The following EPA Radon Worker Health and Safety guidelines are in accordance with Occupational Safety and Health Administration (OSHA) regulations. According to EPA, Office of Air and Radiation (6604-J) EPA 402-R-93-078, contractors shall comply with all OSHA, state and local standards or regulations relating to worker safety and occupational radon exposure.
In addition to the OSHA and NIOSH standards, the following requirements that are specifically or uniquely applicable for the safety and protection of radon mitigation workers shall be met:
- The contractor shall advise workers of the hazards of exposure to radon and the need to apply protective measures when working in areas of elevated radon concentrations.
- All electrical equipment used during radon mitigation projects shall be properly grounded. Circuits used as a power source should be protected by Ground-fault Circuit Interrupters (GFCI).
- The contractor shall have a worker protection plan on file that is available to all employees and is approved by any state or local regulating agencies that require such a plan. Exception: A worker protection plan is not required for a contractor who is a sole proprietor unless required by state or local regulations.
- The contractor shall ensure that appropriate safety equipment such as hard hats, face shields, ear plugs, steel-toe boots and protective gloves are available on the job site during cutting, drilling, grinding, polishing, demolishing or other activity associated with radon mitigation projects.
- When work is required at elevations above the ground or floor, the contractor shall ensure that ladders or scaffolding are safely installed and operated.
- Work areas shall be ventilated to reduce worker exposure to radon decay products, dust, or other airborne pollutants. In work areas where ventilation is impractical or where ventilation cannot reduce radon levels to less than 0.3 WL (based on a short term diagnostic test, e.g., grab sample), the contractor shall ensure that respiratory protection conforms with the requirements in the NIOSH Guide to Industrial Respiratory Protection. (See paragraph 8.14.) (Note: If unable to make working level measurements, a radon level of 30 pCi/L shall be used.)
- Respirators protect the user in two basic ways. The first is by the removal of contaminants from the air. Respirators of this type include particulate respirators, which filter out airborne particles; and “gas masks” which filter out chemicals and gases. Other respirators protect by supplying clean respirable air from another source. Respirators that fall into this category include airline respirators, which use compressed air from a remote source; and self-contained breathing apparatus (SCBA), which include their own air supply.
- Respirators should only be used when engineering control systems are not feasible. Engineering control systems, such as adequate ventilation or scrubbing of contaminants are the preferred control methods for reducing worker exposures.
- NIOSH issues recommendations for respirator use. Industrial type approvals are in accordance to the NIOSH federal respiratory regulations 42 CFR Part 84. Development of respirator standards are in concert with various partners from government and industry.
- Where combustible materials exist in the specific area of the building where radon mitigation work is to be conducted and the contractor is creating any temperatures high enough to induce a flame, the contractor shall ensure that fire extinguishers suitable for type A, B, and C fires are available in the immediate work area.
- Pending development of an approved personal radon exposure device and a protocol for its use, contractors shall record employee exposure to radon at each work site, based on:
- The highest pre-mitigation indoor radon or working level measurement available, and
- In any planned work area where it is suspected that friable asbestos may exist and be disturbed, radon mitigation work shall not be conducted until a determination is made by a properly trained or accredited person that such work will be undertaken in a manner which complies with applicable asbestos regulations.
- When mitigation work requires the use of sealants, adhesives, paints, or other substances that may be hazardous to health, contractors shall provide employees with the applicable Material Safety Data Sheets (MSDS) and explain the required safety procedures.
- The time employees are exposed (without respirator protection) at that level (See paragraph 12.2.6.)
- (Note: This approach is not intended to preclude the alternative use of on-site radon or radon decay product measurements to determine exact exposure.)