Respirable Silica Standard Awareness Daniel Stark, CIH Assistant - - PowerPoint PPT Presentation

Respirable Silica Standard Awareness

Daniel Stark, CIH – Assistant Director daniel.stark@labor.mo.gov

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Objectives

• Understand the Missouri On-site Safety and Health

Consultation Program and the services it can provide.

• Have a basic understanding of the health effects of

crystalline Silica.

• Have basic knowledge of OSHA’s Respirable Silica

Standard for the Construction Industry.

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Missouri On-site Safety and Health Consultation Program

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Consultation Program

• OSHA “mock” inspection
• No fines, penalties, or citations
• Free

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Consultation Program (continued)

• Completely Confidential!
• Serious hazards/Imminent danger
• No referral since program’s inception

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Respirable Crystalline Silica

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What is Silica and how do I get exposed?

• Compound composed of (1) silicon

and (2) oxygen atoms.

• Naturally occurring and man made

minerals

• 3 forms of silica: quartz (most

common), cristobalite and tridymite

• Exposures - chipping, cutting, sawing,

drilling, grinding, sanding, and crushing of concrete, brick, block, rock, stone products, sand products (such as glass manufacturing, foundries, and sand blasting)

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What Silica Does to You

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What Silica Does to You

Exposure to Respirable Crystalline Silica has been linked to: – Silicosis; – Lung cancer; – Chronic obstructive pulmonary disease; and – Kidney disease

Healthy Lung Your Lung on Silica Any questions?

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Historical Events on Silica

1930–1935 Hawks Nest Tunnel Incident; at least 764 Silica related deaths 1970 - OSHA Adopts ACGIH Silica Limits 1974 – NIOSH Criteria Document for Silica Standard 2008 – OSHA National Emphasis Program for Silica 2013 – Notice of Proposed Rulemaking – Occupational Exposure to Respirable Silica 2016 – Publication of the Respirable Crystalline Silica Rule

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Industries & Operations with Exposures

• Construction
• Glass

manufacturing

• Pottery products
• Structural clay

products

• Concrete products
• Foundries
• Dental laboratories
• Paintings and

coatings

• Jewelry production
• Refractory products
• Asphalt products
• Landscaping
• Ready-mix concrete
• Cut stone and stone

products

• Abrasive blasting in:
• Maritime work
• Construction
• General industry
• Refractory furnace

installation and repair

• Railroads
• Hydraulic fracturing for gas

and oil

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Why did we need a new standard?

• Old Permissible Exposure Limit (PEL) not protective

enough

• PEL for Silica are hard to understand - 10/%+2??

What??

• Construction/shipyard PELs are obsolete particle count

limits

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Benefits of a new Silica standard

New rule will prevent:

• More than 900 new silicosis cases per year
• 600 deaths per year
• Lung cancer:

124

• Silicosis and other non-cancer

lung diseases: 325

• End-stage kidney disease:

193

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What you can’t see can kill you!

1 micron = 1/25,000th of an inch

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How much Silica can worker’s be exposed to with the new Standard??

• PEL = 50 µg/m3 as an 8-

Hour TWA

• Action Level = 25 µg/m3

as an 8-Hour TWA

• Don’t confuse the AL

with the PEL!

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Respirable Silica Final Rule Published March 25, 2016

• Construction -

29 CFR 1926.1153

• General Industry –

29 CFR 1910.1053

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Silica Standard for Construction

(a) Scope

(b) Definitions (c) Specified exposure control methods OR (d) Alternative exposure control methods

• PEL
• Exposure

Assessment

• Methods of

Compliance (e) Respiratory protection (f) Housekeeping (g) Written exposure control plan (h) Medical surveillance (i) Communication of silica hazards (j) Recordkeeping (k) Dates

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Things you need to do to comply

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Scope of Standard

• All occupational exposures to respirable crystalline silica are

covered if the Action Level is reached in an 8 hr. TWA.

• If controls are needed to keep employee exposure below the

Action Level; only the following items need to be done: – Written Exposure Control Plan – Competent Person – Housekeeping – Employee Training – Recording Keeping

• However, once the Action Level is reached, these items and

more, much more is required!

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STEP #1 - Write an Exposure Control Plan

All employers who are covered by the standard must have an Exposure Control Plan. The plan must describe:

• Tasks involving exposure to respirable

crystalline silica

• Engineering controls, work practices, and

respiratory protection for each task

• Housekeeping measures used to limit

exposure

• Procedures used to restrict access, when

necessary to limit exposures

• Must evaluate effectiveness annually,

update as necessary

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STEP #2 - Designate a “Competent Person”

• Construction employers must designate a

competent person to implement the written exposure control plan

• Competent person is an individual capable
• f identifying existing and foreseeable

respirable crystalline silica hazards, who has authorization to take prompt corrective measures

• Makes frequent and regular inspection of

job sites, materials, and equipment

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STEP #3 – Follow the right cleanup procedures

When it can contribute to exposure, employers must not allow:

• Dry sweeping or brushing
• Use of compressed air for cleaning surfaces or

clothing, unless it is used with ventilation to capture the dust However, these methods can be used if no other methods like HEPA vacuums, wet sweeping, or use of ventilation with compressed air are feasible

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STEP #4 - Communication of Hazards – Employee Training

• Comply with Hazard Communication Standard

(HCS) (29 CFR 1910.1200)

• Address: Cancer, lung effects, immune system

effects, and kidney effects as part of HCS

• Train workers on health hazards, tasks

resulting in exposure, workplace protections, and medical surveillance

• Identify competent person

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STEP #5 – Records You Need to Keep

Must maintain records per 29 CFR 1910.1020 for:

• Air monitoring data
• Objective data
• Medical Surveillance

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My employee’s exposure is over the Action Limit. Now what do I do?

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STEP #6 – Follow Table 1 (If you can)

• Specified Exposure Control methods - Table 1 in the

construction standard matches 18 tasks with effective dust control methods and, in some cases, respirator requirements.

• Employers that fully and properly implement controls on Table

1 do not have to: – Comply with the PEL – Conduct exposure assessments for employees engaged in those tasks

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List of Table 1 Entries

• Stationary masonry saws
• Handheld power saws
• Handheld power saws for fiber

cement board

• Walk-behind saws
• Drivable saws
• Rig-mounted core saws or drills
• Handheld and stand-mounted

drills

• Dowel drilling rigs for concrete
• Vehicle-mounted drilling rigs for

rock and concrete

• Jackhammers and handheld

powered chipping tools

• Handheld grinders for mortar

removal

• Handheld grinders for other than

mortar removal (tuckpointing)

• Walk-behind milling machines

and floor grinders

• Small drivable milling machines
• Large drivable milling machines
• Crushing machines
• Heavy equipment and utility

vehicles to abrade or fracture silica materials

• Heavy equipment and utility

vehicles for grading and excavating

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What does “Fully and Properly Implementing Controls Specified on Table 1” mean?

• Controls have to be in place, properly
• perated and maintained, and employees

know how to use them.

• Small amounts of dust may just be part of the

equipment working properly, but large amounts shows there is a problem with the control.

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When are Employees Engaged in a Table 1 Task?

• Employees are “engaged in the

task” when operating the listed equipment, assisting with the task, or have some responsibility for the completion of the task

• Employees are not “engaged in

the task” if they are only in the vicinity of a task

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Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and Minimum APF ≤ 4 hr/shift > 4 hr/shift Handheld power saws (any blade diameter) Use saw equipped with integrated water delivery system that continuously feeds water to the blade. Operate and maintain tool in accordance with manufacturers’ instruction to minimize dust

• When used outdoors
• When used indoors or in an enclosed

area None APF 10 APF 10 APF 10

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Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and Minimum APF ≤ 4 hr/shift > 4 hr/shift Stationary masonry saws Use saw equipped with integrated water delivery system that continuously feeds water to the blade. Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions. None None

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Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and Minimum APF ≤ 4 hr/shift > 4 hr/shift Vehicle- mounted drilling rigs for rock and concrete Use dust collection system with close capture hood or shroud around drill bit with a low-flow water spray to wet the dust at the discharge point from the dust collector. OR Operate from within an enclosed cab and use water for dust suppression on drill bit. None None None None

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STEP #7 – Follow the Respiratory Protection Requirements in Table 1

• Where exposures above the PEL are likely to persist,

(despite full and proper implementation of the specified engineering and work practice controls) respiratory protection must be worn.

• Where respirators are required, they must be used by

all employees engaged in the task for entire duration

• f the task
• Provisions specify how to determine when respirators

are required for an employee engaged in more than

• ne task

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I’m not doing any tasks in Table 1 – so now what do I do?

• Conduct an exposure assessment to

determine whether workers are above the PEL by using Alternative Exposure Control Methods: – Performance Option

• r

– Scheduled Monitoring Option

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Performance Option

• Exposures assessed using any combination
• f air monitoring data or objective data

sufficient to accurately characterize employee exposure to respirable crystalline silica

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What’s Objective Data?

• Air monitoring data from industry-wide surveys or

calculations based on the composition of a substance;

• Demonstrates employee exposure associated with

a particular product or material or a specific process, task, or activity;

• Must reflect workplace conditions closely

resembling or with a higher exposure potential than the processes, types of material, control methods, work practices, and environmental conditions in the employer's current operations.

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Scheduled Monitoring Option

What is it? - A schedule for performing initial and periodic personal monitoring. If monitoring indicates:

• Initial below the AL: no additional monitoring
• Most recent at or above the AL: repeat within 6 months
• Most recent above the PEL: repeat within 3 months
• When two consecutive non-initial results, taken 7 or

more days apart, are below the AL, monitoring can be discontinued

• Reassess if circumstances change

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STEP #8 – Notify Employees of Sampling Results

• Employer must notify individually each affected

employee of the results of sampling in writing or posting within 5 working days of completion.

• If above the PEL, notification must include

corrective action being taking to reduce the exposure to at or below the PEL.

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STEP #9 – Make sure you are following the “Hierarchy of Controls”

• Employers shall use

engineering or work practice controls to limit exposures to the PEL

• Respirators permitted where

PEL cannot be achieved with engineering and work practice controls

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Engineering Controls

Polishing stone using water to control the dust Grinding stone without engineering controls

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Engineering Controls

Grinding using a vacuum dust collector Grinding without engineering controls

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Engineering Controls (cont.)

Jackhammer use with water spray to control dust Jackhammer use without engineering controls

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STEP #10 – Comply with OSHA’s Respiratory Protection Standard (29 CFR 1910.134)

Respirators required for exposures above the PEL:

• While installing or implementing controls or work

practices

• For tasks where controls or work practices are

not feasible

• When feasible controls cannot reduce exposures

to the PEL

• While in a regulated area (General

Industry/Maritime)

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STEP #11 – Get your Employees checked by a Doctor

• Must offer medical examinations to workers IF:

– they will be required to wear a respirator under the standard for 30 or more days a year; – Within 30 days of initial assignment.

• Must be offered examinations every 3 years to

workers who continue to be exposed above the trigger.

• Exam includes: medical and work history, physical

exam, chest X-ray, and pulmonary function test (TB test on initial exam only)

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STEP #12 – Get the Doctor’s Report

• Worker receives report with detailed medical

findings.

• Employer receives an opinion that only describes

limitations on respirator use, and if the worker gives written consent, recommendations on:

• Limitations on exposure to respirable crystalline

silica, and/or

• Examination by a specialist

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When does all this stuff need to be done by?

• Employers must comply with all requirements

(except methods of sample analysis) by September 23, 2017 (used to be June 23, 2017)

• Compliance with methods of sample analysis

required by June 23, 2018

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Roadmap for meeting the Requirements of the Respirable Crystalline Silica Standard

• 1. Determine if the silica standard applies to your employees.

Could employees be exposed to respirable crystalline silica at or above 25 ug/m3 as an 8-hour TWA under any foreseeable conditions, including the failure of engineering controls, while performing construction activities? No: No further action is required under the silica standard. Yes: Choose to comply with the standard using either the: Specified exposure control in Table 1, or The alternative methods of compliance.

• 2. Determine what additional requirements you must meet under the standard, based on the compliance method you are

following. Must the Employer Follow the Requirement? Requirement If Fully and Properly Implementing Table 1 If Following Alternative Exposure Controls PEL No Yes Exposure Assessment No Yes Methods of Compliance No Yes Respiratory Protection Yes, if respirator use is required by Table 1 Yes, if respirator use is required to reduce exposures to the PEL Housekeeping Yes Yes Written Exposure Control Plan Yes Yes Medical Surveillance Yes, for employees who must wear a respirator under the silica standard for 30 or more days a year Communication of Hazards Yes Yes Recordkeeping Yes, for any employees who are getting medical examinations Yes, for employee assessments and for any employees who are getting medical examinations

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Helpful Publications

• Small Entity Compliance Guide for the Respirable Crystalline Silica

Standard for Construction: https://www.osha.gov/Publications/OSHA3902.pdf

• Interim Enforcement Guidance for the Respirable Crystalline Silica

Construction Standard: https://www.osha.gov/laws-regs/standardinterpretations/2017-10-19

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Objectives

• Have a basic understanding of the Missouri On-site

Safety and Health Consultation Program and the services it can provide.

• Gain a basic understanding of the health effects of

Crystalline Silica.

• Have basic knowledge of OSHA’s Respirable Silica

Standard for the Construction Industry.

Improve Safety and Save Money!

Questions?