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News + Events

The Galson Blog

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Edward Stuber CIH

10/31/2014

LEED 2009 Registration Extended to October 2016


I have just returned from the annual GREENBUILD International Conference and Expo held in New Orleans. Spending a week in The Big Easy was indeed easy. Good music and even better food made visiting there a real treat. I was at the conference to be part of an AIHA sponsored round table presentation on the IAQ aspect of LEEDv4. Our session was titled “Indoor Air Quality Management and Sampling” The focus of my portion of the presentation was to compare and contrast the IAQ sampling and analysis requirements between LEED 2009 and LEEDv4. I am happy to say that our session was sold out and very well received!



It has been less than a week since the conference ended and today I found out the USGBC says the market needs additional time to prepare for LEEDv4. When LEEDv4 was put into effect in November 2013, you had until June 2015 to implement it. You could no longer use LEED 2009 after that date. The USGBC has decided requiring new LEED projects to register for LEEDv4 as of June 2015 was too soon and has shifted that date back to October 31, 2016. The USGBC said that it was giving the market more time to get ready for LEEDv4 based on feedback it received during the aforementioned Greenbuild Conference. According to USGBC, > 60% of respondents to a survey said they are “not ready” or “unsure” if they are ready for LEEDv4 and require additional time to prepare. USGBC launched LEEDv4 as a more rigorous and fresh take on the LEED green building rating system. Although there are many more components to LEEDv4 that people may take issue with, the laboratory community had some major issues with the IAQ portion of the new standard and for the most part, we are glad for the extension.



As of today, nine LEEDv4 projects had been certified and 304 had started the process by registering during 2014. That's 15 times fewer than the almost 4,500 LEED 2009 projects registered to date. Between those numbers, the survey, and other market feedback (I like to think the lab community had something to do with this), the USGBC decided it had heard enough and extended the LEED 2009 window another 16 months.



What happens at the end of the extension period? Who knows? Could there be another extension? Possibly. By that time, the IAQ portion of LEEDv4 may not even look like it does today. This summer prior to the conference, members of the AIHA IAQ Committee (yours truly included) and the USGBC IEQ TAG meet and reviewed information and questions about LEEDv4 IAQ sampling requirements. A report, complete with recommendations, has been complied and will be presented to the USGBC for consideration and action. Stay tuned for further developments that may come out of this report.



If you would like a soft copy of my presentation, please feel free to email me at estuber@galsonlabs.com.  I would happy to provide you with the presentation. If you are interested in finding out more about LEED IAQ certification. Click here.



 


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Bill Walsh CIH

09/22/2014

Galson and SGS - Better Together!


As has previously been announced, Galson was recently purchased by SGS, the world’s largest certification and testing company based in Geneva, Switzerland. Those people who know me know that this is not the first time the company I worked for, owned by an equity management firm, was purchased by a Global company.  In fact, on the surface the two situations appear to be similar. 



My first experience of being integrated into a very large corporation can be best characterized as a slow process.  The comparison to my first experience and SGS acquisition of Galson, so far is day and night.



 As a matter of fact, I’m sure that this experience and the benefit to our clients will be one of progress for the following reasons:



1)    Galson was purchased in order to be the flagship operation among a number of other accredited IH labs owned by SGS.  These laboratories are located in China, Brazil, Spain, and Australia. Our purchase is part of an overall strategic plan that will export the procedures and culture that has made Galson successful to these other labs.  I’m sure that Galson will also identify procedures and service offerings that can enhance our US operations. The end result will be that our multi-national clients will have access to local laboratories that will offer the quality and customer service they have come to expect from Galson and our domestic clients will benefit from the lessons and capabilities we will receive from the overseas labs. 



2)    This is completely different from my first experience in merging companies together when in the first case the buyer took two proud companies that were in a very spirited competition with each other for over twenty years, possessing diametrically opposed corporate cultures, dramatically overlapping books of business, and lying in close proximity to each other (300 miles) and then expected them to work together while basically remaining competitors in order to meet their independent (and aggressive) growth targets.  I have deep respect for the people involved from both labs even though the “integration” more often resembled a cage match.



3)    There is no deadline for integration.  SGS management realizes that although Galson is now an SGS company, forcing it into a pre-determined mold could end up hurting the values (innovation, market responsiveness, client empathy) that made it an extremely successful (and profitable) operation.  The value of the Galson brand is recognized and the timetable for integration is strictly “when it makes sense”.  In my previous integration experience, I had to spend way too much of my time trying to manage problems caused by observing artificial deadlines instead of carefully planning out a successful integration.  This was especially true in areas outside of my direct control, such as IT, finance, and marketing.



4)    Along the lines of “making sense” SGS has asked the right questions regarding our book of business and determined that given its makeup, it did not make sense to compete against our clients in the US.  This is in spite of the news that one of our competitors (you know who you are) is attempting to spread that word to our consultant clients.  SGS does offer field services in a large number of other countries and as I have previously said, many of our clients are looking forward to having these resources available. For our consulting clients we will now have the ability to get them involved in Global contracts that we did not have access to previously.



5)    Getting rid of an equity partner is always a good thing.  These companies exist to buy, package, and sell firms in order to make a profit.  This is neither a good or bad thing, just a fact of life.  Part of their operating model is to strictly control expenses which can, as a side effect, stifle innovation and capital investment since they are controlling the money without a deep knowledge of the business. Galson/SGS will now be able to make investments insuring the long-term health and growth of the operation.



So I’m feeling good about the sale. Many IH Laboratories have been acquired (DataChem, NATLSCO, Clayton, and others) by large multi-nationals with deep pockets and Galson will be able to compete on a larger stage with SGS as a parent.  Upper management is being thoughtful about integrating us and I expect the corporate staff to be a great help going forward.  During the phone conversation where I was introduced to upper management I was asked specifically what went wrong last time so it could be avoided, reflecting  the overriding concern that things be done right. I’m not so naïve to think that things won’t change in going from a small, tightly knit group to a company with 80,000 employees, but from what I have seen so far the things that have made Galson a trusted partner to its clients will remain.


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Bill Walsh CIH

05/09/2014

Adventures at the U.S. Department of Labor


On April first I had the experience of testifying about the proposed new silica standard at the U.S. Department of Labor in Washington DC.  I did this in my role as Vice-Chair of the Analytical Accreditation Board, testifying on the portion of the proposed standard requiring a lab to be accredited. 



However, because an industry group submitted a study suggesting that “AIHA labs could not accurately analyze silica at the proposed levels”, much of my testimony revolved around the validity (or lack thereof) of this study.



First of all, it was a political exercise with very little hard science involved.  The room was evenly divided between those against the proposal and those in favor of it (basically industry versus labor). The point of the testimony was to get statements supporting a position into the record while nullifying or at least minimizing the impact of an opposing statement.  This is probably pretty obvious to everyone, but it was surprising to actually see it in operation. It was also REALLY surprising to see people, who I know do silica analyses on a daily basis, perform as hired experts saying the method was inaccurate.  I’ve talked to some of them and some were quick to state their opinion was pertaining to the 25 microgram proposed PEL, others were trying to establish themselves as “friends and knowledge resources for the industry”, and some just wanted to take the money and run. 



My testimony consisted of reading a prepared statement and then answering questions.  Due to time constraints, my reading of the statement was stopped and the rest was just entered into the record.  This was done so that the audience and the OSHA panel could ask me questions. This brings up my second point.  The judge and the OSHA panel had to have the patience of Job to sit there for three weeks and listen to person after person read testimony in what was usually a dry, monotone manner influenced by their ability to read.  I listened for two hours prior to probably doing the same thing and it was painful.  Those people had been doing this for THREE WEEKS!  Anyway, when the judge said to move on to the Q&A, the energy in the room increased dramatically.  This was obviously the fun part and why everyone had come.



I answered the questions to the best of my ability (I am quite familiar with the analytical method, instrumentation, and the submitted study).  The questions tended to be more statements than questions and the judge stopped the questioners several times, at one point actually saying, “Are you asking a question or testifying”.  Again, the point of the exercise was to get your viewpoint into the record.  I enjoyed it as I was sure of my facts and enjoy a good verbal tussle.  I would enjoy doing it again.



Here is my opinion of the proceedings:



1)      Nothing may happen for a couple of years.  It is my understanding that now that the comment phase is over, it can be up to two years before the final rule is issued, at which time multiple lawsuits may ensue.  If the IH community is frustrated with the length of time it takes to promulgate a new standard, believe me, many people at OSHA are just as frustrated.  Although I’ve always suspected it, actually seeing the building of the political roadblocks was enlightening (and a little sad from a professional viewpoint).



2)      No one is absolutely wrong in this debate.  The current standard is completely outdated.  But industry is correct in that the current regulations have not been enforced properly.  Just today I had a phone call from a CIH who talked about a road construction project where the cement cutting produced a cloud that was almost impossible to drive through and covered a whole neighborhood.  Obviously this violated a whole slew of standards (PM10, Total Dust, Respirable Dust) beyond silica.  The situation could have been easily rectified in this area because water to do wet cutting was readily available – where was the enforcement of current standards.  I somewhat agree that the good guys spend the money and are affected by the standards, while the people endangering their employees are less affected.



3)      It is REALLY important that the lab you use be accredited to ISO 17025.  This at least lays a ground work for quality results. Just remember that accreditation does not guarantee accuracy.  It is a basement standard of performance, not a ceiling.



4)      Just because the lab is accredited, that doesn’t mean they will be good at what they do (although it helps).  As in anything else, picking a lab is “buyer -beware” and you have to do your homework. Ask to see your lab’s QC data on intra-batch samples, LOQ studies, and ask them how they deal with all the interferences known to be a problem.



5)      I am absolutely confident that the analytical method can be done with acceptable accuracy and precision.  I am just as sure that it produces horrible accuracy and precision if not done CAREFULLY.  Sample prep is critical as are the instrument parameters used to analyze the samples.  Silica analysis is a perfect example of “haste makes waste”.  A great deal of variation can be  caused in the step where the sample is redeposited from the collection filter onto the silver membrane filter used in the analysis.  It has to be slowly and carefully done. 



6)      In the same manner, good labs assume there will always be an interference and proceed accordingly, including a muffle furnace or similar step in the digestion procedure.  PAT samples have some interference present in them. Labs that don’t take this into account will get burned, as will the people who use them. Again, Caveat Emptor. However, not informing the lab about where a sample has been taken and if any KNOWN interferences are present is just tying one hand behind the lab’s back.



7)      I am ABSOLUTELY confident in Galson’s ability to produce accurate and precise results at a PEL of 50 micrograms per cubic meter.  I also believe that we could produce valid data at a level of 25 micrograms per cubic meter, with a few more method modifications. I am just as certain the other labs that I’ve been associated with over my 30 year career also generate good data (although a paid expert from one of those labs testified otherwise!).  I am also just as confident that there are some labs that simply do not do the analysis correctly.



8)      Do your homework, ask the right questions, inform the lab about where you are taking the sample and what possible interferences there may be, and you’ll get great results.  And, that applies to any lab analysis.



 


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Edward Stuber CIH

05/05/2014

California Department of Public Health Recommends Lowering Cal/OSHA PEL for Lead


​Here is something that is not getting much play in the Health & Safety community – at least I have not heard much about it. Back in November 2013, the California Department of Public Health’s (CDPH) Occupational Lead Poisoning Prevention Program (OLPPP) recommended a significant reduction to Cal/OSHA’s permissible exposure limit (PEL) for air lead levels in the workplace. The OLPPP is recommending workers’ exposure to lead in air be kept at or below 0.5 to 2.1 micrograms of lead per cubic meter of air (µg/m3). The current Cal/OSHA PEL, as well as the Federal OSHA PEL, is 50 µg/m3.  Stop and think about that for a minute. The OLPPP is recommending up to a 100X reduction of the current Cal/OSHA PEL for lead. WOW!



OLPPP is saying their recommended PEL is based on its determination that having chronic blood lead levels (BLLs) at or above the range of 5 to 10 micrograms per deciliter (µg/dL) poses a health risk to workers. The proposed PELs were obtained from risk modeling results performed by the Office of Environmental Health Hazard Assessment (OEHHA). The OEHHA estimated the concentrations of lead in air that would result in BLLs of interest over a 40-year working lifetime. They came up with 0.5 to 2.1 ug/m3 of lead in air values.



If CAL/OSHA implements this proposed change, it could mean big things for the lead analysis (ie IH lead laboratory) community. Currently labs can meet the CAL/OSHA and Federal OSHA lead PEL of 50ug/m3 by using relatively inexpensive equipment, such as Flame AA instruments. By using this inexpensive technique, labs can charge a low rate for the analysis. If the new PEL is implemented, labs will have to use the more expensive analytical techniques of graphite furnace or ICP, ICPMS.  This would add considerable cost to the sample analysis.  Something to think about. I am all for protecting the worker and if it means lowering PELs, then so be it.



For more information, you can read OLPPP’s recommendation here


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