Silica Exposure Control Plan. University of Maryland, Baltimore

Transcription

1 Silica Exposure Control Plan University of Maryland, Baltimore

2 Table of Contents Purpose Section 1 Scope.Section 2 Responsibilities..Section 3 Specified Exposure Control Methods..Section 4 Non-Specified Exposure Control.Section 5 Product Substitution..Section 6 Respiratory Protection..Section 7 Monitoring.Section 8 Housekeeping..Section 9 Training.Section 10 Recordkeeping.Section 11

3 Section 1 - Purpose The purpose of this document is to establish and implement a written exposure control plan that identifies tasks involving silica exposure and methods used to protect employees. Departments are required to implement the components of the Plan to ensure compliance with the following applicable state and federal regulations. The following Occupational Safety and Health Administration (OSHA) standards are applicable for respirable crystalline silica. General Standard 29 CFR Construction Standard 29 CFR Section 2 - Scope This plan covers all university activities where during an employee s work they may be exposed to respirable silica dust. The plan covers what is expected from all affected members of the university and actions to be taken to reduce exposure. Section 3 - Responsibilities 3.1 Departments: Ensure that all affected personnel follow the exposure control plan. Purchase the appropriate exposure control devices and associated equipment when determined necessary or warranted. Provide medical monitoring to personnel that are required under the OSHA standard for individuals that use a respirator for more than 30 days in a calendar year due to crystalline silica dust exposure. 3.2 Supervisors: Identify work operations and personnel that may require adherence to the Silica Exposure Control Plan. Ensure workers follow the exposure control plan. Ensure adjacent areas to where work is being done are notified and proper containment is utilized. 3.3 Employees: Adhere to requirements of the Silica Exposure Control Plan. Complete all safety training for silica exposure. Notify employee s supervisor when equipment needs servicing.

4 Report all workplace injuries, unsafe conditions and near misses to their supervisors. Follow guidelines on the proper use and limitations of control devices. Adhere to the requirements of the Respiratory Protection Policy and program if needed. 3.4 Environmental Health and Safety: Prepare the Silica Exposure Control Plan and facilitate the review annually. Distribute the Silica Exposure Control Plan to each affected department and employee. Maintain training and monitoring records. If needed, enroll affected employees in Respiratory Protection Program. Provide training on the Silica Exposure Control Plan and respirable silica dust hazards. Perform monitoring to ensure that activities that are not covered by the specific control plan are below regulatory standard levels or proper safety controls are in place. Conduct periodic audits to determine the control plans effectiveness. Section 4 - Specified Exposure Control Methods Table 1 Specified Exposure Control Methods When Working With Materials Containing Crystalline Silica Equipment/Task (i) Stationary masonry saws (ii) Handheld power saws (any blade diameter) Engineering and work practice control methods Use saw equipped with integrated water delivery system that continuously feeds water to the blade Required respiratory protection and minimum assigned protection factor (APF) 4 hours/shift >4 hours/shift When used outdoors APF 10 When used indoors or in an enclosed area APF 10 APF 10

5 (iii) Handheld power saws for cutting fiber-cement board (with blade diameter of 8 inches or less) For tasks performed outdoors only: Use saw equipped with commercially available dust collection system Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency (iv) Walk-behind saws Use saw equipped with integrated water delivery system that continuously feeds water to the blade When used outdoors When used indoors or in an enclosed area APF 10 APF 10 (v) Drivable saws For tasks performed outdoors only: Use saw equipped with integrated water delivery system that continuously feeds water to the blade

6 (vi) Rig-mounted core saws or drills (vii) Handheld and standmounted drills (including impact and rotary hammer drills) (viii) Dowel drilling rigs for concrete (ix) Vehicle-mounted drilling rigs for rock and concrete Use tool equipped with integrated water delivery system that supplies water to cutting surface Use drill equipped with commercially available shroud or cowling with dust collection system Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism Use a HEPA-filtered vacuum when cleaning holes For tasks performed outdoors only: Use shroud around drill bit with a dust collection system. Dust collector must have a filter with 99% or greater efficiency and a filter-cleaning mechanism 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 APF 10 APF 10

7 (x) Jackhammers and handheld powered chipping tools point from the dust collector OR Operate from within an enclosed cab and use water for dust suppression on drill bit Use tool with water delivery system that supplies a continuous stream or spray of water at the point of impact: When used outdoors APF 10 When used indoors or in an APF 10 APF 10 enclosed area OR Use tool equipped with commercially available shroud and dust collection system Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism: When used outdoors APF 10 (xi) Handheld grinders for mortar removal (i.e., tuckpointing) When used indoors or in an enclosed area Use grinder equipped with commercially available shroud and dust collection system APF 10 APF 10 APF 10 APF 25

8 (xii) Handheld grinders for uses other than mortar removal Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic pre-separator or filtercleaning mechanism For tasks performed outdoors only: Use grinder equipped with integrated water delivery system that continuously feeds water to the grinding surface

9 OR Use grinder equipped with commercially available shroud and dust collection system Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic pre-separator or filtercleaning mechanism: When used outdoors (xiii) Walk-behind milling machines and floor grinders When used indoors or in an enclosed area Use machine equipped with integrated water delivery system that continuously feeds water to the cutting surface APF 10

10 (xiv) Small drivable milling machines (less than halflane) (xv) Large drivable milling machines (half-lane and larger) OR: Use machine equipped with dust collection system recommended by the manufacturer Dust collector must provide the air flow recommended by the manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism When used indoors or in an enclosed area, use a HEPA-filtered vacuum to remove loose dust in between passes Use a machine equipped with supplemental water sprays designed to suppress dust. Water must be combined with a surfactant machine to minimize dust emissions For cuts of any depth on asphalt only: Use machine equipped with exhaust ventilation on drum enclosure and supplemental water sprays designed to suppress dust machine to minimize dust emissions

11 For cuts of four inches in depth or less on any substrate: Use machine equipped with exhaust ventilation on drum enclosure and supplemental water sprays designed to suppress dust machine to minimize dust emissions OR: Use a machine equipped with supplemental water spray designed to suppress dust. Water must be combined with a surfactant machine to minimize dust emissions (xvi) Crushing machines Use equipment designed to deliver water spray or mist for dust suppression at crusher and other points where dust is generated (e.g., hoppers, conveyers, sieves/sizing or vibrating components, and discharge points) machine in accordance with Use a ventilated booth that provides fresh, climate-controlled air to the operator, or a remote (xvii) Heavy equipment and utility vehicles used control station Operate equipment from within an enclosed cab

12 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, or fracturing silica-containing materials When employees outside of the cab are engaged in the task, apply water and/or dust suppressants as necessary to minimize Apply water and/or dust suppressants as necessary to minimize dust emissions OR: When the equipment operator is the only employee engaged in the task, operate equipment from within an enclosed cab Section 5 - Non-Specified Exposure Control When activities are planned that could cause respirable crystalline silica exposures and are not defined in the specified exposure control section, evaluation of these activities will need to be reviewed and monitored for exposure levels. Monitoring of these activities will be done in accordance to OSHA General Standard 29 CFR and Construction Standard 29 CFR for the effectiveness of exposure controls and work practices in the reduction and protection against respirable crystalline silica dust. Section 6 -Product Substitution All departments that use materials that can produce respirable crystalline silica dust during their intended purpose should consider substitution of materials with products that do not contain crystalline silica and that can still achieve the desired application of the previous material. Departments should inventory items that contain crystalline silica and may produce respirable crystalline silica dust and seek substitutions for these products if feasible.

13 Section 7 - Respiratory Protection When respiratory protection is required, all affected workers will: Receive appropriate training on respiratory protection, including the contents of OSHA s Respiratory Protection Standard, and proper respirator selection, use, maintenance, storage; Complete a medical evaluation and been approved to work while wearing a respirator; and, Complete fit testing procedures that have established an appropriate size, brand, and style of respirator for adequate protection from overexposure to respirable crystalline silica while performing designated tasks. Employees that wear a respirator due to crystalline silica dust exposure for more than 30 days in a calendar year will have to undergo medical monitoring by university occupational health doctors. Section 8 - Monitoring 8.1 Alternative Exposure Control Methods For tasks not listed in Table 1 Specified Exposure Control Methods, or where the employer does not fully and properly implement the engineering controls, work practices, and respiratory protection described in Table 1, alternative exposure control procedures will need to be created to ensure that no employee is exposed to an airborne concentration of respirable crystalline silica in excess of 50 μg/m3, calculated as an 8-hour TWA. The tasks to be performed will be reviewed to develop a procedure for alternative mean(s) of protecting the workers and limiting the amount respirable crystalline silica exposure. After the development of the procedure if an employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level, then the task will be assessed in accordance with either the performance option or the scheduled monitoring option in accordance with OSHA standard 29 CFR and Construction Standard 29 CFR The procedure should be reviewed with all affected employees before the task is started. 8.2 Performance Option An 8-hour TWA exposure assessment shall be performed for each employee on the basis of any combination of air monitoring data or objective data sufficient to accurately characterize employee exposures to respirable crystalline silica.

14 8.3 Scheduled Monitoring Option Initial monitoring shall be performed to assess the 8-hour TWA exposure for each employee on the basis of one or more personal breathing zone air samples that reflect the exposures of employees. Where several employees perform the same tasks on the same shift and in the same work area, the employer may sample a representative fraction of these employees in order to meet this requirement. Sampling shall be performed on the employee(s) who are expected to have the highest exposure to respirable crystalline silica. If initial monitoring indicates that employee exposures are below the action level, monitoring will be discontinued for those employees whose exposures are represented by such monitoring. Where the most recent exposure monitoring indicates that employee exposures are at or above the action level but at or below the PEL, monitoring shall be repeated within six months of the most recent monitoring. Where the most recent exposure monitoring indicates that employee exposures are above the PEL, monitoring shall be repeated within three months of the most recent monitoring. Where the most recent (non-initial) exposure monitoring indicates that employee exposures are below the action level, monitoring will be repeated within six months of the most recent monitoring until two consecutive measurements, taken seven or more days apart, are below the action level, at which time monitoring can be discontinued for those employees whose exposures are represented by such monitoring. 8.4 Reassessment of Exposures Exposures will need reassessed whenever a change in the production, process, control equipment, personnel, or work practices may reasonably be expected to result in new or additional exposures at or above the action level, or if it is believed that new or additional exposures at or above the action level have occurred. All sampling reports will be shared with the employees within fourteen days of receiving the results. Section 9 - Housekeeping Department managers shall not allow dry sweeping or dry brushing where such activity could contribute to employee exposure to respirable crystalline silica: Use Wet Sweeping Use HEPA-Filtered Vacuuming Department supervisors shall not allow compressed air to be used to clean clothing or surfaces where such activity could contribute to employee exposure to respirable crystalline silica.

15 Section 10 - Training Employees performing tasks that have the potential to be exposed to respirable silica will need to be trained in: Silica Exposure Control Plan Hazards of Silica Exposure control equipment and procedures Section 11 - Recordkeeping 11.1 Monitoring Records Monitoring records shall be maintained by Environmental Health and Safety and distributed to affected employees and supervisors Training Records Training records shall be maintained by the employee s department and also retained by Environmental Health and Safety Review of this written Silica Exposure Control Plan will occur annually for effectiveness and updated as necessary.