic vapors) and PM10 (particulate matter 10 micrometers or less in diameter) at downwind and upwind locations relative to each designated work area when certain activities are in progress at contaminated sites. The CAMP is not intended for use in establishing action levels for worker respiratory protection. Rather, it is intended to protect the downwind community) from potential airborne contaminants released as a direct result of investigative and remedial work activities. The downwind community includes off-site receptors such as residences, businesses, and on-site workers not directly involved with the subject work activities. The specified CAMP action levels require increased monitoring, corrective actions to abate emissions, and/or work shutdown. Additionally, the CAMP helps to confirm that work activities did not spread contamination off-site through the air.

VOC and particulate monitoring

Basic requirements of a CAMP call for real-time air monitoring for VOCs and/or particulate levels at the perimeter of the exclusion zone, or work area. Sites known to be contaminated with heavy metals alone may only require particulate monitoring. If radiological contamination is a concern, additional monitoring requirements may be necessary in consultation with NYSDEC and NYSDOH. The table below summarizes CAMP Monitoring Action Levels for total VOC and particulate monitoring.

CAMP air monitoring equipment

Since the introduction of DER-10 in 2010, sensor-based technologies have reduced the cost of air monitoring and increased efficiency of the implementation of CAMP. Real-time air monitoring solutions are available to fit the budget and complexity requirements of every project. Below is a sampling of equipment options:

Entry Level – Basic environmental dust monitoring kit

Assembled kits, like this Basic Environmental Dust Monitoring Kit from Raeco Rents, are portable and suited to short-term or temporary CAMP. The ensemble includes an off-the-shelf dust monitor, handheld PID monitor for total VOCs, and a cloud-based telemetry system mounted in an environmental enclosure.

Ultimate Flexibility – All-in-one air quality monitor

All-in-one air quality monitors, like the AQS1 and the Dust Sentry from Aeroqual, are highly flexible and defensible, as well as good allrounders for short or long-term CAMP. In addition to the primary particulate fraction PM10, these monitors can also measure PM2.5, PM1 and Total PM. They can also be configured for monitoring total VOCs and NO2 emissions from remediation and construction sites. A robust light-scattering Nephelometer with sharp cut cyclone is integrated with a PID-based VOC analyzer module (or GSE-based NO2 gas module), Cloud telemetry platform, air quality software, and optional plug-and-play weather and noise sensors. Trigger alerts are programmable for SMS and email notifications, or can be used to activate an external VOC canister sample collection for speciated analysis according to EPA Method TO-15.

The Rolls Royce – GC-based perimeter air monitoring station

Perimeter air monitoring stations, like the AirLogics Classic 2, contain analytical, climatic, and communications instrumentation. This equipment includes: a gas chromatograph (GC) to measure specific VOCs, a respirable particulate meter to measure dust levels, shelter heaters and air conditioners, and a radio-based data acquisition system. These systems were originally developed for use in the cleanup of former manufactured gas plant (MGP) sites.

Weather monitoring

DER-10 guidelines require daily measurement of wind speed and direction, temperature, barometric pressure, and relative humidity, to establish background weather conditions. Wind direction data is used to position the air monitoring equipment in appropriate upwind and downwind locations.

The evaluation of weather conditions is also necessary for proper fugitive dust control. When extreme wind conditions make dust control ineffective, remedial actions may need to be suspended. There may be situations that require fugitive dust suppression and particulate monitoring requirements with more stringent action levels.

Additional monitoring

Under some circumstances, the contaminant concentration and/or toxicity may require additional monitoring to protect site personnel and the community. Additional integrated sampling and chemical analysis of the dust may be required. This must be evaluated when a Health and Safety Plan (HASP), is developed. Appropriate suppression and monitoring requirements are established for protection of people’s health and the environment.

Reporting

All recorded monitoring data is downloaded and field logged daily, including Action Limit Reports (if any) and daily CAMP monitoring location plans. Records are required to be maintained onsite for NYSDEC and NYSDOH to review. A description of the CAMP-related activities is also included in a monthly progress report submitted to the NYSDEC. The overall report submitted to the NYSDEC should include all CAMP monitoring records. If site works are stopped due to inability to control fugitive emissions to below the action limit, the NYSDEC is to be notified within twenty-four hours of the work stoppage.

For a real-life example of air monitoring at a remediation site please read my blog about the pilot cleanup of the Gowanus Canal, NY.

What CAMP solutions does Aeroqual offer?

Aeroqual’s Dust Sentry and AQS1 are flexible air monitoring platforms used by air quality professionals, and environmental and geotechnical consultants, for community air monitoring plans on remediation sites. We help environmental consultants deliver defensible data on projects by providing cost-effective and reliable instrumentation. For insights on the latest air monitoring trends at construction sites please read our blog about measuring NO2 and multiple PM fractions.


About the Author

Paul R. Pickering is the Business Development Director at Aeroqual Ltd., and is located in Auckland, New Zealand. Aeroqual Ltd. is a company that delivers innovative air quality and environmental monitoring solutions. He is passionate about making it easier to measure the air with advanced sensor-based technology. He believes that more relevant information about our environment can help us make better informed decisions, enjoy better quality of life, and make our planet a better home.