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

Environmental

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2020 Electric Operations Conference and Expo January 16, 2020 Brian J. Harms, P.E.(WI), CIH

Silica – How Are We Doing?

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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 work operations involving stone, rock, concrete, brick, block, mortar, and industrial sand. Exposures to respirable crystalline silica can

• ccur when cutting, sawing,

grinding, drilling, and crushing these materials.” *Note: Amorphous or fused silica is

not part of this standard

Photo courtesy of AFS Silica Control Manual Photo courtesy of OSHA.gov

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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
• f silicosis include sandblasting, sand‐casting foundry
• perations, 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

Photo courtesy of sessler.cm.utexas.edu

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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)

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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/m3;

action level is 25 ug/m3 as Crystalline Silica (Quartz, Cristobalite, and Tridymite); Amorphous or Fused Silica are not part of this standard.

Understanding the Silica Rule

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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

Complying With the New Silica Rule

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• 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

OSHA Activity to Date – Construction Silica

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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:

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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.

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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.

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The employees had not been provided required medical evaluations. Proposed penalty: $96,000. Willful‐serious violation.

Contractor Faces Over $300K in Fines

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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.

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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

Contractor Faces Over $300K in Fines (Continued)

https://www.equipmentworld.com/va‐contractor‐faces‐300k‐in‐penalties‐for‐silica‐dust‐violations/

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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.

OSHA Silica Enforcement General Industry

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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.

OSHA Silica Enforcement General Industry

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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.

OSHA Silica Enforcement General Industry

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Where Does that Leave Us?

Photo courtesy of AFS Silica Control Manual

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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

Construction Activities at a Facility?

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• Small Entity Guide for Compliance with the Respirable Crystalline Silica

Standard – Construction https://www.osha.gov/Publications/OSHA3902.pdf An employer has two options for limiting employee exposure to respirable crystalline silica:

• Specified exposure control methods as listed on Table 1; or
• Alternative exposure control methods.

Construction Specific

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Specified Approach Employers who choose the specified exposure controls option must fully and properly implement protections for the tasks or equipment listed in Table 1 of the standard. Employers who fully and properly implement the controls in Table 1 do not have to assess employees’ silica exposure levels or keep employee exposures at or below the permissible exposure limit (PEL). However, still need to do the other provisions such as housekeeping, medical surveillance, training, and written exposure control plans. Alternative Approach Employers who follow alternative exposure control methods must conduct initial monitoring and employ alternative engineering controls or work practices as well as housekeeping, medical surveillance, training, and written exposure control plans.

Construction Specific

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Construction Table 1

(i) Stationary masonry saws (ii) Handheld power saws (any blade diameter) (iii) Handheld power saws for cutting fiber-cement board (with blade diameter of 8 inches or less) (iv) Walk-behind saws (v) Drivable saws (vi) Rig-mounted core saws or drills (viii) Dowel drilling rigs for concrete (ix) Vehicle-mounted drilling rigs for rock and concrete (x) Jackhammers and handheld powered chipping tools (xi) Handheld grinders for mortar removal (i.e., tuckpointing) (xii) Handheld grinders for uses other than mortar removal

Photo courtesy of www.lhsfna.org

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Construction Table 1 (Continued)

(xiii) Small drivable milling machines (xiv) Walk‐behind milling machines and floor grinders (xv) Large drivable milling machines (half‐lane and larger) (xvi) Crushing machines (xvii) Heavy equipment and utility vehicles used to abrade or fracture silica‐containing materials (e.g., hoe‐ramming, rock ripping) or used during demolition activities involving silica‐containing materials (xviii) Heavy equipment and utility vehicles for tasks such as grading and excavating but not including: Demolishing, abrading,

• r fracturing silica‐containing materials.

Photo courtesy of iqpowertools.com

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Monitoring and Root Cause Analysis

Photo courtesy of AFS Silica Control Manual

Review Ventilation & Existing Conditions (Is everything working?) Full Shift Sampling Root Cause Analysis Engineering and/or Work Practice Controls

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• Define your exposures [Know the Source]

– Compliance Monitoring – Real‐Time Task Assessment

• Minimize Regulated Areas

– Map areas

• Define Feasible Engineering Controls

– Get in front of this, the

ACGIH Ventilation Manual is a valuable resource

• AFS Study Grant to Publish Methods

Root Cause Exposure Analysis

Photo courtesy of AFS Silica Control Manual

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Fix the Low Hanging Fruit

1 2 3 4 5 6 7 8 13:34:02 13:34:26 13:34:50 13:35:14 13:35:38 13:36:02 13:36:26 13:36:50 13:37:14 13:37:38 13:38:02 13:38:26 13:38:50 13:39:14 13:39:38 13:40:02 13:40:26 13:40:50 13:41:14 13:41:38 13:42:02 13:42:26 13:42:50 13:43:14 13:43:38 13:44:02 13:44:26 13:44:50 13:45:14 13:45:38 13:46:02 13:46:26 13:46:50 13:47:14 13:47:38 13:48:02 13:48:26 13:48:50 13:49:14 13:49:38 13:50:02 13:50:26 13:50:50 13:51:14 13:51:38 13:52:02 13:52:26 13:52:50 13:53:14 13:53:38

Respirable Particulate Matter (mg/m3) Time

Chart 11 End of Shift Sweeping Powders Room ‐ No Sweeping Compound March 8, 2017

Broom Sweeping Sweeper /Vacuum Truck Enters the Area to Collect Swept up Piles Employee Leaves Area and Takes Samples to the Lab Returns to the Area Sweeper Truck Still Running MAX: 7.01 mg/m3 AVG: 1.55 mg/m3

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Fix the Low Hanging Fruit

1 2 3 4 5 6 7 8 9 10 8:24:59 8:25:23 8:25:47 8:26:11 8:26:35 8:26:59 8:27:23 8:27:47 8:28:11 8:28:35 8:28:59 8:29:23 8:29:47 8:30:11 8:30:35 8:30:59 8:31:23 8:31:47 8:32:11 8:32:35 8:32:59 8:33:23 8:33:47 8:34:11 8:34:35 8:34:59 8:35:23 8:35:47 8:36:11 8:36:35 8:36:59 8:37:23 8:37:47 8:38:11 8:38:35 8:38:59 8:39:23 8:39:47 8:40:11 8:40:35 8:40:59 8:41:23 8:41:47 8:42:11 8:42:35 8:42:59 8:43:23 8:43:47 8:44:11 8:44:35 8:44:59

Respirable Particulate Matter (mg/m3) Time

Chart 3 Sweeping with Sweeping Compound & Auto Sweeper March 7, 2017

Broom sweeping with compound (Max of 34.8 mg/m3) Driving Sweeper w/No Compound Hand Tossing MAX 34.8 mg/m3 AVG: 0.44 mg/m3

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Compressed Air On Clothing

5 10 15 20 25 13:24:58 13:26:24 13:27:50 13:29:17 13:30:43 13:32:10 13:33:36 13:35:02 Total Dust mg/m3 Time

Figure 9 Kiln Attendant ‐ Clothing Blowoff

Clothing Blowoff Time Walking Outside Back to Lunch Average: 1.40 mg/m3

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• Case Studies Using Real‐Time Instruments

– Case Study #1: Mapping – Case Study #2: Tracer Gas and Mapping – Case Study #3: Work Practices – Case Study #4: Booth Flow Rate Design – Case Study #5: Recirculation Issue

Root Cause Exposure Analysis

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Case Study #1 ‐ Mapping

Total Particulate Matter (mg/m3)

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• More Information Needed Before Moving Forward –

Employees in Blast Booth Area Exceeding OSHA PEL

– Original Theories

• Is the background air causing exceedance?
• What is the impact of material on the castings?
• Shot leaking from areas of blast booth, is that causing the

exceedance?

– Real‐Time Method Used

• DataRAM synchronized with video tape.

Case Study #2 – Root Cause Evaluation

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Case Study #2 – Root Cause Evaluation

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• Conclusions

– Background concentrations low. – Blast booth shot leak negligible affects. – Material on castings main source. – Approximately 90% of shift activities within acceptable

• limits. Remaining shift cleanup activities (i.e., sweeping,

shoveling, etc.) high enough to cause overexposures.

– Video useful in illustrating cause and effect to

management decision makers.

– Root Cause: Clean Up Issues – Why so much sand on the

castings? Shakeout not operating correctly upstream – guilty.

Case Study #2 – Root Cause Evaluation

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Case Study #3 – Recirculation Issue

Shakeout Osborne Mold- Making Wheelabrator Sand Muller 8/16/2006 11/16/2006 12/18/2007 0.000 0.010 0.020 0.030 0.040 0.050 0.060 0.070 0.080 0.090 Respirable Quartz (mg/m 3) Employee Location Date

Figure 3 Historical Silica as Quartz Results Comparison (mg/m3)

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• Conclusions

– pDR‐1200 illustrated lack of general ventilation. – pDR‐1200 graph also illustrated similar dust levels during

shakeout and melting. Why? Led to bar graph.

– Bar graph of historical results indicated better capture at

shakeout, however recirculation back inside providing mixing and silica exposure to other employees. Implicating the baghouse.

– Baghouse was opened up and found to be plugged. Guilty.

Case Study #3 – Recirculation Issue

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• OSHA Technical Manual: Chapter 3

Although not generally recommended, recirculation is an alternative to air

• exchanging. Where used, recirculation should incorporate air cleaners, a by‐

pass or auxiliary exhaust system, regular maintenance and inspection, and devices to monitor system performance. Key points to consider in the use of recirculation are shown in Table III:3‐6 *Allow time for any necessary air permitting with EPA or DNR agencies https://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_3.html

Ventilation Recirculation of Silica Processes?

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Table III:3‐6. Recirculation Criteria (OSHA)

• Protection of employees must be the primary design consideration.
• The system should remove as much of the contaminant as can economically be

separated from exhaust air.

• The system should not be designed simply to achieve PEL levels of exposure.
• The system should never allow recirculation to significantly increase existing

exposures.

• Recirculation should not be used if a carcinogen is present.
• The system should have fail‐safe features, e.g., warning devices on critical parts,

back‐up systems.

• Cleaning and filtering devices that ensure continuous and reliable collection of the

contaminant should be used.

• The system should provide a by‐pass or auxiliary exhaust system for use during

system failure.

• The system should include feedback devices that monitor system performance,

e.g., static pressure taps, particulate counters, amperage monitors.

• The system should be designed not to recirculate air during equipment

malfunction.

• The employer should train employees in the use and operation of the system.

Recirculation Continued

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Case Study #4 – OSHA Inspection – Foundry July 2019 (Initial Baseline)

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Case Study #4 – OSHA Inspection – Foundry July 2019 (After Working On Low Hanging Fruit)

Questions?

Brian J. Harms, P.E., CIH

P: 262.901.2129 | E: Bharms@trccompanies.com www.trccompanies.com