If you’ve read your OSHA Standard, 29CFR 1910, General Industry Standard – as we all do each night before falling asleep – you probably recall that, according to OSHA, there are two distinct ways to protect yourself and coworkers: engineering controls and PPE.
That’s especially true when processing water-damage claims involving contamination.
Restoration companies are responsible for evaluating all losses before beginning restoration. They must evaluate the job site for obvious or suspected hazards. Once identified, they must train employees about those hazards and how to avoid or at least mitigate them, through a comprehensive HAZCOM program. Training includes proper use of both engineering controls and PPE.
Several situations in particular require careful attention, particularly when only part of a building is involved:
- Category 3 water losses
- Mold contamination
- Deconstruction, which generates dust and debris, and which is frequently overlooked
- HAZMAT abatement, which also may require addition training and licensing, and trauma losses.
Incredibly, restorers continue to ignore safety basics that can have consequences for both themselves and their customers. In the litigation work we do involving losses with contamination or simply those that require partial or wholesale demolition, we’ve seen some startling violations of common sense mitigation and safety procedures.
During the initial walk-through inspection to identify safety and absorption/staining problems, restorers should turn off the HVAC system serving affected areas to avoid having that system cause cross contamination, as well as contaminating the system itself. As soon as practical, the HVAC systems should be protected from contaminant infiltration and eventually, cleaned.
According to the “IICRC S500 Standard and Reference Guide for Professional Water Damage Restoration”:
12.1.19 Using Existing Drying Resources
HVAC systems known or suspected of being contaminated with biological growth or hazardous materials should not be used as a drying resource. If contaminants are known or suspected to be present in the work area, supply or return vents located in this area should be contained to prevent possible contamination of the HVAC system during drying.
Restorers should eliminate the use of air movers that circulate contamination or dust and debris throughout the area. In losses involving older properties (e.g., those built before 1978), this debris may include HAZMAT such as asbestos or lead.
Restorers should use critical barriers or containment to separate affected from unaffected areas. At a minimum, restorers should create critical barriers at entry points; but ultimately they should erect plastic containment wherever necessary to prevent cross contamination. This includes ensuring that contamination is not spread when transporting debris from affected areas.
According to the IICRC S500:22.214.171.124 Multiple Layers of Drywall; Firewalls
…If multiple layers of thoroughly saturated drywall are present, restorers should make decisions quickly about whether to attempt to dry the assembly in place or to remove it…If the wall assembly is to be removed rather than dried, following worker protection and containment of demolition debris, removal should be performed near the start of the drying process…
Restorers should establish managed airflow using air filtration devices (AFDs) or negative air machines (NAMs). The AFD should be exhausted outside the affected area so as to create negative pressure and prevent cross contamination; i.e., air movement from affected to non-affected areas.
Again, according to IICRC S500:
12.5.2 Engineering Controls
The most effective way to ensure that gaseous and aerosolized contaminants do not spread is to isolate work areas by establishing critical barriers or by erecting containment (plastic sheeting) and maintaining adequate negative air pressure within contained work areas relative to adjacent areas…
Restorers should package or wrap contents and unsalvageable materials. Category 3-saturated carpet or cushion, for example, should be cut into manageable pieces and rolled in polyethylene plastic, with ends sealed as practical.
Of course, in addition to engineering controls, all restorers performing mitigation services, should have available and be trained in the proper use of appropriate PPE, provided and maintained by the company.
As illustrated with the quotes above, all of these procedures are covered in one or more areas of the IICRC S500. As a component of the industry “standard of care,” these steps are mandatory unless the restorer deviates based on common sense and professional judgment. Carelessness or compromising proper procedures at the demand of unformed property owners or cutting costs due to pressure from insurance representatives is never acceptable.
Failure to adhere to these important initial procedures can result only in potential harm to restorers or property occupants, not to mention the potential for protracted and expensive litigation.