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Read our latest Risk Factor Newsletter:

3/29/2021 - Odor Surveys and Assessments - 2021

If you ever had an odor or indoor air quality issue within your facility you can appreciate the difficultly in identifying the sources or causes and responding to questions from employees.

The Risk Factor 2nd Quarter 2007

Sunday, April 15, 2007
The Risk Factor 2nd Quarter 2007

Legionella Bacteria Prevention Planning

Legionella bacteria can be found in a variety of naturally occurring sources (e.g., soils, ponds and streams) in addition to man-made sources such as cooling towers, potable water systems, and heating, ventilation and air-conditioning (HVAC) systems. Legionella bacteria are present in public and well water supplies at extremely low concentrations. Legionella bacteria grow well in cooling towers and other indoor water systems, primarily because of the presence of warm water and available nutrients. If not properly treated, this warm water can promote the growth of algae, microbiological “slime” and amoebae, which enhance the potential for Legionella bacteria amplification.

Following the 1976 American Legion convention at the Bellevue Stratford Hotel in Philadelphia, 34 attendees died and 221 people became ill from pneumonia caused by the bacterium Legionella pneumophila. This disease, now commonly known as Legionnaires’ disease, is a respiratory infection that strikes susceptible individuals exposed to virulent Legionella bacteria. Infection results from inhaling airborne water droplets or mist containing viable disease-causing Legionella bacteria, which are small enough to pass deep into the lungs and be deposited in the alveoli, the small pockets in the lungs. The dose of Legionella pneumophila and other Legionella bacteria required to infect humans is not definitively known. Legionnaires’ disease can have an incubation period of two to ten days. Although healthy individuals can develop Legionnaires’ disease, people thought to be at increased risk of infection include smokers and patients with cancer, chronic respiratory disease, kidney disease or any immunosuppressed condition.

The purpose of a Legionella control program is to minimize the presence of Legionella bacteria and other environmentally associated bacteria in building waterside systems and consequently reduce the potential for illnesses associated with these organisms. The mechanism to achieve the above is to limit the ecological conditions (temperature range and nutrients) and physical plant (design) operations and maintenance issues that allow the Legionella bacteria to grow and amplify. However, note that complete elimination of Legionella bacteria in building water systems may not be possible. As such, instituting preventive maintenance procedures is a critical aspect of Legionella bacteria control. A well-designed control program includes the following information and procedures.

  • Source Identification – Review design, operations and maintenance of waterside systems (e.g., hot water tanks, cooling towers, HVAC systems, humidifiers,  piping networks, process water and distribution systems) for source identification and to perform a risk assessment to determine the likelihood that the system harbors Legionella bacteria and the potential for exposure to aerosolized water droplets or mist.

  • Preventive Maintenance - Develop site-specific guidelines for preventive maintenance procedures for each of the waterside systems for cleaning and maintenance of environmental conditions, such as temperature ranges and water treatments, to reduce the potential for amplification of Legionella bacteria.

  • Sampling and Analytical Procedures, and Data Interpretation - Determine the best practices for water sampling, including location, frequency of sampling and data interpretation, in relation to preventive maintenance and risk assessment.

  • Decontamination Guidelines - Develop site-specific guidelines for decontamination of each waterside system, including mechanical cleaning, chemical treatment options and heat pasteurization techniques.

  • Emergency Response Procedures - Identify the appropriate team members from within the facility and outside resources, including facilities/physical plant personnel, safety team, medical workers, experienced industrial hygiene consultant, environmental laboratory technician, chemical treatment vendor and field sample collection team, to efficiently respond to high concentrations of Legionella bacteria in samples or a Legionnaires’ disease outbreak.

For additional information or to request a proposal, please contact Harry M. Neill, CIH, at 610.524.5525, ext. 15, or email.

Hazardous Energy Lockout/Tagout: Fried and Died

The consequences of failing to effectively lock out/tagout equipment can be catastrophic. An extreme example of this occurred at a forging manufacturing facility in Houston, Texas, on December 22, 1996, when eight workers were killed. A crew of ten maintenance workers was performing work on a 40-foot-high pressurized nitrogen tank for a 35-ton forging press. They believed that the pressure had been bled from the tank prior to beginning work. When two-inch bolts were removed from a three-foot-square lid, it blew off, ripping a 40-by-50-foot hole in the factory roof. Five of the workers were blown off of the top of the tank. How could this have been prevented?

The OSHA-proposed penalty was $1,803,500. The citation that OSHA issued had 34 items listed, including:

  • There was a failure to provide appropriate hardware for isolating, securing, or blocking machines or equipment from energy sources.

  • The hazardous energy control procedures (HECP) did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be used for the control of hazardous energy.

  • The employer failed to effectively train each authorized employee.

  • The employer did not conduct a periodic inspection of the energy control procedure at least annually.

Another example that illustrates the need to use of HECPs and effective communication between host employers and contractors occurred at a printing company in Lancaster, Pennsylvania, on December 22, 2002. The contractor was severely burned by a release of steam from a line that he believed had been de-energized. He died from the burns. Both employers were cited, with the printing company paying $55,000 as the host employer and the contractor paying $3,325. OSHA items common to both citations included:

  • Lack of a compliant energy control program

  • Absence of a suitable hazardous energy control procedure

  • Failure to provide appropriate hardware for isolating, securing or blocking machines or equipment from energy sources

  • Failure of the on-site and outside employers to inform each other of their respective lockout or tagout procedures

Failing to protect your employees from an unexpected release of energy can obviously have significant adverse consequences. 1Source Safety and Health, Inc. can help you to properly address this exposure by working with you to develop and implement compliant hazardous energy control programs, develop equipment-specific HECP, and provide training. For additional information or support contact Colin J. Brigham, CIH, CSP, CPE, CPEA, via email or 610-524-5525, xt. 24.

A Process of Continuous Improvement

It has been said that if something can be measured, it can be improved. This principle not only applies to increased quality and performance of products used in our daily lives, but it equally applies to everyday business practices. Yes, including safety and health programs. Fact is, most safety and health programs do not reach their full potential for one of many reasons, one of which is failure to implement a successful continuous improvement process. The basic framework for implementing a continuous improvement process for safety and health programs is depicted in the following model.

As shown in the model, gaining management support is one of the keys to the success of the process. Management support can be achieved only if you can provide convincing factual data regarding the benefits, i.e., the return on investment that the process will provide. Obtaining factual data requires detailing all the issues by conducting a GAP analysis. This may take time and outside resources to understand the intricacies of safety and health, BUT it really is at the crux of success. Remember, you need to correctly identify the issues in order to correct the problems.

Completing the GAP analysis will allow you to establish measurable goals and to develop very specific action plans that are critical to success. Action plans should be very short statements of what needs to be done, by whom and by when and with what results.  It is important to point out that at this point the process is going to get more difficult, because it will require more commitment, more knowledge, more experience, more cooperation and involvement from more and more individuals.

As you begin to implement the action plans, you also need to begin the process of monitoring progress by collecting data. Remember that monitoring progress requires the use of objective measurable data which will identify how the process is progressing. This information will then allow you to modify the goals and actions plans as needed and provide reports back to management demonstrating the success of the safety and health program. Remember, management will commit its resources only if there is a clear path to success.

For additional information or to discuss how a continuous improvement program can increase the performance of your safety and health program, please contact Chris Schneider, CIH, President at 610.524.5525 ext 14, or via email.