Implementing the New OSHA Respirable Crystalline Silica Standard in General Industry

Transcription

1 Implementing the New OSHA Respirable Crystalline Silica Standard in General Industry Greg Zigulis, CIH, CSP Sixth Sense Safety Solutions March 14, 2018 Topics of Discussion A Quick Introduction to Self and Silica Regulatory Status of Respirable Crystalline Silica (RCS) Standards An Overview of Requirements Implementation Considerations with Lessons Learned Wrap Up 1

2 Disclaimer The material provided in this presentation is for informational purposes only and is not intended to convey or constitute legal advice. You should contact your attorney to obtain advice with respect to any particular issue or problem. The opinions expressed in this presentation and on the following slides are solely the opinions of the presenter. Introduction Greg Zigulis, CSP, CIH Sixth Sense Safety Solutions Member of ASSE Greater Detroit Chapter (GDC) Member of Michigan Industrial Hygiene Society (MIHS) Member of Western Michigan Industrial Hygiene Society (WMIHS Board) 4 2

3 Background 32 Years Public, Private, Large, Small Military, Chemical Waste, Construction, Fatality Research, Manufacturing, Disaster Restoration, Mining Silica (Respirable Crystalline Silica) applications in: Consumable dental supplies milling/grinding/packaging Sandblasting/abrasive blasting Construction processes Foundries 5 A Quick Introduction to Silica Silicon dioxide (SiO2) Occurs in crystalline or non crystalline form α Quartz is the most abundant crystalline form Most common mineral on the earth s continents Found in sand, sandstone, shale and granite Ampian SG, Virta RL [1992]. Crystalline silica overview: Occurrence and analysis. Washington, DC: U.S. Department of the Interior, Bureau of Mines, Information Circular IC

4 Where is Silica Found? Amorphous nuisance dust Quartz glass Vitreous glass Fused silica Opals Crystalline carcinogen Sand Mortar Concrete Abrasive Porcelain Paints Bricks 7 Uses of Silica Glass and porcelain Optical fibers for telecommunications Production of elemental silicon used in electronics Sand casting for manufacturing of metallic components Food additive Concrete and mortar Polishing and cutting Sandblasting Electrical insulators Toothpaste High temperature thermal protection fabric Paints Brick Aggregates 8 4

5 Industrial Operations Potential Crystalline Silica Exposures Construction Industry Abrasive blasting Tuck Pointing Jackhammering Rock/well drilling Concrete mixing and drilling Brick and concrete cutting Quarry work and tunneling 9 Industrial Operations Potential Crystalline Silica Exposures General Industry Abrasive blasting Manufacturing Cement and brick Asphalt/pavement China and ceramics Steel and foundry industries 10 5

6 Hydraulic Fracturing 11 OSHA Silica Standard More than 80 years ago, Labor Secretary Frances Perkins identified silica dust as a deadly hazard and called on employers to fully protect workers U.S. Secretary of Labor Thomas Perez in statement on Final Rule March 24, 2016 OSHA Fact Sheet OSHA s Proposed Crystalline Silica Rule Overview 12 6

7 Potential Disease Outcomes Courtesy of Dr. Ken Rosenman Regulatory Status OSHA: employees exposed to respirable silica at the permissible exposure limit (PEL) set in the old standard face a significant risk of material impairment to their health. OSHA estimates: 2 million construction workers and 300,000 in general industry and maritime 7

8 A Quick Introduction to Silica The Standards First Updates Since 1971 OSHA Construction Standard: 29CFR , Respirable Crystalline Silica Compliance delayed from June 23, 2017 until Sept 23, 2017 OSHA General Industry Standard: 29CFR , Respirable Crystalline Silica (Also Applies to Maritime) With exception compliance by June 23, 2018 for controls, with med monitoring by 6/23/2018 if >PEL and 6/23/2018 if >AL Hydraulic fracturing (fracking) operations in the oil and gas industry will have until June 23, 2021, to implement controls to limit exposures to the new PEL. From June 23, 2018, to June 23, 2021, hydraulic fracturing employers can continue to have employees use respirators when exposures exceed the PEL. Silica Standard General Industry Scope ( General Industry/Maritime) Definitions Permissible exposure limit(pel) Exposure assessment Regulated areas Methods of compliance Engineering and work practice controls 8

9 Silica Standard General Industry Written exposure control plan Respiratory protection Housekeeping Medical Surveillance Communication of silica hazards Recordkeeping Dates Silica Standards Comparison Scope ( General Industry/Maritime) Definitions Permissible exposure limit(pel) Exposure assessment Regulated areas Methods of compliance Engineering and work practice controls Written exposure control plan Respiratory protection Housekeeping Medical Surveillance Communication of silica hazards Recordkeeping Dates Scope ( Construction) Definitions Specified exposure control methods or Alternative exposure control methods Permissible exposure limit (PEL) Exposure assessment Methods of compliance Written exposure control plan Respiratory protection Housekeeping Medical surveillance Communication of silica hazards Recordkeeping Dates 9

10 Previous OSHA Silica Standard General Industry Was based on research from 1960s Actually a PEL for respirable dust PEL Respirable Dust using a sliding scale based on percent of crystalline silica in respirable particulate Equivalent to 100 µg/m 3 (100% silica) 19 Particle Size Exposure Inhalable Thoracic Respirable Slide images courtesy of SKC 20 10

11 Silica Standard General Industry Changed the Action Level and Permissible Exposure Limit PEL to 50 µg/m3 Action Level of 25 µg/m3 Exposure Assessment Above the AL averaged over an 8 hour work day, 30 days/year or more? Above the PEL, same hours/days criteria? If So,. Now We ve Got Some Deadlines and Actions to Take! Silica Standard General Industry Regulated area requirements 11

12 Silica Standard General Industry Methods of Compliance Housekeeping No dry sweeping or dry brushing unless wet sweeping or HEPA vacs not feasible No compressed air to clean clothing or surfaces unless used in conjunction with a ventilation system that captures the dust 12

13 Compressed air cannot be used for cleaning Compressed air can be used as part of the process (v. housekeeping) Preamble Contribute to exposure Feasibility (safety hazard) From AFS 13

14 Exposure Control Plan One Company s Approach: Rollout Plan Corporate Buy In Multi Year Process Target Dates for Key Steps Builds in Time for Location Buy IN Builds in Time for the Unanticipated/Glitches/Delays Key Steps Aligned to Achieve Compliance by June 23,

15 Silica Standard General Industry Scope ( General Industry/Maritime) Definitions Permissible exposure limit(pel) Exposure assessment Regulated areas Methods of compliance Engineering and work practice controls One Company s Approach: Exposure Assessment Respirable particles determined by a sampling device Respirable particle size selective samplers meeting International Organization for Standardization (ISO) 7708: µm 50% Cut Point (Previous OSHA Standard 3.5 µm) 15

16 One Company s Approach: Exposure Assessment ISO 7708 defines three size selective particulate fractions: Sampler Specification Sampler Performance Specification uses the convention of the 50% Cut Point Cut Point is the particle size that a device can collect with 50% efficiency Particles smaller than 50% cut point are collected with greater efficiency Particles larger than 50% cut point are collected with less efficiency BGI Cyclone Higgins Dewell Cyclone Dorr Oliver Cyclone 32 16

17 IMPORTANT NOTE ON FLOWRATE All cyclones are not created equal! Each cyclone has different operating specifications to meet the required performance criteria. Be sure you know the flow rate specified before using any cyclone. DISPOSABLE PPI: DESIGN FEATURES NO TIPPING HAZARD TO INVALIDATE THE SAMPLE. The disposable PPI looks like a traditional 37 mm filter cassette. But the inlet section has 4 internal, pre oiled impactor plates that scrub out larger particles. The respirable dust is then collected onto the filter in the outlet section for analysis. 17

18 One Company s Approach: Exposure Assessment Laboratory Qualification Laboratory Accredited to ISO (AIHA LAP Accreditation meets this requirement) Analytical Methods OSHA ID 142 (X ray Diffraction) NIOSH 7500 (X ray Diffraction) NIOSH 7602 (Infrared) NIOSH 7603 (Infrared) MSHA P 2 (X ray Diffraction) MSHA P 7 (Infrared) 35 One Company s Approach: Exposure Assessment Use of Direct Reading Instruments 36 18

19 Exposure Assessment Considerations Silica generation: Where Can It Be Found? What Kinds of Samples to Take and for What Purpose? What are you trying to prove or disprove? What Variables in Exposure Potential? Evaluation Steps Process Walk Developed a plan for evaluation steps Developed a standard method of documentation What is the Typical Range of RCS Data Data from OSHA Final Standard 81FR

20 What is the Typical Range of RCS Data Data from OSHA Final Standard 81FR

21 Exposure Assessment Considerations Personal Air Sampling vs. Area Air Sampling vs. Direct Reading What About Exposure Maps? 21

22 What About Mapping? Exposure Control Plan: Possible Content Policy Statement Responsibilities Exposure Assessment Regulated Areas Exposure Control Methods Task Specific Exposure Control Medical Surveillance Hygiene Facilities and Practices Training Recordkeeping Appendices 22

23 Some Exposure Control Plan Considerations Effecting Organizational Change/Overcoming Resistance: Leadership Team Employees at Points of Exposure Prohibitions on Use of Compressed Air & Dry Sweeping Engineering Controls Investigation, Changes Regulated Area Definitions and Demarcations Respirable dust can stay suspended Minutes In still air Particle diameter (microns) 23

24 Some Exposure Control Plan Considerations Integration of the ECP with Other Procedures/Plans/Policies Employee Understanding Process for Establishing Feasibility Notes on Engineering Controls Source Capture Tools Central Vacuum Systems Filter Cleaning Mechanisms, Dust Free Emptying 24

25 Notes on Engineering Controls Cyclonic Pre Separators help efficiency Implementation Considerations with Lessons Learned To Competent Person or Not Competent Person How Will You Handle Persons Going Into and Out Of Regulated Areas? What Are You Going to Protect Against? The Age Old Facial Hair Issue Difficulties in Finding Qualified Medical Providers Expect Lots of Questions and Possible Resistance Build Time for Implementation of Changes 25

26 Implementation Considerations with Lessons Learned How to Handle: Lots of MONEY Spent But Difficulty Achieving Significant Reduction? This is where FEASIBILITY comes into play What are your CRITERIA? Have a game plan you must be able to PROVE Document, document, document Wrap Up IF You Haven t Already Started The Time is NOW Get the Regulation, Read It. Agree or Not The Standard Is Here Identify and Think Through Critical Questions Regulatory Mandates vs Management Policy Develop Your Time Based Action Plan Consider the Human Issues as Well as Regulation Lots of Ongoing Communication Get and Keep Current: OSHA Directives, Industry Associations, Other Resources 26

27 Contact Information Greg Zigulis, CIH, CSP Sixth Sense Safety Solutions 989/