Silica How Are We Doing? 2020 Electric Operations Conference and - PowerPoint PPT Presentation

Environmental Silica – How Are We Doing? 2020 Electric Operations Conference and Expo January 16, 2020 Brian J. Harms, P.E. (WI) , CIH 1

Background From OSHA…. “ Respirable crystalline* silica – very small particles at least 100 times smaller than ordinary sand you might encounter on beaches and playgrounds – is created during Photo courtesy of AFS Silica Control Manual work operations involving stone, rock, concrete, brick, block, mortar, and industrial sand. Exposures to respirable crystalline silica can occur when cutting, sawing, grinding, drilling, and crushing these materials.” Photo courtesy of * Note: Amorphous or fused silica is OSHA.gov not part of this standard 2

Background  DIRECTIVE NUMBER: CPL 03‐00‐007 EFFECTIVE DATE: 1/23/08 Silica can be crystalline or amorphous. Crystalline silica is significantly more hazardous to employees than amorphous silica. In addition to causing the disabling and irreversible lung disease silicosis , crystalline silica has been classified as a Group I carcinogen ‐ Carcinogenic to Humans by the International Agency for Research on Cancer (IARC ) [IARC, 1997]. The term "silica" as it is used in this directive refers specifically to crystalline silica. Crystalline silica is an important industrial material, and occupational exposure occurs in a variety of workplace settings, including mining, manufacturing, construction, maritime, and agriculture. Processes associated historically with high rates Photo courtesy of of silicosis include sandblasting, sand‐casting foundry sessler.cm.utexas.edu operations, mining, tunneling, cement cutting and demolition, masonry work, and granite cutting. https://www.osha.gov/pls/oshaweb/owadisp.show_docume nt?p_table=DIRECTIVES&p_id=3790 3

Background  August 2013: Proposed Rule Released  March 2014: Public Hearings Begin on Silica Proposal  December 2015: Rule Sent for Final Review  March 25, 2016: Final Rule Published in Federal Register  June 23, 2016: Rule Becomes Effective (Starts the Clock)  September 23, 2017 : Requirements Effective for Construction  June 23, 2018: Requirements Effective for General Industry (Including Engineering Controls)  June 23, 2018: Medical surveillance required for employees above the PEL for 30 or more days  June 23, 2020: Medical surveillance required for employee above the Action Level for 30 or more days  June 23, 2021: Engineering controls to be in place (Applies to Fracking Industry Only) 4

Understanding the Silica Rule New Rule 29 CFR 1910.1053 Industry https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=1282 New Rule 29 CFR 1926.1153 Construction https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=1270  Removes formula, new PEL is 50 ug/m 3 ; action level is 25 ug/m 3 as Crystalline Silica (Quartz, Cristobalite, and Tridymite); Amorphous or Fused Silica are not part of this standard. Page 5

Complying With the New Silica Rule 1. Review and Understand the New Silica Rule 2. Conduct Initial Ventilation Assessment and Monitoring 3. Document Initial Monitoring Results in Your Silica Exposure Control Plan 4. Target Problem Areas For Root Cause Analysis 5. Document Results of the Root Cause Analysis and Identify Action Items 6. Fix the “Low Hanging Fruit” – Engineering Controls/Work Practices 7. Document Those Fixes in Your Silica Exposure Control Plan 8. Re‐Monitor and Document Results 9. ( $$ ) For Areas Still Above the New PEL: Outline Requirements (i.e. Medical Evaluations, PPE, Monitoring Schedules, Notifications, etc.) 10. ( $$$ )Prepare an Engineering Study for Processes Still Above the New PEL and Document an Approach in your Silica Exposure Control Plan 6

OSHA Activity to Date – Construction Silica  Enforcement of the Construction Silica Standard – September 23, 2017 – April 17, 2018 – 116 Citations (First Citation Issued on November 8, 2017)  35 Related to failure to conduct initial monitoring  31 Citations for failure to follow Table 1 correctly  24 Citations for failure to follow a Written Exposure Reduction Plan  19 Citations for failure to conduct employee training  7 Citations for improper respiratory protection Occupational Health & Safety Reporter (SM) April 24, 2018 – Silica Safety Enforcement Ramps Up at Construction Sites  https://www.bna.com/silica‐safety‐enforcement‐n57982091432/ American Society of Safety Professionals (ASSP) June 27, 2018 – OSHA Silica Enforcement Behind the Statistics  https://www.assp.org/news‐and‐articles/2018/06/27/osha‐silica‐enforcement‐behind‐the‐statistics 7

Contractor Faces Over $300K in Fines Contractor in Roanoke, Virginia was issued five citations in August 2018 by VOSH for violations on February 20 and May 16. According to VOSH, the violations are as follows: – Workers were not using wet methods to reduce silica dust while operating jackhammers to remove concrete from piers on the Exit 45 bridge on Interstate 81 at Marion on February 20. On May 16, workers were operating jackhammers without using respiratory protection. Proposed penalty: $96,000. Willful‐serious violation. The company did not assess the exposure to each employee exposed to silica – dust on February 20 and May 16. Proposed penalty: $96,000. Willful‐serious violation. The employees had not been provided required medical evaluations. – Proposed penalty: $96,000. Willful‐serious violation. 8

Contractor Faces Over $300K in Fines (Continued) A temporary worker removed concrete from the deck of the bridge without – being trained on silica hazards as required. Proposed penalty: $8,065. Serious violation. – Workers and the superintendent were not wearing proper eye protection May 16 while operating jackhammers or observing the work. They were wearing sunglasses instead of approved safety eyewear while removing concrete from the bridge deck. Proposed Penalty: $8,065. Serious violation. Equipment World.COM Article – Don McCloud – September 5, 2018: Va. Contractor Faces $300K in Penalties for Silica Dust Violations https://www.equipmentworld.com/va‐contractor‐faces‐300k‐in‐penalties‐for‐silica‐dust‐violations/ 9

OSHA Silica Enforcement General Industry June 7, 2018, OSHA issued a memorandum to its regional administrators concerning general industry/maritime enforcement. It stated that: – OSHA will assist employers that are making good‐faith efforts to meet the new standard’s requirements during the first 30 days of enforcement. – If an employer is not making efforts to comply, OSHA officers will conduct air monitoring according to agency procedures. – Officers will also consider citations for noncompliance with the applicable sections of the new standard. – During the first 30 days of enforcement, any proposed citations related to silica inspections will undergo national office review. 10

OSHA Silica Enforcement General Industry SYRACUSE, NY – The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has cited an iron foundry for 33 workplace health and safety violations. The company faces $460,316 in penalties.  OSHA inspectors cited the company for multiple hazards, including exposing employees to crystalline silica, iron oxide, combustible dust, falls, struck‐by and caught‐between hazards, unsafe work floors and walking surfaces, inadequate respiratory protection, deficient safeguards for entering confined spaces, inaccessible and unavailable fire extinguishers, and an impeded exit route. The company also lacked an effective program for removing pests, and did not prevent the build‐up of bird feces on equipment. 11

OSHA Silica Enforcement General Industry DELAWARE, OH – The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) has cited a Casting Company for exposing employees to crystalline silica above the permissible exposure levels. The company faces $270,048 in proposed penalties for three repeated and 18 serious health violations.  OSHA inspectors determined that the company failed to implement engineering and work practice controls to limit employee exposure to silica, provide and require the use of respirators, develop an exposure control plan and medical surveillance procedures, and train employees on OSHA's silica standards. The company also failed to provide personal protective equipment; conduct hazard assessments; use adequate machine guarding, and develop lockout/tagout control procedures; and exposed employees to fall and electrical hazards. 12

Where Does that Leave Us? Photo courtesy of AFS Silica Control Manual 13

Construction Activities at a Facility? The general industry standard does not apply to the following:  Where the employer chooses to comply with the construction standard (29 CFR 1926.1153) for tasks performed that are indistinguishable from a construction task listed on Table 1 of the construction standard, provided the tasks are not performed regularly in the same environment and conditions. For Example: the construction standard could not be used by a general industry and maritime employer for sanding or cutting of concrete blocks in a concrete block manufacturing plant, because that is a task performed regularly in the same environment and conditions. Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime 14