Highlights of Respirable Crystalline Silica. Jim Shelton, CAS Houston North Area Office

Transcription

1 Highlights of Respirable Crystalline Silica Jim Shelton, CAS Houston North Area Office

2 Respirable Crystalline Silica Published March 25, 2016 Effective dates for construction: Effective date delayed to September 23, 2017 Requirements except for methods of analysis in paragraph (d)(2)(v) effective June 23, 2017 Requirements for methods of analysis in paragraph (d)(2)(v) effective June 23, 2018

3 Why an Updated Standard Exposure to respirable crystalline silica has been linked to: Silicosis; Lung cancer; Chronic obstructive pulmonary disease; and Kidney disease Healthy Lung Silicotic Lung

4 Respirable Crystalline Silica a) Scope and Application b) Definitions c) Specified Exposure Control Methods - or - d) Alternative Exposure Control Methods e) Respiratory Protection f) Housekeeping g) Written Exposure Control Plan h) Medical Surveillance i) Communication of Respirable Crystalline Silica Hazards to Employees j) Recordkeeping k) Dates

5 (a) Scope and Application Applies to all occupational exposures to respirable crystalline silica in construction work except where employee exposure 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 500 micrograms

6 (b) Select Definitions Action Level Concentration of airborne respirable crystalline silica of 25 µg/m 3 calculated as an 8- hour TWA Competent Person An individual 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. Knowledge and ability necessary to fulfill the responsibilities set forth in paragraph (g)

7 (b) Select Definitions High Efficiency Particulate Air (HEPA) Filter A filter that is at least 99.97% efficient in removing monodispersed particles of 0.3 micrometers in dimeter e.g. Respirable Crystalline Silica Quartz, cristobalite, and/or tridymite contained in airborne particles that are determined to be respirable by a sampling device designed to meet the characteristics for respirableparticle-size-selective samplers specified in ISO 7708:1995

8 (c) 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

9 (c) Specified Exposure Control Methods Employers must to ensure that: Controls are present and maintained Employees understand the proper use of those controls and use them accordingly Employees are engaged in the task when operating the listed equipment, assisting with the task, or have some responsibility for the completion of the task Employees are not engaged in the task if they are only in the vicinity of a task

10 (c) Specified Exposure Control Methods Respirators required where exposures above the PEL are likely to persist despite full and proper implementation of the specified engineering and work practice controls Where respirators required they must be used by all employees engaged in the task for entire duration of the task

11 Table 1 Tasks 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 stand-mounted 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

12 Table 1 Tasks

13 Table 1 Tasks

14 Table 1 Tasks

15 Table 1 Tasks

16 Table 1 Tasks When implementing Table 1 controls: For tasks indoors or in enclosed areas provide a means of exhaust as needed to minimize the accumulation of visible airborne dust For tasks using wet methods apply water at flow rates sufficient to minimize release of visible dust For tasks that include an enclosed cab or booth ensure: Maintained as free as practicable from settles dust Door seals and closing mechanisms work properly Gaskets and seals in good condition and working properly Positive pressure maintained through continuous delivery of fresh air Intake air filtered through filter 95% efficient in µm range or better Has heating and cooling capabilities

17 Table 1 Tasks If an employee performs more than one task from table 1 during their shift and the total duration of all tasks combined is more than four hours the required respiratory protection for each tasks is the protection specified for more than four hours per shift. If the total duration is less than four hours combined the respiratory protection is that required is that specified for less than four hours per shift

18 (d) Alternative Exposure Control For tasks not listed in Table 1 or where engineering controls, work practices, and respiratory protection is not fully and properly implemented for Table 1 tasks then: Must ensure no employee is exposed to airborne respirable crystalline silica in excess of 50 µg/m 3 calculated as an 8-hour TWA Must assess the exposure of each employee who is or reasonably expected to be exposed at or above the action level Where several employees perform the same tasks on same shift and same work area you can sample a representative fraction of the employees. Sample the employees expected to have the highest exposures

19 d) Alternative Exposure Control Exposures must be reassessed whenever a change in production, process, control equipment, personnel, or work practices can reasonable be expected to result in new or additional exposures at or above the action level or it is believed that new or additional exposures at or above the action limit have occurred Affected employees must be informed of the exposure assessment within five working days after completion either individually or by posting Affected employees or designated representatives must have the opportunity to observe the monitoring

20 d) Alternative Exposure Control Methods of Compliance Engineering and work practice controls must be used to reduce the exposure to or below the PEL unless the employer can show it is not feasible Where feasible engineering and work practice controls won t reduce the exposure to or below the PEL they must still use them to reduce it to the lowest feasible level and supplement them with respiratory protection Ventilation shall be followed when applicable for abrasive blasting using crystalline silica blasting agents or when abrasive blasting in substrates containing crystalline silica

21 Cutting block without engineering controls Cutting block using water to control the dust

22 Grinding without engineering controls Grinding using a vacuum dust collector

23 Jackhammer use without engineering controls Jackhammer use with water spray to control dust

24 (e) Respiratory Protection When required each employee must be provided an appropriate respirator that complies with this paragraph and Respiratory protection is required when: Specified in Table 1 For tasks not in Table 1 or where the employer does not fully and properly implement the engineering controls, work practices, and respiratory protections Exposures above the PEL during periods necessary to install or implement feasible engineering and work practice controls For exposures above the PEL during tasks such as maintenance and repair where engineering and work practices are not feasible During tasks where all feasible engineering and work practice controls have been implemented and they re not sufficient to reduce exposures < to the PEL

25 (f) Housekeeping Dry sweeping or dry brushing that could contribute to employee exposure is not allowed unless wet sweeping, HEPA-filtered vacuuming or other methods that minimize exposure are not feasible Compressed are is not allowed to clean clothing or surfaces where the activity could contribute to employee exposure unless: The compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud or No alternative method is feasible

26 (g) Written Exposure Control Plan Employer will establish and implement a written exposure control plan containing at least the elements: Description of tasks in the workplace that involve exposure Description of the engineering controls, work practices, and respiratory protection used to limit employee exposure for each task Description of the housekeeping measures used to limit exposure Description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed and their level of exposure including exposures generated by other employers or sole proprietors

27 (g) Written Exposure Control Plan The employer shall review and evaluate the effectiveness of the plan at least annually and update as necessary The written plan shall be readily available for examination The employer shall designate a competent person to make frequent and regular inspections of job sites, materials, and equipment to implement the plan

28 (g) Written Exposure Control Plan The employer shall designate a competent person to make frequent and regular inspections of job sites, materials, and equipment to implement the plan

29 (h) Medical Surveillance Employer shall make medical surveillance available at not cost to the employee, and at a reasonable time and place, for each employee who will be required to use a respirator 30 or more days per year Required medical examinations and procedures must be performed by a PLHCP Initial (baseline) examination must be made available within 30 days of initial assignment unless they ve had one meeting these requirements of this section within the last three years

30 (h) Medical Surveillance Periodic examinations at least every three years or more frequently if recommended by the PLHCP The PLHCP shall be provided a copy of the standard and other employee history and job information The PLHCP shall explain the results to the employee and provide a written medical report within 30 days of examination The employer shall obtain a written medical opinion from the PLHCP within 30 days If the PLHCP written opinion indicates the employee needs to see a specialist they must be made available within 30 days

31 (i) Communication of Hazards Respirable crystalline silica shall be included in the hazard communication training Each employee must have access to labels on containers of crystalline silica and SDSs and trained in accordance with the HCS Hazards that must be covered include cancer, lung effects, immune system effects, and kidney effects

32 (i) Communication of Hazards Employees must demonstrate knowledge and understanding of at least: The health effects Specific tasks with exposures Engineering controls, work practices, and respirators used to control exposures Content of the standard Identity of the competent person Purpose and description of the medical surveillance program A copy of the standard readily available

33 (j) Recordkeeping Employer must make and maintain an accurate record of all air monitoring data used to assess exposure The employer must make and maintain an accurate record of all objective data relied upon to comply with the requirements The employer must also make and maintain an accurate record for each employee covered by medical surveillance Exposure records, objective data, and medical surveillance records must be maintained and made available in accordance with

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35 Resources

36 Questions? Houston North Area Office Joann Figueroa, Area Director Jim Shelton, CAS 690 S. Loop 336 W., Suite 400 Conroe, TX

37 Disclaimer This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics [or hazards], it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA s website at