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Ellis Environmental Management Inc.

Ⓒ 2021. The following articles are here for you to stay up to date on recent projects by Ellis Environmental Inc as well as news and information related to our services.

Airborne Dust - Types & Hazards

We do many projects that relate to the measurement and improvement of indoor air quality. As a result, we receive many questions, some of which we hope to answer here regarding Ultra-Fine Particles (UFPs), types, acceptable amounts, and how you can protect your indoor air quality. If you have a question, please contact us.

Dust, of course, is a part of our daily lives.  But understanding the relative hazards of various TYPES of dust is an important part of managing the risks associated with each.  Read on.

  1. Particulate matter (PM) contains microscopic solids or liquid droplets that are so small that they can be inhaled and cause serious health problems. Some particles less than 10 micrometers in diameter can get deep into your lungs and some may even get into your bloodstream. Of these, particles less than 2.5 micrometers in diameter, also known as fine particles or PM2.5, pose the greatest risk to health. Fine particles are also the main cause of reduced visibility (haze) in parts of the United States, including many of our treasured national parks and wilderness areas.
  2. PM 10.  Nuisance dust and pollens.  These include dust particles smaller than (<) 10 microns.  Prevalent in construction dust.  Not as hazardous as PM 2.5 (see below), but should be kept below 60 ug/m3 if possible.  Like a nesting doll, PM 10 actually includes PM 2.5 particles. 
  3. PM 2.5.  Also known as “respirable dust” since it can be drawn more deeply into the lungs and is thus more dangerous.  <2.5 microns. 
  4. Ultra-Fine Particles (UFPs)  UFPs are those particles measuring less than 0.1 microns in diameter.  In any given sample of air, UFPs constitute the greatest number of particles, yet make up only a small fraction of the mass.  IAQ investigations in thousands of buildings have already shown UFPs to be directly related to complaints.  UFPs are usually products of combustion or chemical reactions.  Engine exhaust, laser printers, and leaf blowers are possibly the 3 primary generators of UFPs. 

Generally, we’ve found the following average UFP concentrations in sampled environments – expressed in particles per cubic centimeter, or p/cc.  (Results must be considered anecdotal until additional data can be processed.)

  • Open countryside, clear skies, no fires:  500 -600 p/cc
  • Urban office environments with a well-maintained HVAC system: 800 – 2000 p/cc
  • Urban intersections with high vehicular traffic:  15,000 -26,000 p/cc
  • Outside beneath jet aircraft landing paths:  7500 (median) to 55,000 (maximum)  p/cc.
  • 10 to 20 yards from a commercial leaf blower during and shortly after use near a university parking lot::  30,000 to 50,000 p/cc.

Summary:  A well-maintained, roof-mounted heating, ventilation, and air conditioning (HVAC) system, in which filters are periodically and regularly replaced, is generally effective in maintaining indoor UFPs at acceptable levels, even in urban environments.  Based on data gathered so far, we believe the use of motorized leaf blowers should be greatly reduced or eliminated where possible. 

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The South Coast Air Quality Management District (SCAQMD) Evolution

SCAQMD. The South Coast Air Quality Management District (SCAQMD) continues to evolve. Here are a few new asbestos-related developments or rules that have been promulgated or clarified by the Agency in the past few years:

  1. The agency has abandoned AHERA sampling protocol and now requires a minimum 3 samples collected from each unique material, regardless of quantity and type.
  2. Concrete - floors, loading docks, stairwells, etc. - must be sampled prior to any disturbance. 3 samples required, but chipping a piece from the surface (instead of coring with a powered coring bit) is acceptable.
  3. The agency now requires a "discussion" of asbestos in asphalt, whenever it must be removed prior to removal. This came up when a roadway had to be removed to access asbestos - cement pipe. We take that to mean that sampling of asphalt is now required.
  4. In some cases, asbestos – cement pipe must be saw cut to facilitate new fittings.  SCAQMD now requires a full enclosure (tent) and HEPA air filtration for this effort. 
  5. We continually speak to and correspond with this agency on compliance issues and will happily share copies of those exchanges if requested. 

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Ellis offers surface and air SARS-CoV-2 (coronavirus) testing

SERVICES OFFERED.  Ellis offers SARS-CoV-2 (coronavirus) testing by way of:

  • Indoor air testing using a low flow sampling pump with PTFE filters (37 mm cassette)
  • Surface testing at common horizontal touch points using “PurBlu” specialty swabs.

SARS-CoV-2 transmission can occur by an infected individual’s droplets (> 5um in diameter, travel up to 1 meter) or by droplet nuclei (<5 um in diameter, travel greater than 1 meter).

Droplets (>5um) can occur by coughing, sneezing or talking (close contact-settle quickly).

Aerosol (<5um) can occur by breathing, talking, sneezing (stay in air longer – travel further).

Common means of transmission of SARS-CoV-2 are in enclosed spaces, prolonged exposure and in places of inadequate ventilation.

Air testing for (SARS-CoV-2)

  • Using a low flow sampling pump with PTFE filters (37 mm cassette)
  • Flow rate of 3-5 LPM to achieve >1,000 liters (3-4K preferred)
  • Turnaround time 2-day standard/24-hr rush
  • Samples are analyzed by Method RT-qPCR
  • Samples are shipped to certified labs in Los Angeles and New Jersey.

 

Call Today: (310) 544-1837 for more information.

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Evidence-Based Facility Disinfecting Services

Ellis Environmental Provides a "Scientifically Proven" Clean

Before you open up your facility after the quarantine, it needs to be clean, not just cleaned. With the level of uncertainty around the novel coronavirus, you cannot afford anything less than evidence-based clean; a level of clean expertly administered, monitored, and scientifically cleared by Ellis Environmental.

Ellis has partnered with a local AIHA accredited testing laboratory and several reputable abatement contractors to assist our clients in providing their occupants with something that we are all searching for: evidence. Evidence-based in accredited testing laboratory data and approved surface biological agent sampling protocol (qPCR swab testing).

Why is that important, and what does that really mean?

If and when you choose to reach out to Ellis for assistance in disinfecting your facility, the following steps take place:

  1. You’ll speak with trained and knowledgeable personnel who will gather specific facility information about your unique situation (square footage of occupied spaces, hours of occupancy, the last time a potentially infected person was in the space, etc.).
  2. Ellis will then provide their proven, general disinfecting work plan to several reputable abatement contractors with disinfection experience, and we will set-up a bid walk (if applicable).
  3. Following a site walk or extensive discussion about facility specifics, Ellis will review bids for accuracy and assist our clients in awarding the work.
  4. Ellis will then provide full-time 3rd party oversight and monitoring during the licensed abatement contractor’s cleaning efforts – observing, directing, and documenting cleaning activities as they occur.
  5. Lastly, and following disinfecting efforts, Ellis will collect surface swab samples according to the existing sampling protocol as a surrogate for specific biological or viral surface contaminants. A report documenting all cleaning activities, as well as the results of surface sampling, is then provided to our clients as part of the closeout process.

In rush situations, Ellis has been able to provide the above services – from initial client contact, to release of our closure report – in as little as 72 hours.

At last – a document you can have “in hand” when approached by concerned occupants returning to your facility. Evidence.

If you want to be CERTAIN your facility is disinfected properly, call Ellis Environmental.

Call Today: (310) 544-1837 for more information.

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Ellis Successfully Administers Disinfecting Efforts for Two Local Credit Union Branches Following a Positive Employee Test for COVID-19

Ellis has just completed a successful administration of its second decontamination/disinfecting project in an occupied office (bank) environment. In both of these cases, the branches were both temporarily closed following an employee testing positive for COVID-19.

In the interest of health and safety, both clients elected to pursue an active branch cleaning effort – one that would provide their occupants with scientific documentation that facility disinfection was monitored and performed by licensed professionals.

An abatement contractor was retained to do a Level III COVID-19 Cleaning (Confirmed Exposure) which includes:

  • Cleaning of “touchpoints” throughout the designated areas. Touch points are those areas where building occupants commonly place their hands; i.e. door knobs/handles, door push plates, chairs, rails, elevator rails/operating panels, vending machine buttons, telephones, keyboards and mouse, desks, countertops, trash bins, drawers, pen holders, light switches, printers, computer buttons,  kitchen and break room tables, restroom facilities, flush handles, soap dispensers, faucet controls, paper towel dispensers, toilet seats, etc.
  • An approved disinfectant, Decon 30, was applied to all “touch points” in the designated cleaning areas. The manufacture recommended “dwell time” of 10 minutes was used prior to the wiping of the surfaces. After the appropriate dwell time, disposable cloths were used to wipe the surfaces. Each cloth was used only once and placed in biohazard bags for appropriated disposal.
  • Non-porous floors were cleaned using Decon 30 and wiped down with cloths. The carpet was disinfected and HEPA vacuumed.
  • Furniture and upholstery were treated with Decon 30 and wiped down with a cloth.
  • All paper products (toilet paper, business cards, paper towels, deposit envelopes, ETC) were removed from the designated areas and disposed of as biohazard waste.
  • A mobile Ultra-violet light (Spectra 1000 UV Disinfection System) was used to treat each location for a period of 10 minutes.
  • At the completion of the disinfecting efforts, Ellis collected swab samples from cleaned “touch points” and submitted samples to an AIHA accredited laboratory in Denver, CO. Post-abatement swab samples were collected and analyzed for bacterial/ fungal agents as surrogates to measure the effectiveness of the cleaning and disinfecting protocol.

Ellis monitored and directed each step of the disinfection efforts, and provided surface testing upon project completion. Each client received an Ellis generated monitoring report, which included photo documentation, and tabulated laboratory results from an AIHA accredited laboratory.

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Coronavirus - Is Disinfection Even Necessary?

COVID-19 Virus. My company (ten employees) provides, among other things, surface testing for known contaminants. As most of you know, there is no published protocol for the collection or analysis of the Coronavirus in an office environment. Instead, we're suggesting the collection of surface swabs from the representative desk and countertops AFTER administering and monitoring an abatement contractor's disinfection effort, performed according to a cleaning protocol that my company had prepared. Results of the post-cleaning surface tests will be expressed either as "bacteria positive" or "negative."

We were ready to start administering just such a cleanup at a bank branch in the San Fernando Valley after a worker was diagnosed "positive" for the virus and was sent home. The cleanup effort was intended to reduce or eliminate bacteriological contaminants as photographed and documented by our firm.

Initially, the insurance carrier denied the claim. They stated, in effect, that the coronavirus only survives on surfaces for a very short time, so leaving the bank vacant for 5 days, followed by normal cleaning, should be sufficient.

Perhaps. But that approach would not necessarily produce confidence among the office workers, who are reluctant to return without some sort of independent 3rd party testing.
We agreed, arguing that results of surface testing from a certified lab would provide documentation - i.e. proof - that the contractor's disinfection efforts had been effective. We stand by that recommendation.

In the end, the  bank agreed; We began the cleaning project today, April 3rd, and will see it through to the end. A good call, and we'll begin our second bank cleaning effort on Monday.

-Duane Behrens, President
Ellis Environmental Mgmt., Inc

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COVID-19 Work Plan: Reduction of surface bacteria in office and other work environments

To our valued clients,

Our current global climate has created an unprecedented atmosphere - one that is full of questions and concerns. Ellis has been approached by numerous clients searching for professional direction on cleaning and disinfecting their facilities. While there is no CDC or CDPH-approved clearance sampling protocol for testing following decontamination of surfaces impacted by the COVID-19 virus, the attached work plan has been effective in reducing overall surface bacteria and biological contaminants.  We offer it here for your use without charge or warranty.  

This method IS labor-intensive and intended for use by an experienced abatement contractor with a trained crew.  Its success will depend on constant professional oversight and direction by a 3rd party consultant to ensure the labor is performed thoroughly, carefully, and as designed. 

Best regards,

Ellis Professional Staff 


Note: If you need professional assistance to disinfect your facility, please contact us to discuss the details of your specific situation to receive a project quote.

Call: 310-544-1837

Email Us


General Work Plan

Reducing Non-Specific Biological Surface Contaminants

 

BACKGROUND

Description of Hazard: Office spaces have the potential to house a large number of potential biological surface contaminants. Cluttered desk areas, food, and the hygiene of occupants all contribute to this potential. While general housekeeping operations help to reduce this potential, a more thorough disinfecting process, performed by a licensed cleaning contractor and combined with constant professional guidance and inspections, can further reduce the presence of surface contaminants and biological hazards.  

Type of Hazard: Recognized biohazard; possible bacterial or viral infection, particularly in immunocompromised individuals.

Modes of Transmission: Potential physical contact with contaminated persons and/or surfaces; particularly where persons touch contaminated surfaces and touch their eyes, nose, or mouth.

Routes of Entry: Entry may occur with contact with mucous membranes (eyes, nose, and mouth).

 

HAZARD CONTROL - SUMMARY 

Workplace activities involving infectious or biological agents require containment so that workers, the immediate work environment, and the community including those outside the immediate workplace are protected or shielded from exposure.

This is achieved through (1) engineering controls, (2) good work practices, (3) appropriate safety equipment, and (4) constant monitoring, guidance and inspection by an independent 3rd-party industrial hygiene firm

 

ENGINEERING CONTROLS

The following engineering controls, when combined with proper worker training and work methods, will help ensure that any potential biological hazards are contained within the work area.

  1. Establish a regulated area with signs and barrier tape.  Signs shall conform to CDC/NIH guidelines (Biosafety Level 2).
  2. Seal all penetrations into the work area with two layers of 6-mil poly sheeting and tape (“critical barriers”). 
  3. Ensure that the HVAC system is either (a) shut down or (b) isolated by installing 2 layers of poly sheeting at all supply and return vents.
  4. Install sufficient HEPA negative air filtration at one end of the work area to ensure a constant and visible flow of air into the work area.  Place exhaust points facing upward and 10 feet above the nearest ground surface. 
  5. Install a 3-stage wash station (Decon Unit) at the entrance to the work area.  Maintain an adequate supply of disinfectant soap and warm water inside the decon unit.  Ensure that all workers are completely clean and disinfect hair, face, and other exposed skin prior to exiting the work area.
  6. If space is available, install a separate wash station and waste decon unit.   This unit will be a single large chamber suitable for cleaning exterior surfaces of packaged waste prior to removal. Maintain a clean wash down area in front of this waste decon unit.  Have disposable layers of 6 mil poly, mops, rags and disinfectant solution at hand.
  7. Prior to actual work start, request an independent inspection of engineering controls by the IH monitor. 

 

PERSONAL PROTECTION

The following personal protective equipment (PPE), when combined with proper worker training, supervision and 3rd party guidance, will help to maintain a safe working environment for employees performing initial cleaning activities.

  1. Respirators.  Full-face (recommended) or ½ face APR with eye protection (mandatory).  Organic/HEPA filters. 
  2. Clothing.  Tyvek or similar non-permeable, non-breathing protective coveralls.  Ensure that workers remove all street clothing prior to donning the protective suit.
  3. Headwear.  Cover all hair with a disposable, non-vented shower cap or similar.  Do not allow exposed hair inside the work area.
  4. Eye protection.  In lieu of a full-faced APR, goggles shall be required inside the work area at all times. Thoroughly clean and disinfect eyewear as part of the decontamination process.
  5. Footwear. Calf length, standard black irrigation boots with outer impermeable lining. Thoroughly clean and disinfect eyewear as part of the decontamination process.
  6. Hand protection.  4-mil (min.) disposable “gauntlet”-type poly gloves, taped and sealed to Tyvek suit at the forearm.
  7. All workers shall immediately report any breaches to PPE (or any potential exposures) to their foreman or supervisor/competent person.
  8. Workers must be trained on the hazards of the chemical agents used in the cleaning/disinfection process in accordance with OSHA’s Hazard Communication standard (29 CFR 1910.1200)
  9. All persons performing cleaning activities, and their employers, must comply with OSHA’s standards on Bloodborne Pathogens (29 CFR 1910.1030) including disposal of regulated waste, and PPE (29 CFR 1910.132)

 

TOOLS AND EQUIPMENT

  1. Airless mister is capable of 2,000 psi at point of release.
  2. Sufficient disposable mop heads. 
  3. Sufficient disposable cloth rags.
  4. Cutting tools. Provide initial safety training in the use of sharp equipment.  Decontaminate all cutting tools at the end of the project.
  5. Prepare a solution of 1 part 3-5% chlorine bleach and 1 part low suds, anti-bacterial detergent mixed with 4 parts water.  Test initial concentration of bleach/detergent as the project progresses. Reduce the amount of bleach if complaints of irritated eyes or skin persist. DO NOT mix bleach with ammonia or any other cleanser.
  6. If bleach is not appropriate for some surfaces, disinfecting agents with EPA-approved emerging viral pathogen claims may be used with prior approval.
  7. 4 mil-poly sheeting and tape for double-wrapping, packaging, and disposal of contaminated items.  6-mil poly bags may be used to contain smaller items.

 

WORK METHODS

  1. Provide an enclosed area adjacent to the decontamination unit for workers to remove street clothing and don personal protective equipment.
  2. All workers shall enter and exit the work area through a single decontamination unit, located as far as possible from public access.
  3. For visibly dirty surfaces, perform initial cleaning activities prior to further disinfecting surfaces. Cleaning should be performed using approved detergents and chemical agents listed in the “Tools and Equipment” section of this document.
  4. Immediately transfer used cleaning rags/mops/towels to 6-mil poly waste bags. “Goose necking” and sealing bags with standard duct tape prior to moving waste to the wash down location in front of the waste decon unit.
  5. Wash down the station.  Spray wrapped/bagged materials and other items with bleach/disinfectant solution. Prior to removing from the work area, wrap waste again in another new 6-mil poly waste bag.  Tape all seams with standard duct tape.  Move the wrapped waste into the decon chamber.  Immediately mop or wipe down the floor of the wash down station, and/or replace temporary floor sheeting as required. Keep this area clean at all times.
  6. Inside the waste decon chamber, 2 workers will wipe down containerized waste with clean rags that have been dampened (but not soaked) in bleach/disinfectant solution. Bag soiled rags as they accumulate.  Dispose of these materials along with other rags/mops/towels used in the cleaning and disinfecting process.
  7. Move containerized waste out of the decon unit and immediately transport the waste to a designated container.
  8. If clothing or other similar items are identified in the work area, gently gather and place in 6-mil poly waste bags labeled with a “launder” or similar label. Do not shake these items prior to containerization. Launder according to manufacturer instructions on the warmest appropriate water settings for the items; dry completely. 

 

WORKER DECONTAMINATION

Perform the following under the constant supervision of an independent 3rd party IH

  1. Maintain a clean wash down station next to the inner (3rd) chamber of the decon unit. It is here that workers will first clean and remove their protective rubber boots.  Step into the 3rd (inner) decon chamber.
  2. Remove Tyvek suit, gloves and other PPE inside the 3rd chamber.  After removal, roll up each article of clothing so that any soiled surfaces are to the center.  Place removed garments in a 6 mil poly waste bag adjacent to the inner chamber. Dispose of soiled PPE along with the containerized waste.
  3. Still wearing a respirator, move to the 2nd (middle) chamber.  Clean all body surfaces (including hair) and respirator surfaces with antibacterial soap and warm water.  Take the extra time to clean any skin that may have been accidentally exposed while in the work area.
  4. Move to the first (outer) chamber.  Remove and re-clean respirator thoroughly.  Dry body and hair thoroughly with disposable towels.  Place wet towels in 6 mil bags for disposal with containerized waste.
  5. Move into the outer changing area and don street clothes.

 

WASTE DISPOSAL

  1. Maintain a dumpster adjacent to the work area and as close as possible to the waste decon unit.
  2. Ensure that all waste is completely wrapped and decontaminated prior to transport through the building, as outside workers will not be wearing personal protective equipment.
  3. Keep the dumpster locked whenever it is not in use.
  4. Coordinate transport and disposal to approved landfill (if necessary) with EH&S and Facilities Department.  If the material will be disposed of as normal construction waste, ensure that the landfill is informed of the nature of the waste. 

 

RE-ESTABLISHMENT OF THE WORK AREA

  1. Prior to removing engineering controls, wipe down all remaining surfaces (walls, floors and other permanent items) with bleach/disinfectant solution.  Dry with clean rags.
  2. Call for inspection by the 3rd – party IH.
  3. Maintain and operate the negative filtration system for a minimum of 24 hours following completion of cleaning operations but before removing critical barriers and returning the HVAC system to normal service.
  4. During this 24 hour period, the Owner’s representative will perform surface sampling inside the work area with a swab sampling kit.  Samples will be analyzed for general biological contaminants/bacteria (present or absent).
  5. Disconnect and remove negative filtration units at the end of 24 hour settling period.  Maintain critical barriers in place until results from clearance sampling have been received, usually 1 to 2 days. 
  6. Following a final inspection by the 3rd party IH, remove remaining critical barriers and signs.  Make a final inspection of the work area for damage and or remaining soiled items.

The listed procedures may be used in conjunction with a variety of broadcast, disinfectant delivery systems, including airless misters, UV light or other approved method. Contractor to submit for approval prior to application.  Include information on products used, mixing ratios and delivery methods (e.g. airless mister).  Broadcast application of disinfectants shall be employed as secondary to primary, wipe down efforts of horizontal surfaces.”


Note: If you need professional assistance to disinfect your facility, please contact us to discuss the details of your specific situation to receive a project quote.

Call: 310-544-1837

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Ellis is strong thanks to you!

We were on a roll . . . increasing, record revenue for the past 4 years running, 10 employees, the latest in testing equipment, and 3 or 4 company trucks depending on who you ask.  (Thank you, Mike Motors.) 

I was feeling down over the weekend because, after 3.5 years with no changes in personnel, a key industrial hygienist resigned last week.  It made for a rough weekend of quiet thought and second-guessing myself. 

But you know what?  This morning at 05:30, I met 3 employees at the office and helped them get their assigned vehicles loaded up for a day of monitoring and inspections at various locations in LA County. 

Finished, I stood there in the parking lot, smiled and quietly waved at each as they left the parking lot.  They probably found that a bit weird.  But I needed to remind myself of all the GOOD things that have come from our little company. . . . that these good people continue to rely on Ellis almost as much as we rely on them. 

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Sampling Concrete for Asbestos

For years, concrete floors, walls and footings were not considered to be “suspect asbestos-containing materials.”  Concrete was often not even sampled during a standard asbestos survey.  Some time ago, the SCAQMD confirmed that concrete was indeed a “suspect material,”  so we began collecting surface samples from accessible concrete walls and floors, using a cold chisel and a hammer. 

During a recent refresher training session in Anaheim, an instructor noted that concrete in the middle of a wall or floor may be different than concrete on the surface.  He (or someone) suggested coring through each slab or wall to get a better representation of the material.  We performed a few of these cores, but I didn’t like it.  It seemed overly burdensome and expensive for the client.  l  So I wrote directly to the SCAQMD, requesting clarification.  My letter and their response are shown below:


From: Duane Behrens [mailto:This email address is being protected from spambots. You need JavaScript enabled to view it.]
Sent: Tuesday, June 18, 2019 1:23 PM
To: Christopher Ravenstein <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Cc: Ellis Professional Staff <This email address is being protected from spambots. You need JavaScript enabled to view it.>
Subject:  Sampling Concrete

Hi, Chris.  Our understanding of Rule 1403 indicates that concrete is indeed a suspect ACM.  In the past, we’ve used a cold chisel and hammer to knock off a chip from the concrete’s surface.  Ryan in our office correctly notes that this procedure may only capture the top, non-aggregate portion (“cream”) of the concrete.  So we’ve taken to coring concrete walls and floors to get samples that are more representative of the material. 

Retaining and scheduling a coring contractor is, of course, quite a bit more expensive and time-consuming than just chipping off a piece from the surface with a cold chisel.  So I’d really appreciate your input on the subject.  Is coring truly necessary? Or would you accept results from surface samples collected the old way (hammer and cold chisel)?  Let me know.  Thank you.  

ELLIS ENVIRONMENTAL MGMT INC
Duane Ellis Behrens, President   
CAC #92-0226     CDPH #7914

------------------------------------------------------------------------

SCAQMD RESPONDS:

Good Afternoon Duane,

I’ve discussed this with supervisors in Toxics. While we refer to materials as “homogeneous”, we are cognizant of the fact that those materials that are mixed and applied onsite aren’t ALWAYS uniform in their makeup throughout. For instance, stucco. Stucco sample results can vary widely. Another example is acoustic ceiling material. Results from acoustic sampling can vary significantly.

While it may be true that the concentration of asbestos fibers (if any) in the concrete may not be uniformly distributed through the cement matrix, we do not believe that the surface cement, or “cream”, would tend to have a wildly different concentration. There’s really no reason to think that it would, and we haven’t seen any data to suggest that it is.

It is our opinion that a sufficient number of representative surface samples of the concrete are adequate to characterize the material.

Christopher A. Ravenstein
Staff Specialist
South Coast Air Quality Management District

Everyone has the right to breathe clean air

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Ellis Staff & Vehicles - 2019

 

It occurred to me the other day as I walked through the office (and the parking lot, actually) of how much we’ve grown. New vehicles add to our growing fleet, sophisticated new IAQ equipment – all of it helps us respond faster and do better work for you. We believe in re-investing in the business, including investing in our people, maybe most importantly, in our people.

And it occurred to me you are a big part in making this possible. From all of us who come to work every morning wanting to outperform ourselves, thank you for this opportunity to practice a profession we love.

 

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When Water Intrudes

Recent heavy rains in southern California are impacting many buildings. We’re seeing damage to ceiling spaces, wall spaces and floors.  If not addressed quickly, mold growth – and its attendant problems – are likely.

Avoiding mold growth is not difficult

These simple steps are the most efficient way to get your building and work spaces back in service, at a minimum cost, and with the shortest possible delay. Done quickly, mold growth can be avoided altogether.

First, look for telltale signs of water intrusion:

  1. Blistering paint on walls.
  2. Brown or tan water spots on ceiling tiles or ceiling wallboard.
  3. Damp carpet.

If you suspect water intrusion in your space, the following corrective steps must be performed immediately:

  1. Building services: first identify the source of water intrusion.  Inspect the roof and above-ceiling spaces for evidence of standing water, clogged roof drains, etc.
  2. Building services (or roofing contractor): Correct the source of intrusion.  Clear the drains, patch any suspect gaps or tears in existing roofing seals and mastics.
  3. Concurrently with items 4 and 5 above, place dehumidifiers and fans in impacted areas.   Along with the steps listed below, this will accelerate the corrective measures. 
  4. Ellis: Assess the extent of moisture damage.  We use conductive moisture meters and infra-red cameras to do this and will mark out the extent of water-impacted materials.
  5. Ellis: Where wet wallboard is identified, test impacted materials and paint for asbestos and lead.  (Many owners neglect to do this.) 
  6. Ellis:  Where no hazardous materials are identified, cut a few small exploratory holes in the wettest areas.  Have facilities or a general contractor on standby to patch holes.  (Ellis can also arrange this.) 
  7. Is there fiberglass insulation inside those walls?  If there is, the wallboard must be stripped out (removed) along its base, the wet insulation removed, and the interior wall space dried completely.  Ellis can arrange for a contractor to perform this step. 
  8. If there is NO insulation, coring and drying the wall spaces - rather than complete removal – MAY be effective.    Keep the fans and dehumidifiers running during this period.
  9. Once complete, contact Ellis for additional guidance and/or clearance sampling.

The best course: act quickly. The earlier you identify and remove mold, the less expensive the remedy.  Feel free to contact us for answers to your questions, contractor recommendations, etc.

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Ellis Responds to Southern California Woolsey & Hill Fires

In the aftermath of the Southern California Woolsey and Hill Fires, Ellis is providing services at reduced cost to schools, daycare and other facilities with children present. Because of insurance limitations, we cannot respond to requests from private residents or homeowners.

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Iron Mining - and Mesothelioma

Regarding the high number of mesothelioma deaths in northeastern Minnesota (3 to 4 times the national average), the Vermillion and Mesabi mining ranges were among the first big mining ranges famous for their large deposits of iron ore.   In these mining pits, a large amount of taconite was also mined, which contained iron.  Taconite is compared with asbestos because of similarities in chemical makeup.  Taconite products are commonly distributed - not just in the Mesabi and Vermillion ranges – but also around the surrounding Great Lakes Region.  These products have been linked to the increased number of mesothelioma diagnoses in this area.  Unfortunately, mesothelioma can take many years to develop.   So, anyone who worked in the mines or was exposed to products made from these materials is at risk of developing mesothelioma. 

More information can be found at the Mesothelioma Guide:

View Mesothelioma Guide

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Ellis Surpasses $1 Million In Sales

In 2017 and for the third year running, our little company (Ellis Environmental) surpassed $1 million in sales and assets. Not bad for a 9-person effort. During that time and in addition to our core services, we saw a steady rise in the number of indoor air quality investigations performed, representing app. 12% of total revenue in FY2016/17. Many, many thanks to the faithful clients, employees, contractors and vendors who have made this possible.

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Visual Inspections on VFT and Associated Mastic Abatement

I wanted to share some protocols and "tips" I've learned and followed during my years with Ellis performing inspections on vinyl floor tile (VFT) and mastic abatement. Though these jobs are often viewed as fairly straight forward, challenges and obstacles can arise quickly, and owners can often land themselves in some fairly sticky situations as a result. 

Here's how Ellis approaches these inherently complex jobs:

  1. What is the substrate material?

This is critical to the abatement and inspection process for VFT & mastic, and it's something that must be learned long before abatement begins --during bulk sampling. Inspectors and consultants performing building surveys should always make a note and include substrate material in their sampling reports. Because:

Wood Substrate

  • VFT will be removed with hand methods (tile bars or similar), and full containment with a ceiling is not required. Waste is non-friable.
  • Associated underlying mastic will be removed with hand methods (razor scrapers or similar) to a NON-DIMENSIONAL finish. This means that mastic will be scraped "flat",  but will still be present in the porous surface of the wood. Damaging/gouging/splintering the wood substrate to get this residual mastic is not encouraged, rather, following a non-dimensional scrape and passing visual inspection, the contractor will apply a white encapsulant to the surface of the wood.

Concrete Substrate 

  • VFT will likely be removed utilizing tile bars, but mechanical removal methods such as a Terminator may also be used in larger areas. For any SCAQMD notified job ( >100 s.f.), Ellis always encourages mechanical removal methods of mastic with the client and abatement contractor. By doing this, our containments switch to Class 1 (full containment with ceiling), and waste becomes friable, but mechanical methods are best at removing mastic completely.
  • Concrete often contains divots, cracks, "pock" marks in its surface. These areas tend to catch and pool with mastic. Good consultants pay special attention to them during visual inspections. 
  • Clear encapsulant is appropriate following VFT & mastic abatement on concrete substrate.

During bid-walks and pre-starts, substrate material and contractor expectations are ALWAYS discussed and documented in Ellis' bid notes.

  1.  Will Walls Be Demolished Following Flooring Abatement?

Again, this is something that needs to be discussed with a client and a contractor during bid-walks and pre-start meetings. Here is why it's critical:

  1. There's always a chance that a building has been remodeled. Floors may test hot, but newer walls don't, and our clients often choose to have general contractors demo them after flooring abatement takes place. During this demolition, residual flooring left under the bottom plates of walls and not accessed during abatement is often uncovered -- and it's usually uncovered by non-protected personnel who become concerned. That ultimately causes abatement remobilizations, project delays and increased costs for the client, who are often left frustrated.
  2. If walls WILL remain, and it's clear tile extends under the bottom plates of the walls, utility knives or similar blades MUST be used to create a flush and straight line with the bottom of the wall. No exceptions. Jagged edges and "bits" of tile are all grounds for a failed Ellis visual inspection
  1. Using Information Gained In Steps 1 & 2 to Complete a Visual Inspection

If a consultant knows the substrate, and knows if walls will remain or be removed, they are better informed to perform their visual inspections. It can't be overstated how CRITICAL these inspections are. They are the professional stamp of approval on the completeness of the work. With that stamp a consultant represents themselves, their coworkers, and their company. Inspections should be held to a high standard, and consultants performing them should be prideful (regardless of the eye rolls or push backs they may receive from the abatement foreman). Good consultants understand that if a contractor thinks they can get away with doing less, they will. 

On wood: get to a non-dimension finish that is as uniformly flat as possible without destroying the substrate. 

On concrete: make sure all the mastic is GONE. No black should remain (with the sole exception of cracks or tight divots; these areas can still be cleaned with wire brushes to an acceptable finish, but black staining invariably will remain). 

  1. Performing a Post Teardown Inspection Following Passing Air Clearance

Tape used during abatement (especially on criticals: doorways/door sills/etc.) can hide small areas of mastic. Good consultants stay with the contractor during tear down and perform a final walk through. If any mastic remains (quantities should be EXTREMELY minimal, and cleanable with a rag and a small quantity of mastic remover) a consultant will show the foreman and have them address it before exiting the site.

Finally, the relationship between an abatement contractor and a consultant is tricky. It's as symbiotic as any professional working relationship I've ever encountered. Without each other, they are both sunk. Work doesn't get performed without abatement contractors, and work doesn't get approved without consultants. What this means (from the consultant side) is that to be a successful relationship, expectations must be set early. Containments and work areas should be visited by the consultant several times during work, and feedback should be provided to the foreman -- bad AND good feedback. What the consultant is looking for should be established long before the project gets close to completion. Simple things like asking the foreman to show small locations after the worker and foreman have looked at it and consider it "abated". This establishes a finish the contractor can come back to when abating the remainder of the containment and helps move the project along smoothly. 

Just a glimpse into what Ellis puts into every job, even these "simple straight forward" ones.

Ryan C Davidson 
Industrial Hygienist

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A Year In Review

2015/2016 were Ellis’ most successful back-to-back years since the company was formed 22 years ago. Some of our more notable accomplishments:

  • Ellis assisted a large Glendale landowner in assessing possible contaminants at an adjacent property prior to purchase. The project required Ellis to assemble, coordinate and review the efforts of geologists, toxicologists, contractors and developers. In this case, potential cleanup costs were significant, and the buyer made the difficult choice to pass on the purchase.
  • Ellis provided AHERA 3-year, asbestos re-inspections for Palos Verdes, Inglewood and other public school districts. After identifying the asbestos materials (ACMs), Ellis prioritized identified ACMs for removal based on their condition, damage, accessibility and “friability” (ability to become airborne).
  • Ellis assisted a local/regional airport in identifying toxic substances (primarily lead and zinc) released following 3 severe hangar fires. Procured bids for and managed the subsequent hazardous materials cleanup.
  • Ellis provided lead and asbestos surveys, lead surveys, and testing for lead in potable and drinking water for more than a dozen regional charter schools.
  • Provided countless indoor air quality studies, testing for airborne carbon dioxide, ultra-fine particles (UFPs), carbon monoxide, volatile organics, asbestos dust, lead dust, mold, gram-positive cocci, enterococcus and a host of other contaminants.
  • Ellis assisted in responding to more than 100 water intrusion events for various clients. Most of the water intrusions were rainwater, but we also responded to gray water, sewage and water supply line leaks. Ellis is the best first call here; we identify wet wallboard (and other damaged materials) and then manage their timely removal before mold has a chance to grow. For sewage-related spills, clearance enterococcus swabs are collected to insure a complete cleanup.
  • Ellis assisted UCLA Housing, Loyola Marymount University, Mt. St. Mary’s, Santa Monica College, and other regional colleges and universities in procuring bids and managing the removal of moisture-damaged, asbestos-containing and/or lead-containing materials classrooms and housing facilities.

And so on. Our employees are, without exception, degreed chemists or industrial hygienists. Clients seem to appreciate and rely on the confidence, experience and professionalism those employees bring to each project. We’re thankful for each opportunity to do so.

All the best for 2017.

Duane Behrens, President.

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Lead In Drinking Water

leadinwater.jpgEllis is retained by a number of local school districts to test potable (drinking) water for lead content. 

BACKGROUND - Dissolved lead in drinking water is poisonous.  It can lead to nerve and brain damage, particularly in exposed children.  Lead can enter a school's water supply in one of two ways:

  • Through a contaminated municipal water supply (ala Flint, Michigan); or
  • Through deteriorating lead joints in the building's branch, copper supply lines.  As the joints deteriorate, they can release lead directly into the water.  This is of particular concern in older buildings.

CASE HISTORY – So far, results from testing at different schools have been fairly consistent; lead has been identified in a small percentage of water fountains at each school.  So let's use the first school tested as an example:


METHOD – At every site tested, Ellis collects two representative samples from each water fountain ("source point").  From each source point, the two samples are collected as follows:

  • First draw:  as the fountain is operated, the very first water to come out is directed into a 250 ml jar provided by the testing laboratory.
  • Second draw:  the fountain is then operated (flushed) continuously for 30 seconds.  A second sample is then collected and placed in a similar container.
  • At our example site, 44 fountains were sampled, both first and second draw, for a total of 88 samples collected. 
  • Sampling was conducted between 5 and 7 a.m., before the students arrived.
  • Each sample jar came with a lab-provided liquid preservative.
  • All samples were placed in an insulated container, then hand-delivered directly to an accredited laboratory for analysis.

RESULTS – The EPA has published an "action level" for lead of 15 micrograms lead per liter (15 ug/l).  Here is what we found at the example site:

  • Measured concentrations of lead equaled or exceeded the EPA's action level at 7 of the 44 locations tested – approximately 16 percent.
  • One of those was identified at the municipal supply, where water first enters the school grounds.  The exceedance was found only in the first draw, however. If both the first and second draw had indicated high lead, it might  have indicated a potential problem with the municipal supply.  But no.  As with other locations, flushing the line here reduced lead levels significantly, indicating the problem was likely a leaded joint at the supply point, NOT the overall supply source.  
  • At 6 of the 7 locations where elevated levels were identified, they were observed ONLY in the first draw.  In other words and in every case, flushing the line for 30 seconds reduced lead concentrations significantly.
  • At one location only, lead concentrations for BOTH the first and second draw exceeded the EPA's action level.  But even here, lead concentrations were reduced significantly by flushing the line, from 370 ug/l to 16 ug/l.

SUMMARY -  Again, using the above site as an example:

  • Lead, above the EPA's recommended "action level" of 15 ug/l, was detected in approximately 16 percent of the fountains tested.
  • At each location, flushing the lines for 30 seconds greatly reduced lead concentrations, usually to well below 15 ug/l, often to levels reported as "none detected."

Why is lead in drinking water of concern?  Lead is an ingestion hazard, that is, poisoning by swallowing.  Exposure via contact with surface dust or paint chips MAY sometimes be delayed or reduced by infrequent contact and washing of hands (hygiene).  But because drinking water is ingested directly, exposure to lead poisoning is immediate. 


WHAT WE'VE LEARNED

  • Lead is typically found in drinking water only in a small minority of drinking fountains – typically those fountains that are left idle and unused for long periods.  This allows residual lead at pipe joints to collect and stagnate in the line.
  • Unless initial levels are high, simply flushing (operating the fountain) for as little as 30 seconds typically and significantly reduces lead concentrations, usually to below 15 ppb, the EPA action level.
  • Where lead IS observed in water, the fix is usually also quite simple; inspect the small supply line that services the fountain, and replace it with a section of new line and non-leaded joint.

RECOMMENDATIONS -

  • All schools should have their potable water lines periodically tested for lead.
  • Fountains (source points) with elevated lead levels should be closed to public use until the lines can be inspected and repaired with non-lead joints.
  • Water at the entrance to the school property should also be tested to see if the municipal supply itself is contaminated.
  • Regardless of test results, all parents should arrange for medical testing for blood lead levels in their child.  This process is quick, inexpensive, and useful in assessing whether students' health has been impacted. The test can be arranged privately by parents as part of any normal medical exam. 

Call Ellis at 310 544 1837 with questions or to arrange for testing at your school site. 

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Friable vs. Non-Friable

In its normal state, asbestos-containing floor tile is "non-friable" - that is, cannot be crushed under normal hand pressure. Because asbestos is an inhalation hazard, this quality makes non-friable materials safer to work around and remove.  In California, OSHA (Title 8 S1529) and the SCAQMD (Rule 1403) recognize this fact, and regulate the two types of  materials (ACMs) differently.  Removal of non-friable materials (such as roofing mastics) often require little more than proper signage and trained workers, while the removal of friable fireproofing requires numerous additional engineering controls:  negative air filtration, critical barriers at doors and windows, poly sheeting on walls, 3-stage decon unit, and so on. 

In the eyes of the SCAQMD, removal of asbestos flooring mastic, if performed with scrapers and mild solvents, does NOT render the material friable, and it may be transported as non-friable / non-hazardous asbestos waste. For larger work areas, most abatement contractors find it best to supplement the use of solvents with abrasive pads affixed to rotary scrubbing machines.  The SCAQMD views this as "removal by mechanical means", which automatically re-classifies the mastic as "friable."  This in turn triggers the requirement for tenting, HEPA filtration, 3-stage decon unit, and other OSHA Class 1 engineering controls.

But what about the waste that is generated during this process?  We recently observed a contractor install Class 1 engineering controls as required prior to the use of mechanical buffer machines to remove mastic.  All good and in compliance with AQMD rules. 

image001.jpgimage002.jpg

But THEN, they placed all of the removed mastic and solvent into unmarked bags and produced a non-hazardous waste manifest for the Owner's signature.  We balked, and directed the contractor to re-bag, re-label and re-manifest the material as hazardous asbestos waste, in keeping with their SCAQMD.  They made this change, but reluctantly, stating their belief that it was not required. 

Wrong.  It IS required.  In response to our query on the matter, the SCAQMD confirmed this, stating, "Good catch. Please refer to 1403(f)(1)(A)(viii): . . . [asbestos shall be] classified, packed, marked, and labeled, and in proper condition for highway transport according to applicable federal, state, and local regulations."

The SCAQMD further advised that, whenever friable asbestos waste is improperly packaged and transported as non-friable waste, the violation should be reported to the DTSC.

Duane Behrens, CAC #92-0226

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Certified Asbestos Consultant

California OSHA considers the administration of an asbestos abatement project to be a “Health and Safety” service, requiring the participation of a CAC.

Ellis recently responded to an asbestos emergency at a major southern California university. An abatement contractor had been given an asbestos survey report prepared by Ellis. They were then hired to remove the asbestos materials in that report prior to renovation.

And here's where it got odd: An outside "construction manager" suddenly convinced the college that this newest project could be managed "in-house," i.e. without assistance or input from Ellis or from any other California-certified asbestos consultant (CAC).

About a week after the project started, Ellis WAS called. An EH&S employee had observed the contractor remove eight thousand square feet of asbestos flooring and wallboard without engineering controls, personal protective equipment or notification. Ellis was asked to assist on an emergency basis. When asked why they'd done it, the contractor admitted they had received Ellis' original asbestos survey report, but claimed they had somehow "missed" the presence of these two asbestos materials. (Both were actually listed in Ellis' executive summary on page 1 of the report.)

The AQMD automatically investigated, cited the contractor AND the Owner, and mandated that a CAC direct all subsequent cleanup operations. Ellis administered the cleanup and the remaining abatement. The project was completed without further incident.

Had a CAC been properly retained at the start, the facility would have avoided tens of thousands in fines and delays, since its consultant would have properly identified and administered the removal of all impacted asbestos materials. California OSHA considers the administration of an asbestos abatement project to be a "Health and Safety" service, requiring the participation of a CAC. OSHA defines a CAC as "Any person who contracts to provide health-and-safety services relating to asbestos-containing construction material." OSHA even defines those activities which must be performed under the direction of an Asbestos Consultant:

  • Building Inspection
  • Abatement Project Design
  • Contract Administration
  • Sample Collection
  • Preparation of Asbestos Management Plans
  • Clearance Monitoring
  • Supervision of Site Surveillance Technicians

A reputable abatement contractor wants Ellis at their job site. They understand our role: we reduce the contractor's liability by assisting them in complying with myriad state and federal asbestos regulations, and we provide a final report to document that compliance.

REFERENCE
[1] CA Title 8 Section 1529
[2] State of California, Department of Industrial Relations, Division of Occupational Safety and Health, Asbestos
Consultant and Trainer Approval Unit, Asbestos Consultant & Site Surveillance Technician Certification Application
Package, Revised February 2004.

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California, Asbestos, and Disclosure Protocols

A potential client asked me an important question: "After performing an asbestos building survey, does [Ellis] have an obligation to disclose any asbestos findings to any State/regulatory agency? Or will it remain private to the client?"

I thought it was an important enough question to share the answer I gave, along with the opinions of a couple of Ellis employees:

Duane: "Unlike with lead paint, there is no legal requirement for a testing agency to share asbestos sampling results directly with any regulatory agency. It is the Owner and general contractor who must, by law, provide results of sampling to employees, building occupants and any trades working in the building."

Lina: " To answer the client: A testing company does not have to report asbestos findings to state/regulatory agency. Notifications to AQMD and CalOsha only if planned renovation or demolition activities involves disturbance of asbestos material greater than 100 square feet "

Ryan: "While no explicit directives exist from regulatory agencies as to the disclosure of sampling results, as a licensed consultant, Ellis has an obligation to protect itself from claims of negligence and liability with respect to the health and safety of the public.

An example might be performing a survey, finding damaged friable asbestos in occupied spaces, and receiving no further correspondence from the client. At some point following our survey, a complaint from a concerned occupant may be sent directly to a regulatory agency. The agency would likely contact the client, who may then provide Ellis' survey as their evidence of "compliance". That agency may then contact Ellis directly, and based upon the findings of our report, potentially issue sanctions and fines for non-communication of a situation that is immediately dangerous to public health and safety. In this case, Ellis is also open to potential litigation from occupants if they ever get their hands on a report and discover that Ellis as a professional noted a dangerous existing condition and did nothing further.

While extreme, the above example demonstrates that Ellis has certain obligations to not only protect the public, but also to notify regulatory agencies of intentional non-compliance when that non compliance can directly affect the health and safety of the public, or the health of Ellis as a business."

So, while there is no single black and white answer that fits all circumstances, feel free to ask us.  Knowing your options and obligations is always the smartest path forward.

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