3/28/2018. Session #14 Silica The Next Steps. Course Objectives. At the end of this session, you should be able to: Environmental

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1 Environmental Session #14 Silica The Next Steps WSC Safety & Health Conference April 17, 2018 Brian J. Harms, P.E. (WI), CIH 1 Course Objectives At the end of this session, you should be able to: Have an understanding of OSHA s new Silica Rule Understand the next steps for your facility Have some tools utilizing real time instruments for performing root cause analysis of the exposure sources Page 2 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 3 1

2 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 occur 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 4 Background DIRECTIVE NUMBER: CPL 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 of silicosis include sandblasting, sand casting foundry operations, mining, tunneling, cement cutting and demolition, masonry work, and granite cutting. nt?p_table=directives&p_id=3790 Photo courtesy of sessler.cm.utexas.edu 5 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) 6 2

3 Understanding the Silica Rule Existing OSHA PEL until June 23, 2018 ( Table Z 3) Resp. PM PEL = 10 / (% Quartz + 2) [MSHA still to use this] Cut in half for Cristobalite and Tridymite Example Results: 0.80 mg/m 3 respirable PM; 18% Quartz or 0.14 mg/m 3 of Quartz PEL Calculation = Resp. PM PEL = 10 / (18 + 2) = 0.5 mg/m 3 Result of 0.80 mg/m 3 is greater than 0.5 mg/m 3 and is over the existing PEL for Respirable PM containing silica. Page 7 Understanding the Silica Rule New Rule 29 CFR Industry New Rule 29 CFR Construction Removes formula, new PEL would be mg/m 3 ; action level would be mg/m 3 as Silica, not Respirable PM Page 8 Construction Specific Small Entity Guide for Compliance with the Respirable Crystalline Silica Standard Construction An employer has two options for limiting employee exposure to respirable crystalline silica: Specified exposure control methods; or Alternative exposure control methods. 9 3

4 Construction Specific 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. 10 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) Photo courtesy of (xii) Handheld grinders for uses other than mortar removal 11 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, or fracturing silica containing materials. Photo courtesy of iqpowertools.com 12 4

5 Initial Monitoring Review Ventilation & Existing Conditions (Is everything working?) Full Shift Sampling Root Cause Analysis Engineering and/or Work Practice Controls Photo courtesy of AFS Silica Control Manual 13 Conduct Initial Monitoring Initial exposure assessment either through Air Monitoring or a new Performance Option Identify activities that have potential silica exposure (Crystalline Silica Quartz, Cristobalite, Tridymite) Amorphous Silica is not part of this rule. Conduct 8 hour employee exposure sampling to determine if any positions are above the new PEL or Action Level Performance Option Can be tricky, can look at historical data and process configurations to make assessment. OSHA may sample anyway. Page 14 Amorphous Silica Note Amorphous Silica Not Part of the Rule, however for those that use Ceramics such as Lost Foam or Lost Wax or Refractories with Amorphous Silica please be aware of possible transformation to cristobalite: The formation of cristobalite at C from amorphous silicic acid and silica gel adds credence to this proposal. The absence of tridymite when the different SiO 2 materials are heated is noteworthy. More than forty different heating trials were made during the course of our study and not once was any indication of the presence or formation of any tridymite observed.... The absence of the tridymite phase is not unusual in studies of the one component SiO 2 system; in fact, this modification has never been synthesized in the laboratory without the use of mineralizers which introduce foreign ions into the system and thereby result in complex stuffed derivatives. The American Mineralogist, Vol. 46, January February, 1961 Phase Transformations in Silica as Examined by Continuous X Ray Diffraction. F.M. Wahl, R.E. Grim, and R.B. Graf, University of Illinois, Urbana, Illinois 15 5

6 Notes on Sampling 1968 ACGIH Criteria cut point of ~3.5 µm New ISO/CEN Definition cut point of ~4.0 µm particle size collection criteria are also often described by their 50 percent respirable cut size or cut point. This is the aerodynamic diameter at which 50 percent of the particle mass is collected, i.e., the particle size that the sampler can collect with 50 percent efficiency. Particles with a diameter smaller than the 50 percent cut point are collected with an efficiency greater than 50 percent, while larger diameter particles are collected with an efficiency less than 50 percent. The cut point for the 1968 ACGIH specification is 3.5 µm and for the ISO/CEN convention is 4.0 µm pg Federal Register / Vol. 81, No. 58 / Friday, March 25, 2016 / Rules and Regulations Page 16 Cyclone Sampling Discussion Existing rule (and OSHA) typically use Dorr Oliver nylon cyclones, new rule opens it up for other cyclone usage as well. SKC Cyclone ~4 um cut point at 2.5 LPM Dorr Oliver Cyclone ~3.5 um cut point at 1.7 LPM Page 17 Initial Monitoring Rule Applicability If positions are found to be below the Action Level, those positions drop out of the standard (a)(2) Respirable Crystalline Silica This section does not apply where the employer has objective data demonstrating that employee exposure to respirable crystalline silica will remain below 25 micrograms per cubic meter of air (25 μg/m 3 ) as an 8 hour time weighted average (TWA) under any foreseeable conditions. Document These Results in Your Silica Control Plan Page 18 6

7 Employee Notification of Monitoring Results (d)(6) Employee Notification of Assessment Results (d)(6)(i) Within 15 working days after completing an exposure assessment in accordance with paragraph (d) of this section, the employer shall individually notify each affected employee in writing of the results of that assessment or post the results in an appropriate location accessible to all affected employees (d)(6)(ii) 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. 19 Now We Know What Areas to Target Photo courtesy of AFS Silica Control Manual 20 Root Cause Exposure Analysis 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 Photo courtesy of AFS Silica Control Manual Page 21 7

8 Root Cause Exposure Analysis Case Studies Using Real Time Instruments Case Study #1: Mapping Case Study #2: Work Practices Case Study #3: Recirculation Issue Page 22 Case Study #1 Mapping Total Particulate Matter (mg/m 3 ) Page 23 Case Study #2 Work Practices 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. Page 24 8

9 Case Study #3 Work Practices Page 25 Case Study #2 Work Practices 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. Page 26 Case Study #3 Recirculation Issue Figure 3 Historical Silica as Quartz Results Comparison (mg/m 3 ) Respirable Quartz (mg/m 3 ) /18/ /16/2006 Date Shakeout Osborne Mold- Making Wheelabrator Sand Muller 8/16/2006 Employee Location Page 27 9

10 Case Study #3 Recirculation Issue 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. Page 28 Written Silica Exposure Control Plans (f)(2) [Make this tell your story] Employers Must Implement a Written Exposure Control Plan and Review Annually for all tasks that involve potential exposure to crystalline silica. Plans require: (i) A description of the tasks in the workplace that involve exposure to respirable crystalline silica; (ii) a description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task; [Use Your Root Cause Analysis Discussion] (iii) a description of the housekeeping measures used to limit employee exposure to respirable crystalline silica; (iv) for construction, 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 29 Hex Chrome Story Time Make the Written Exposure Plan Work for You Similar Issue When Hex Chrome Became a Standard. Photo courtesy of Galson Labs 30 10

11 Fix the Low Hanging Fruit Respirable Particulate Matter (mg/m3) MAX: 7.01 mg/m3 AVG: 1.55 mg/m3 Broom Sweeping Chart 11 End of Shift Sweeping Powders Room No Sweeping Compound March 8, 2017 Employee Leaves Area and Takes Samples to the Lab Sweeper /Vacuum Truck Enters the Area to Collect Swept up Piles Returns to the Area Sweeper Truck Still Running 0 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 Time 31 Fix the Low Hanging Fruit 10 Chart 3 Sweeping with Sweeping Compound & Auto Sweeper March 7, 2017 Respirable Particulate Matter (mg/m3) Hand Tossing Broom sweeping with compound (Max of 34.8 mg/m3) MAX 34.8 mg/m3 AVG: 0.44 mg/m3 Driving Sweeper w/no Compound 1 0 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 Time 32 Conduct Full Shift Sampling Again Review Ventilation & Existing Conditions (Is everything working?) Full Shift Sampling Root Cause Analysis Engineering and/or Work Practice Controls Photo courtesy of AFS Silica Control Manual 33 11

12 Still Above the PEL Full Rule Required Respiratory Protection Periodic Monitoring Regulated Areas Housekeeping Medical Surveillance Training Engineering & Work Practice Controls 34 Periodic Monitoring Required every 3 months for exposures above the PEL; every 6 months for exposures above the action level, but below the PEL (Requirement Starts September 23, 2017 for Construction and June 23, 2018 for Industry) Need two consecutive sampling rounds with passing results, at least 7 days apart to modify schedule Page 35 Regulated Areas Areas Above the PEL to be Demarcated Signage at Entrances All who enter required to have respirators on DANGER RESPIRABLE CRYSTALLINE SILICA MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS WEAR RESPIRATORY PROTECTION IN THIS AREA AUTHORIZED PERSONNEL ONLY Page 36 12

13 Housekeeping Housekeeping provisions in the rule to apply to situations where dry sweeping, dry brushing or use of compressed air could contribute to employee exposure to respirable crystalline silica. (Regardless of Being Over the PEL or Not) (i) The employer shall not allow dry sweeping or dry brushing where such activity could contribute to employee exposure to respirable crystalline silica unless wet sweeping, HEPA filtered vacuuming or other methods that minimize the likelihood of exposure are not feasible. (ii) The employer 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 unless: (a) The compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air; or (b) No alternative method is feasible Photo Courtesy of Page 37 Compressed Air On Clothing 25 Clothing Blowoff Time Figure 9 Kiln Attendant Clothing Blowoff 20 Average: 1.40 mg/m 3 Total Dust mg/m Walking Outside Back to Lunch :24:58 13:26:24 13:27:50 13:29:17 13:30:43 13:32:10 13:33:36 13:35:02 Time 38 Medical Surveillance Required for each employee who will be occupationally exposed to respirable crystalline silica at or above the action level for 30 or more days per year. Due June 30, 2018 for those above the PEL & Every 3 Years (Make Sure Your Medical Provider is ready for this) Due June 30, 2020 for those above the Action Level and below the PEL New employees or new assignments; baseline examination due within the first 30 days of Initial Assignment Photo courtesy of Page 39 13

14 Medical Surveillance 40 Training The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: (A) The health hazards associated with exposure to respirable crystalline silica; (B) Specific tasks in the workplace that could result in exposure to respirable crystalline silica; (C) Specific measures the employer has implemented to protect employees from exposure to respirable crystalline silica, including engineering controls, work practices, and respirators to be used; (D) The contents of this section; and (E) The purpose and a description of the medical surveillance program. The employer shall make a copy of this section readily available without cost to each employee covered by this section. Page 41 Training (j)(1) Hazard communication. The employer shall include respirable crystalline silica in the program established to comply with the hazard communication standard (HCS) (29 CFR ). The employer shall ensure that each employee has access to labels on containers of crystalline silica and safety data sheets, and is trained in accordance with the provisions of HCS and paragraph (j)(3) of this section. The employer shall ensure that at least the following hazards are addressed: Cancer, lung effects, immune system effects, and kidney effects

15 Engineering & Work Practice Controls 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. Due September 23, 2017 for Construction Activities Due June 23, 2018 for Industry Due June 23, 2021 for Fracking Industry Ventilation Recirculation Scrutinized (See OSHA s Dust Control Handbook Chapter 7) *Allow time for any necessary air permitting with EPA or DNR agencies Page 43 Questions? Brian J. Harms, P.E., CIH P: E: Bharms@trcsolutions.com 15