The New OSHA Silica Standard

Transcription

1 The New OSHA Silica Standard What do you need to know? March 17, 2017 Robyn Steiner, MSPH CIH CSP

2 Agenda What is Silica? Silica Exposure Health Effects OSHA regulations old and new Controls and other requirements Questions

3 What is Silica? Silica is a very common material SiO 2 silica combines with oxygen to form silicon dioxide or crystalline quartz 3 mineralogical forms Quartz most common Cristobalite Tridymite

4 It s not just dust It s silica

5 Major component of soils and readily found in rock Granite ~30% quartz Shale ~20% quartz Beach sand nearly pure quartz Crystalline Silica

6 Industries with potential for silica exposure electronics foundries ceramics, clay, pottery, stone, and glass construction agriculture Maritime road construction concrete products railroad slate and flint quarrying and crushing use and manufacture of abrasives mining countertop manufacturing roofing foundries dental laboratories

7 Occurrence and Use Airborne silica is produced by: sandblasting rock drilling foundry work stone cutting drilling quarrying tunneling jack hammering concrete manufacturing demolition asphalt pavement manufacturing

8 Workers and Industries Affected (estimated) 2.3 million workers: Construction: 2 million General Industry/Maritime: 300, ,000 establishments Construction: 600,000 General Industry/Maritime: 76,000 And even more in Mining.

9 What are the Hazards of Crystalline Silica? Crystalline silica has been classified as a human lung carcinogen. The respirable silica dust enters the lungs and causes the formation of scar tissue, thus reducing the lungs ability to take in oxygen. There is no cure. In addition, smoking causes lung damage and adds to the damage caused by breathing silica dust.

10 Health Effects of Crystalline Silica Silicosis Chronic, accelerated, acute A continuing problem Lung cancer Tuberculosis Chronic obstructive pulmonary disorder Other Immunologic disorders and autoimmune diseases Renal disease Stomach and other cancers

11 What is silicosis? A disabling and often fatal lung disease caused by breathing very small respirable particles of crystalline silica >14,000 deaths since 1968 >200 deaths each year in the U. S.

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13 Silicosis Chronic/Classic Occurs after years of moderate to low exposure Accelerated Occurs after 5 10 years of high exposures Acute Occurs after a few months or as long as 2 years to extremely high concentrations

14 Symptoms and Signs of Chronic Silicosis NOTE: There may be no symptoms in the early stages. As the disease progresses Cough Breathlessness Weakness Significant X-ray changes after years of exposure

15 Other Health Effects of Silica Exposure Lung cancer IARC Group 1: Carcinogenic to Humans Tuberculosis Chronic Obstructive Pulmonary Disorder Bronchitis, Emphysema Immunologic Disorders & Autoimmune Disease Renal Disease

16 Symptoms of Related Illnesses (such as Tuberculosis) Fever Weight loss Night sweats Chest pains Respiratory failure These symptoms can become worse over time, leading to death.

17 Why Target Crystalline Silica Exposure? Widespread occurrence and use Number of related deaths Number of exposed workers Health effects PEL established in 1971!

18 Definitions: Crystalline Silica - A common mineral found in many naturally occurring materials and used in many industrial products. Sand, concrete, stone, mortar, glass, pottery, ceramics, bricks contain crystalline silica. Respirable - Particles in the air able to be breathed in. Competent Person An individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them.

19 Definitions: Employee Exposure - The exposure to airborne respirable crystalline silica that would occur if the employee were not using a respirator. High-Efficiency Particulate Air (HEPA) Filter - A filter that is at least percent efficient in removing mono-dispersed particles of.3 micrometers in diameter. 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.

20 Old Permissible Exposure Limit (PEL) For General Industry: Quartz (respirable dust): 10 mg/m3 % respirable quartz + 2 Cristobalite and Tridymite: use ½ of the value calculated from the formula for quartz

21 OSHA New Silica Standard: Final Rule Published on March 25, 2016

22 Reasons for the New Rule Previous permissible exposure limits (PELs) were formulas that many found hard to understand General industry formula PEL was about equal to 100 µg/m 3 or 0.1 mg/m 3 while construction/ shipyard formulas were about 250 µg/m 3 or 0.25 mg/m 3

23 Most Important Reasons for the New Rule Previous PELs did not adequately protect workers Exposure to respirable crystalline silica has been linked to: Silicosis Lung cancer Chronic obstructive pulmonary disease Kidney disease Extensive epidemiologic evidence that lung cancer and silicosis occurs at exposure levels below 100 µg/m 3

24 Health Benefits OSHA estimates that once the effects of the rule are fully realized, it will prevent: More than 600 deaths per year Lung cancer: 124 Silicosis and other non-cancer lung diseases: 325 End-stage kidney disease: 193 More than 900 new silicosis cases per year

25 PELs for Quartz Old Calculated PELs (General Industry) 10% = 0.83 mg/m 3 25% = 0.37 mg/m 3 50% = 0.19 mg/m 3 75% = 0.13 mg/m 3 100% = 0.1 mg/m 3 New PEL The new standard sets one PEL for quartz regardless of percentage: Action Limit of mg/m 3 PEL of 0.05 mg/m 3

26 Respirable Crystalline Silica Rule Two standards: One for general industry and maritime One for construction Similar to other OSHA health standards and ASTM consensus standards

27 General Industry/Maritime - Scope All occupational exposures to respirable crystalline silica are covered, unless objective data shows exposures remain below 25 µg/m 3 as an 8-hr TWA under any foreseeable conditions. Agricultural operations and exposures resulting from processing of sorptive clays are not covered. General industry employers can follow the construction standard in some very limited circumstances.

28 General Industry Standard Measure the amount of silica that workers are exposed to if it may be at or above an action level of 25 μg/m3 (micrograms of silica per cubic meter of air), averaged over an 8-hour day. Protect workers from respirable crystalline silica exposures above the permissible exposure limit of 50 μg/m3, averaged over an 8-hour day. Limit workers access to areas where they could be exposed above the PEL. Use dust controls to protect workers from silica exposures above the PEL. Provide respirators to workers when dust controls cannot limit exposures to the PEL.

29 General Industry Standard Cont. Restrict housekeeping practices that expose workers to silica where feasible alternatives are available. Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers. Offer medical exams including chest X-rays and lung function tests every three years for workers exposed at or above the action level for 30 or more days per year. Train workers on work operations that result in silica exposure and ways to limit exposure. Keep records of workers silica exposure and medical exams.

30 General Industry Compliance Dates Employers are required to comply with all obligations of the standard, with the exception of the action level trigger for medical surveillance, by June 23, Employers are required to offer medical examinations to employees exposed above the PEL for 30 or more days a year beginning June 23, Employers are required to offer medical examinations to employees exposed at or above the action level for 30 or more days a year beginning June 23, 2020.

31 Exposure Assessment Required if exposures are or may reasonably be expected to be at or above action level of 25 µg/m 3 Exposures assessments can be done following: The performance option Exposures assessed using any combination of air monitoring data or objective data sufficient to accurately characterize employee exposure to respirable crystalline silica

32 Objective Data Includes 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

33 Exposure Assessment The scheduled monitoring option Prescribes 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

34 PERSONAL SAMPLING

35 AIR SAMPLING EQUIPMENT Personal Air Pump with Cyclone

36 Section View of the Cyclone and Respirable Dust Filter

37 Appendix A Methods of Sample Analysis Employers must ensure that samples are analyzed by a laboratory that follows the procedures in Appendix A Appendix A specifies methods of sample analysis Allows for use of OSHA, NIOSH, or MSHA methods Analysis must be conducted by accredited laboratories that follow specified quality control procedures

38 Regulated Areas Required where exposures can reasonably be expected to exceed the PEL Must be demarcated in any manner that limits workers in the area Must post warning signs at entrances Respirator use required

39 Methods of Compliance Hierarchy of Controls Employers can use any engineering or work practice controls to limit exposures to the PEL Respirators permitted where PEL cannot be achieved with engineering and work practice controls

40 Ways to Reduce Exposure Substitute materials that have no crystalline silica Locate employees as far as possible from dust-generation source Isolate employees OR the source Control rooms Enclosures Barriers Use local exhaust ventilation (LEV systems) Use tools with dust-collecting systems

41 Ways to Reduce Exposure (cont d) Use wet methods Cutting Chipping Drilling Sawing Grinding Clean surfaces with HEPA vacuums or wet sweeping no compressed air!

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

43 Engineering Controls (cont.) Grinding without engineering controls Grinding using a vacuum dust collector

44 Example of a Combination of Controls Source: What Dental Technicians Need to Know About Silicosis. NJDHSS.

45 Ways to Reduce Exposure (cont d) And if other methods are not sufficient Use Proper Respiratory Protection

46 Written 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

47 Medical Surveillance Employers must offer medical examinations to workers who will be exposed above the action level for 30 or more days a year Employers must offer examinations every three 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)

48 Communication of Hazards Employers required to comply with hazard communication standard (HCS) (29 CFR ) 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.

49 Construction Scope All occupational exposures to respirable crystalline silica are covered, unless employee exposure will remain below 25 μg/m 3 as an 8- hr TWA under any foreseeable conditions.

50 Construction Standard The standard requires employers to limit worker exposures to respirable crystalline silica and to take other steps to protect workers. Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur. Designate a competent person to implement the written exposure control plan. Restrict housekeeping practices that expose workers to silica where feasible alternatives are available.

51 Construction Standard Cont. Offer medical exams, (including chest X-rays and lung function tests), every three years for workers who are required by the standard to wear a respirator for 30 or more days per year. Train workers on work operations that result in silica exposure and ways to limit exposure. Keep records of workers silica exposure and medical exams.

52 Construction Competent Person Construction employers must designate a competent person to implement the written exposure control plan Competent person is an individual capable of 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

53 Construction 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

54 List of Table 1Entries 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 standmounted 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 (tuckpointing) Handheld grinders for other than mortar removal 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

55 Example of a Table 1 Entry Equipment / Task Stationary masonry saws Engineering and Work Practice Control Methods 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. Required Respiratory Protection and Minimum APF 4 > 4 hr/shift hr/shift None None

56 Example of a Table 1 Entry Equipment / Task 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. Operate and maintain tool in accordance with manufacturers instruction to minimize dust - When used outdoors - When used indoors or in an enclosed area Required Respiratory Protection and Minimum APF 4 > 4 hr/shift hr/shift None APF 10 APF 10 APF 10

57 Construction Compliance Dates Employers are required to comply with all obligations of the standard (except methods of sample analysis) by June 23, Employers are required to comply with methods of sample analysis by June 23, 2018.

58 Guidance and Outreach Silica Rulemaking Webpage: Fact sheets FAQs Video Appendix B Medical Surveillance Guidelines OSHA s silica rule can be found at: Regulatory text for construction standard, with complete Table 1:

59 Questions?

60 Thank you! -The Members of the ATC Team The new OSHA Silica Standard

61 Ms. Robyn Steiner has more than twenty years of professional problem-solving experience as a health, safety, and industrial hygiene professional providing comprehensive industrial hygiene and safety services to a wide variety of clients and industries. Ms. Steiner has investigated complex indoor air quality, mold, and industrial hygiene concerns for industrial, construction, commercial, and municipal clients in manufacturing, construction, office, and residential settings. She has developed and executed exposure monitoring programs to assure compliance with local, state, and federal regulations and guidelines governing exposure to chemicals such as lead, cadmium, hexavalent chromium, and ethylene oxide along with physical stressors such as heat and noise. In addition, she has testified as an expert witness in Arizona on microbial and workers compensation claims. Ms. Steiner has a Master s Degree in Public Health, emphasis Industrial Hygiene, from San Diego State University. She has been certified in the comprehensive practice of industrial hygiene since 1997 and in the comprehensive practice of safety since Ms. Steiner has previously worked for San Diego State University, Rohr Inc., Karsten Manufacturing (Ping golf clubs), Cable Systems International, Belden Communications Division, and IHI Environmental. Ms. Robyn Steiner is currently the Principal Industrial Hygienist/Industrial Hygiene Department Manager for ATC Group Services LLC in Tempe, Arizona and may be contacted at or robyn.steiner@atcassociates.com. INTRO: Ms. Robyn Steiner is a CIH and CSP with over 20 years of experience as an environmental, health and safety professional, currently working for ATC Group Services LLC in Tempe, Arizona. She has worked with public and private industry, government agencies and construction firms to address their health and safety issues. Today, she will be presenting information on the continuing asbestos legacy and why we still need to be concerned.