OSHA S NEW FINAL RULE ON CRYSTALLINE SILICA: WHAT YOU NEED TO KNOW 29 CFR

Transcription

1 Proactive By Design. Our Company Commitment OSHA S NEW FINAL RULE ON CRYSTALLINE SILICA: WHAT YOU NEED TO KNOW 29 CFR Mike McCoy, M.S., CIH, CSP Senior Industrial Hygienist Page 1

2 Learning Objectives Why should we care about Silica? History of Silica as an Occupational Disease Important Dates for Compliance Applicable Activities in Oil and Gas How to Comply: Specified Exposure Controls Table 1 Alternative Exposure Controls Housekeeping Written Exposure Plan Medical Surveillance Hazard Communication Recordkeeping Page 2

3 Question of the Day VS. Page 3

4 Why do we care? Page 4

5 Silicosis Chronic silicosis: years of moderate to low exposures to respirable crystalline silica. Chest x-ray to determine lung damage. Shortness of breath when exercising and poor oxygen/carbon dioxide exchange Later stages, fatigue, extreme shortness of breath, cough, and, in some cases, respiratory failure. Accelerated silicosis: 5 10 years of high exposures to respirable crystalline silica. It is similar to chronic silicosis, but progresses more rapidly. Acute silicosis: Few months or a few years to extremely high levels of respirable crystalline silica. Rapidly progressive, severe shortness of breath, weakness, and weight loss. Page 5

6 History 1930s, the Hawk s Nest Tunnel near Gauley Bridge, West Virginia Hundreds of workers died from silicosis while building the tunnel Another 1,500 were reported to have contracted the disease within two years of working on the project. Tragedy brought recognition of acute silicosis as occupational lung disease and onset of legislation to protect workers. Page 6

7 History Walsh Healey Act, 1936 (predecessor to OSHA) Sets labor and project health and safety standards for Gov t contractors Occupational Safety and Health Administration, 1970 Primary federal law which governs occupational safety and health. Existing Permissible Exposure Limit (PEL): PEL=10 mg/m 3 / (% silica + 2), as respirable dust Approximately 100 micrograms per cubic meter or air (μg/m 3 ) New Action Level / PEL: Action Level of 25 μg/m 3 PEL of 50 μg/m 3, Both calculated as an 8-hour TWA Silicosis, lung cancer, chronic obstructive pulmonary disease (COPD), kidney disease and activation of a latent TB infection Page 7

8 New Silica Rule About 2.3 million workers are exposed to respirable crystalline silica in their workplaces. 2 million construction workers who drill, cut, crush, or grind silicacontaining materials such as concrete and stone. 300,000 workers in general industry operations such as brick manufacturing, foundries, and hydraulic fracturing, also known as fracking. OSHA estimates that the rule will: Save over 600 lives and prevent more than 900 new cases of silicosis each year, once its effects are fully realized. The Final Rule is projected to provide net benefits of about $7.7 billion, annually. Page 8

9 How much is 50 micrograms per cubic meter? 500 µg silica in photo New standard is 50 µg per cubic meter of air. One cubic meter is 1000 Liters of air. 500, 2-liters bottles of air with 10% of the silica in picture Source: Page 9

10 Compliance Dates (1) New silica standard ( Respirable Crystalline Silica) became effective June 23, (2) Construction - September 23, (3) Maritime and General Industry June 23, (4) Hydraulic Fracturing June 23, 2018, for all provisions except Engineering Controls which have a compliance date of June 23, The dates may change so keep an eye on Page 10

11 NIOSH Study In cooperation with oil and gas industry partners, NIOSH collected 116 full shift air samples at 11 hydraulic fracturing sites in five states (Arkansas, Colorado, North Dakota, Pennsylvania, and Texas) to determine the levels of worker exposure to silica at various jobs Of the 116 samples collected: 47% showed silica exposures greater than the calculated OSHA PEL. 79% showed silica exposures greater than the NIOSH REL of 0.05 milligrams per cubic meter (mg/m 3 ). 9% of all samples showed silica exposures 10 or more times the PEL, with one sample more than 25 times the PEL. 31% of all samples showed silica exposures 10 or more times the REL, with one sample more than 100 times the REL. Source: Page 11

12 Applicability to Oil and Gas Sand is delivered via truck and then loaded into sand movers. Transferred via conveyer belt and blended with other hydraulic fracturing fluids prior to high pressure injection into the drilling hole. Transporting, moving, and refilling silica sand into and through sand movers, along transfer belts, and into blender hoppers can release dusts containing silica into the air. Page 12

13 Applicability to Oil and Gas Page 13

14 Applicability to Oil and Gas NIOSH Study: 8 Primary Points of Dust Generation 1. Release from top hatches, sand movers 2. Transfer belt under sand movers 3. Site traffic 4. Sand dropping in blender hopper 5. Release from T belt operations 6. Release from dragon tail 7. Dust ejected from fill ports on sand movers 8. Release from work uniforms Source: Page 14

15 Applicability to Oil and Gas Page 15

16 Which Path Can You Choose? Alternative Exposure Control PEL and Action Limit Applies Preferred Pathway Specified Exposure Control Review Table 1 Exposure Assessment Engineering/Administrative Controls Silica Program Compliance Equipment/Task Controls/PPE Sampling Required Written Exposure Control Plan. Medical monitoring. Training. Respiratory Protection. Sampling Not Required Page 16

17 Compliance- Specified Exposure Control Page 17

18 Compliance- Specified Exposure Control Page 18

19 Compliance- Specified Exposure Control Page 19

20 Compliance- Specified Exposure Control PREFERED No additional monitoring required. Page 20

21 Compliance- Specified Exposure Control Table 1 The Fine Print When implementing the control measures specified in Table 1, each employer shall: For tasks performed indoors or in enclosed areas, provide a means of exhaust as needed to minimize the accumulation of visible airborne dust; For tasks performed using wet methods, apply water at flow rates sufficient to minimize release of visible dust; Page 21

22 Compliance- Specified Exposure Control Table 1 The Fine Print For measures implemented that include an enclosed cab or booth, ensure that the enclosed cab or booth: (A) Is maintained as free as practicable from settled dust; (B) Has door seals and closing mechanisms that work properly; (C) Gaskets and seals that are in good condition and working properly; (D) Is under positive pressure maintained through continuous delivery of fresh air; (E) Has intake air that is filtered through a filter that is 95% efficient in the μm range (not quite HEPA); and (F) Has heating and cooling capabilities. Page 22

23 Compliance- Specified Exposure Control Table 1 The Fine Print Where an employee performs more than one task on Table 1 during the course of a shift, and the total duration of all tasks combined is more than four hours, the required respiratory protection for each task is the respiratory protection specified for more than four hours per shift. If the total duration of all tasks on Table 1 combined is less than four hours, the required respiratory protection for each task is the respiratory protection specified for less than four hours per shift. Page 23

24 Compliance- Specified Exposure Control 3 HRS 3 HRS But what happens if we can t Comply with Table 1? Page 24

25 Compliance- Alternative Exposure Control Page 25

26 Compliance- Alternative Exposure Control Alternative exposure control methods. For tasks not listed in Table 1, or where the employer does not fully and properly implement the engineering controls, work practices, and respiratory protection described in Table 1: (1) Permissible exposure limit (PEL). The employer shall ensure that no employee is exposed to an airborne concentration of respirable crystalline silica in excess of 50 μg/m 3, calculated as an 8-hour TWA. (2) Exposure assessment The employer shall assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level in accordance with either the performance option or the scheduled monitoring option. Page 26

27 Compliance- Alternative Exposure Control Exposure Assessment Performance option. The employer shall assess the 8-hour TWA exposure for each employee on the basis of any combination of air monitoring data or objective data. Scheduled monitoring option. The employer shall perform initial monitoring 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 on each shift, for each job classification, in each work area. Reassessment of Exposures. The employer shall reassess exposures 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 when the employer has any reason to believe that new or additional exposures at or above the action level have occurred. Page 27

28 Compliance- Alternative Exposure Control The employer shall use engineering and work practice controls to reduce and maintain employee exposure to respirable crystalline silica to or below the PEL, unless the employer can demonstrate that such controls are not feasible. Wherever such feasible engineering and work practice controls are not sufficient to reduce employee exposure to or below the PEL, the employer shall nonetheless use them to reduce employee exposure to the lowest feasible level and shall supplement them with the use of respiratory protection. Page 28

29 Compliance- Alternative Exposure Control Employee notification of assessment results. (A) Within five working days after completing an exposure assessment. (B) Whenever an exposure assessment indicates that employee exposure is above the PEL, the employer shall describe in the written notification the corrective action being taken to reduce employee exposure to or below the PEL. Page 29

30 Compliance- Housekeeping (1) The employer shall not allow dry sweeping. HEPA-filtered vacuuming or other methods that minimize the likelihood of exposure. (2) The use of compressed air is prohibited to clean clothing or surfaces unless: (i) The compressed air is used in conjunction with a ventilation system; or (ii) No alternative method is feasible. Page 30

31 Compliance- Demarcation Demarcation: The employer shall demarcate regulated areas from the rest of the workplace in a manner that minimizes the number of employees exposed to respirable crystalline silica within the regulated area. Page 31

32 Compliance- Written Exposure Control Plan The employer shall establish and implement a written exposure control plan that contains at least the following elements: (i) (ii) (iii) (iv) A description of the tasks in the workplace that involve exposure to respirable crystalline silica; A description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task; A description of the housekeeping measures used to limit employee exposure to respirable crystalline silica; and A description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed to respirable crystalline silica and their level of exposure, including exposures generated by other employers or sole proprietors. Page 32

33 Compliance- Previously Implemented Plans Medical surveillance DONE! Training Always ongoing in Oil and Gas! Respiratory Protection DONE! How then, do we assess the occupational exposure to crystalline silica? Call a CIH (me preferably) Page 33

34 Summary and Take Away Silicosis is a deadly disease with poor prognosis in advanced disease. Remember the Arrows. Which pathway should I choose? Specified Exposure Control (Table 1) or Alternative Exposure Control Specified Exposure Control (Table 1). Job tasks, tools and duration of exposure. Select correct PPE for job task, tools and duration. Alternative Exposure Control. Exposure assessment. Engineering, administrative controls before PPE. What is feasible and what you SHALL do. Written Exposure Control Plan. Medical monitoring and training. Respiratory Protection. Page 34

35 Questions?? Page 35

36 RESPIRABLE SILICA MONITORING Proactive By Design. Our Company Commitment Mike McCoy, M.S., CIH, CSP Senior Industrial Hygienist Page 36

37 Learning Objectives Human respiratory system Particle size and size-selective sampling Laboratory requirements Methods for sampling for crystalline silica Real time sampling for airborne dusts Silica sampling case study Page 37

38 Very Important Question Which of the below was the number one Google search result for Who is the mascot of the Pittsburgh Steelers? A. B. C. Page 38

39 Compliance- Employee Exposure Monitoring Q: So Mike, can we throw a sampling pump and a cyclone or one of those button sampler thingy's on our guys? Page 39

40 Compliance- Employee Exposure Monitoring Possible Outcomes of Poorly Performed Silica Sampling Under detection (Negatively Biased Samples) Worker illness/injury, regulatory compliance failure, future legal implications False sense of security Over detection (Positively Biased Samples) Economic costs, additional PPE burden, added cost of unneeded regulatory compliance, unneeded controls Unneeded worker anxiety Page 40

41 Particle Deposition in Lungs Proactive By Design. Our Company Commitment Aerodynamic diameter Page 41

42 Proactive By Design. Our Company Commitment Page 42

43 Proactive By Design. Our Company Commitment µm (microns) Page 43

44 Compliance- Employee Exposure Monitoring Respirable dust SKC aluminum cyclone. Flow rate is critically important. 2.5 LPM Calibration! Cannot be inverted during wearing or handling. Page 44

45 Compliance- Employee Exposure Monitoring Parallel Particle Impactors (PPI): -2 LPM for 8-hour TWA (beige) -4 LPM for > 4-hour (green) -8 LPM for short-term and low concentration sampling (red) Respirable PPI Samplers match ACGIH and the ISO 7708/CEN criteria that is specified in the 2016 OSHA final rule on respirable crystalline silica. Page 45

46 Compliance- Employee Exposure Monitoring Evaluate all samples using the procedures specified in one of the following analytical methods: OSHA ID-142; NIOSH Manual of Analytical Methods (NMAM) 7500; NMAM 7602; NMAM 7603; MSHA P-2; or MSHA P-7 Page 46

47 Compliance- Employee Exposure Monitoring TSI: DUSTTRAK II Aerosol Monitor 8530 Desktop battery-operated, data-logging, light-scattering laser photometer that gives you real-time aerosol mass readings Additional uses Attachment cassette for silica Other aerosol sampling Diesel particulate attachment Measures aerosol concentrations PM 1 PM 2.5 Respirable, PM 4 PM 10 Flow rate 1.5 to 4.0 L/min Range to 400 mg/m 3 Page 47

48 Silica Case Study Sand mining operation, bagging facility Workers had 8-hour TWA silica over the new PEL. Bagging operations were less than 2 hours per day Other work performed by worker did not include significant silica exposure Page 48

49 Silica Case Study Bagging work includes: Task 1 Emptying the Sand Hopper Task 2 Bag Filling Are there specific tasks that may contribute to the total respirable silica exposure? Short term peak exposures may get lost in 8 hr sampling. Worker may not perform this specific task during routine sampling. Ask questions! Page 49

50 Silica Case Study Personal Sampling Real Time Sampling Page 50

51 Silica Case Study Task 1 Page 51

52 Silica Case Study Task 1 Average Respirable = mg/m 3 Sample Duration = 1 hr 24 minutes Spikes account for approximately 12 minutes of the sampling period ~15% Page 52

53 Silica Case Study Task 1 Following Statistics can be downloaded from the DUSTTRAK : Channel: PM1 PM2.5 RESP, PM 4 PM10 TOTAL Units: mg/m^3 mg/m^3 mg/m^3 mg/m^3 mg/m^3 Average: Minimum: Time of Minimum: 10:30:06 10:30:06 10:30:06 10:30:06 10:30:06 Maximum: Time of Maximum: 10:18:36 10:18:36 10:18:36 10:18:36 10:18:36 TWA (8hr) Page 53

54 Silica Case Study Page 54

55 Silica Case Study Task 2 Average Respirable =0.906 mg/m 3 Average Total =1.48 mg/m 3 Sample Duration = 1 hr 27 minutes Spikes account for approximately 20 minutes of the sampling period 23% Page 55

56 9:44:06 AM 9:48:36 AM 9:53:06 AM 9:57:36 AM 10:02:06 AM 10:06:36 AM 10:11:06 AM 10:15:36 AM 10:20:06 AM 10:24:36 AM 10:29:06 AM 10:33:36 AM 10:38:06 AM 10:42:36 AM 10:47:06 AM 10:51:36 AM 10:56:06 AM 11:00:36 AM 11:05:06 AM 1:04:32 PM 1:09:02 PM 1:13:32 PM 1:18:02 PM 1:22:32 PM 1:27:02 PM 1:31:32 PM 1:36:02 PM 1:40:32 PM 1:45:02 PM 1:49:32 PM 1:54:02 PM 1:58:32 PM 2:03:02 PM 2:07:32 PM 2:12:02 PM 2:16:32 PM 2:21:02 PM 2:25:32 PM (blank) Dust Concentration (mg/m 3 ) Silica Case Study Full Day 20 Real Time Monitoring of Respirable Dust Average Time Sample #1 Sample #2 Page 56

57 Silica Case Study Identify specific job tasks Measure the maximal level during specific tasks If the worker performed the task for their entire 8hr shift (worst case scenario) exceeds new AL/PEL Can we eliminate or modify tasks? Applied to Oil and Gas, if you exceed the action level on routine sampling Use the spikes to identify the specific task or operation and administer the proper controls Page 57

58 9:44:06 AM 9:48:36 AM 9:53:06 AM 9:57:36 AM 10:02:06 AM 10:06:36 AM 10:11:06 AM 10:15:36 AM 10:20:06 AM 10:24:36 AM 10:29:06 AM 10:33:36 AM 10:38:06 AM 10:42:36 AM 10:47:06 AM 10:51:36 AM 10:56:06 AM 11:00:36 AM 11:05:06 AM 1:04:32 PM 1:09:02 PM 1:13:32 PM 1:18:02 PM 1:22:32 PM 1:27:02 PM 1:31:32 PM 1:36:02 PM 1:40:32 PM 1:45:02 PM 1:49:32 PM 1:54:02 PM 1:58:32 PM 2:03:02 PM 2:07:32 PM 2:12:02 PM 2:16:32 PM 2:21:02 PM 2:25:32 PM (blank) Dust Concentration (mg/m 3 ) Silica Case Study Real Time Monitoring of Respirable Dust Task #1 Task #2 Average Time Page 58

59 Silica Case Study Percent Silica 37-51% Sample #1 Sample #2 8-hour TWA silica concentration for employee was mg or 63 µg/m 3 or 126% of the PEL. Page 59

60 Silica Case Study Two tasks/operations were identified as causing spikes in the dust real time monitoring Task #1: Emptying the hopper Task #2: dropping pallet/filling bag Implement engineering controls during these operations Require PPE during specific tasks Worker does not typically perform these tasks for the duration of an 8hr shift or on a daily basis Protect against Worst Case Scenario If this occurred implement a Work Rule For example: if a worker is going to be emptying the hopper for an extended period PPE must be worn. Page 60

61 Silica Case Study Task based real time monitoring provides useful information in identifying potential exposures Supplement routine sampling with real time monitoring results Focus resources Results are instantaneous! Feasibility Real time monitor was easy to transport and operate Proactive Tool Overall employee health and moral Limitations Does not replace regulatory sampling Expense Page 61

62 Summary and To-Do List! 1. Carefully Evaluate Work Tasks with Potential Silica Exposure 2. Revisit prior silica sampling data vs. new PEL and Action Limits (50 and 25 µg/m 3, respectively) 3. Review Table 1 for Work Equipment/Tasks 4. Does Alternative Exposure Control Apply? 5. Assess Exposure via Sampling 6. Prepare a Written Exposure Control Plan 7. Update your Respiratory Protection Program 8. Review Respiratory Protection Page 62

63 Contact me with Questions! Michael McCoy, CIH, CSP Swenson Dr., Suite 150, Waukesha, WI Cell: Page 63