4.4 Additional Safety Hazards: Ladders, Confined Spaces, Fire & Explosion, and Non-Asbestos Air Contaminants

4.4 Additional Safety Hazards Beyond Asbestos

Quick Answer: "Additional safety hazards" is its own content area on the New Jersey exams: about 10% of the worker exam and 7% of the supervisor exam. Beyond electrical, heat, and scaffold hazards (Section 4.3), expect questions on ladders (extend 3 feet above the landing, 1:4 angle, no standing on the top step), confined spaces (19.5%-23.5% oxygen; flammable gas below 10% of the lower flammable limit), fire and explosion (flame-resistant poly, solvent control, fire extinguishers, hot-work controls), and non-asbestos air contaminants (carbon monoxide from engines, solvent vapors, lead, silica, mold, and animal droppings).

Why These Hazards Are Tested

The federal Model Accreditation Plan requires every worker and supervisor course to teach "hazards encountered during abatement activities and how to deal with them, including electrical hazards, heat stress, air contaminants other than asbestos, fire and explosion hazards, scaffold and ladder hazards, slips, trips, and falls, and confined spaces." New Jersey's rule adds "additional safety hazards" as a required topic (N.J.A.C. 12:120-6.6). Containment makes every hazard worse. Visibility is reduced, floors are wet plastic, workers wear respirators and suits, and exits pass through airlocks.

Ladders (29 CFR 1926.1053)

Abatement tip: Ladder feet slide easily on wet polyethylene. Set a ladder on poly only after securing the base or laying a non-slip mat.

Confined Spaces (29 CFR 1926 Subpart AA)

Crawl spaces, pipe tunnels, tanks, boilers, vaults, and chases often contain TSI. A confined space is large enough to enter, has limited entry or exit, and is not designed for continuous occupancy. A permit-required confined space also has, or could have, a hazardous atmosphere, an engulfment hazard, an inwardly converging or sloped layout that could trap someone, or another serious hazard.

Key controls:

1. A competent person identifies confined spaces before work begins.
2. Test the atmosphere before entry, in this order: oxygen, then flammable gases, then toxic gases. Monitor continuously as needed.
   • Acceptable oxygen: 19.5% to 23.5%.
   • Flammable gas or vapor: below 10% of the lower flammable limit (LFL).
   • Toxic contaminants: below exposure limits.
3. Ventilate the space. Remember that HEPA negative-air machines control fibers but do not supply oxygen or remove gases.
4. Use an entry permit, an attendant stationed outside, a trained entrant, and an entry supervisor. Rescue arrangements must be in place before entry.
5. Air-purifying respirators do not provide oxygen. Oxygen-deficient or IDLH atmospheres require supplied-air or SCBA protection (Section 4.1).

New Jersey's subcode lists tunnels, crawl spaces, and live steam lines among conditions that require special precautions written into plans and specifications approved by the ASCM (N.J.A.C. 5:23-8.15(i)).

Fire and Explosion Hazards

Sources of fire and explosion risk on abatement jobs:

• Polyethylene sheeting is combustible. In buildings required to be of noncombustible construction, New Jersey requires separation-barrier materials to meet the building subcode and all plastics to be flame-resistant (N.J.A.C. 5:23-8.15(e)4). The subcode defines flame-resistant poly as nominal 6-mil film meeting NFPA 701.
• Solvent-based mastic removers, adhesives, and encapsulants can give off flammable vapors. Use low-flammability products where possible, ventilate, and eliminate ignition sources.
• Hot work (cutting or welding pipe after abatement) can ignite poly and debris. Use hot-work permits, fire watches, and cleared areas.
• Blocked exits: Containment must not eliminate egress. New Jersey requires that separation barriers not block required means of egress and that fire evacuation routes be maintained for building occupants (N.J.A.C. 5:23-8.15(f)4 and 8.19(c)1).
• Temporary electrical overloads from extension cords, heaters, and lighting can start fires. Use GFCI-protected, properly rated equipment (Section 4.3).

Keep fire extinguishers of the correct type accessible, mark emergency exits inside containment, and train workers to cut through poly to escape during a fire. Life safety overrides containment.

Air Contaminants Other Than Asbestos

Noise, Lighting, and Slips

• Noise: Negative-air machines, HEPA vacuums, and generators can create high noise levels. Use hearing protection when exposures warrant it.
• Lighting: Containment blocks daylight. New Jersey requires the contractor to have sufficient temporary lighting protected by GFCIs for the AST and inspectors (N.J.A.C. 5:23-8.15(b)8).
• Slips, trips, and falls: Wet poly, hoses, cords, and debris cause frequent injuries. Keep walkways clear, pick up debris promptly (which also meets the wet clean-up rules), and wear slip-resistant boots.

Emergency Procedures New Jersey Requires

On subcode projects, the contractor must post written emergency procedures in each work area covering (N.J.A.C. 5:23-8.15(d)5):

1. Medical emergencies
2. Fire evacuation
3. Temporary loss of electrical power or water
4. Repair and clean-up after a temporary breach of containment barriers

At the pre-commencement inspection, the AST also checks that an emergency telephone list is posted. It must include the ASCM, fire, police, emergency squad, local hospital, health officer, NJDOL, NJDOH, and DCA (N.J.A.C. 5:23-8.7(a)2).

Exam Traps

• A HEPA negative-air machine is not ventilation for oxygen or gases. It filters particles only.
• Stepladder top step: Never use it as a step.
• Air-purifying respirators in low oxygen: Never. Use supplied air.
• Carbon monoxide inside containment: Gasoline-powered equipment does not belong inside containment or near air intakes.

Scenario

A crew is abating pipe insulation in a crawl space beneath a municipal building. The supervisor places a gasoline generator just outside the crawl-space opening to power lights and a HEPA vacuum. An hour later a worker develops a headache and dizziness.

Analysis: The symptoms suggest carbon monoxide drawn into the space. The supervisor should:

1. Stop work and remove the workers to fresh air.
2. Call for medical help.
3. Move the generator well away from any opening or air intake, or switch to electric power.
4. Test the atmosphere (oxygen, flammability, CO) before re-entry.

Because the crawl space may be a permit-required confined space, entry procedures, an attendant, and rescue arrangements must also be in place.