SILICA WEBINAR. Chris Chipponeri Chief Operations Officer Hazard Management Services, Inc.

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1 SILICA WEBINAR Chris Chipponeri Chief Operations Officer Hazard Management Services, Inc. SILICA HISTORY AND BACKGROUND Basic component of soil, sand, granite and many other minerals Naturally-occurring (most common element in the World) and used in a wide range of construction products Regulated in CA under 8 CCR and for Construction Regulated in CA under 8 CCR 5204 for General Industry The above regulations were issued for CA in addition to the long existing 8 CCR for Crystalline Silica health hazard. 1

2 EARLY DETECTION OF SILICA HEALTH HAZARD The health hazard from silica has been known for decades. The U.S. Department of Labor released a newsreel of silica hazard as early as Stop Silicosis.mp4 Material is still used in today s construction products and cannot likely be stopped (it occurs naturally in every rock and stone in the world). POTENTIAL PATHS OF EXPOSURE In general, activities involving construction will cause the highest levels of exposure to workers. Exposures range from high levels, such as abrasive blasting to lower exposures from wet sanding of textures and paints. The worst exposure may be when sand (silica itself) is used as the abrasive blasting media! Indoor work, and work in tunnels, can experience even higher levels of exposure. One of the most common exposures is when concrete finishing, refinishing, cutting jackhammering, grinding, mixing of dry concrete with water, and similar activities are conducted. 2

3 POTENTIAL PATHS OF EXPOSURE Severe exposure can be the results of lack of engineering controls, poor work practices, and lack of, or improper, use of personal protection equipment. Manufacturing of typical goods can also lead to exposure, such as jewelry castings, ceramic wares, and cement manufacturing. Routine maintenance of building materials can lead to exposure to workers. CURRENT REGULATIONS FOR CRYSTALLINE SILICA Construction Standard 8 CCR This section 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/m3) as an 8-hour time-weighted average (TWA) under any foreseeable conditions. Construction Standard enforcement began September 23, 2017 General Industry Standard enforcement begins June 23, 2018 Must also comply with requirements set in 8 CCR General Industry Standard 8 CCR 5204 This section applies to all occupational exposures to respirable crystalline silica, except: Construction work covered under Section Agricultural operations covered under 8 CCR Section 3436; and Exposures that result from the processing of sportive clays. 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. This section does not apply if the employer complies with Section and: The task performed is indistinguishable from a construction task listed on Table 1 in subsection (c) of Section and the task will not be performed regularly in the same environment and conditions. 3

4 HEALTH EFFECTS OF CRYSTALLINE SILICA Crystalline Silica are small, respirable factions of silica dust that enter a worker s lungs Respirable factions are 1/100 th of a typical grain of sand Silica-related diseases include: - Silicosis -Lung Cancer - Chronic Obstructive Pulmonary Disease (COPD) -Kidney Disease - And other cardio-vascular health problems (such as heart attack) TYPICAL MATERIALS CONTAINING CRYSTALLINE SILICA All stone, rock, and masonry materials Building materials such as concrete, drywall, stucco, ceiling tiles, window glazings, etc. Any other material, component, manufactured good that contains sand, rock, or stone as part of it s manufacturing process. 4

5 EXPOSURE LIMITS Action Level = 25 µg/m³ as 8-hour Time-Weighted Average (TWA) Permissible Exposure Limit = 50 µg/m³ as 8-hour TWA So what happens or is required at each of these levels? SO HOW DO WE COMPLY WITH REGULATION? Cal/OSHA s 8 CCR Standard sets out a table of common tasks performed that impact materials containing Crystalline Silica Table is broken down into two columns work lasting equal or less than 4 hours or work lasting more than 4 hours. Table provides a total of 18 different tasks that are commonly completed Tasks are broken out further based on working being completed outdoors or indoors / enclosed area. Table assists with determining minimum respiratory protection for task. 5

6 A MAJOR DEPARTURE FROM MOST RESPIRATORY HAZARD REGULATORY REQUIREMENTS Typically OSHA requires employers to assume their workers will be exposed above the allowable permissible exposure level (PEL) the first time the conduct work where exposure could occur. This leads to the requirement wear a respirator the first time a ask is conducted task, and continue to wear the respirator until air samples show the exposure is below the PEL. With Silica, there are times this is not true Some tasks can be started with the assumption exposures will remain below the PEL, provided You follow the prescribed work practices, and Collect air samples to prove the technique keeps exposures below the PEL and Action levels. TABLE 1 SPECIFIED EXPOSURE CONTROL METHODS WHEN WORKING WITH MATERIALS CONTAINING CRYSTALLINE SILICA Equipment/task Engineering and work practice control methods 4 hours/shift > 4 hours/shift (iv) Walk-behind saws 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: -When used outdoors None None. -When used indoors or in an enclosed area APF 10 APF 10. 6

7 TABLE 1 SPECIFIED EXPOSURE CONTROL METHODS WHEN WORKING WITH MATERIALS CONTAINING CRYSTALLINE SILICA Equipment/task Engineering and work practice control methods 4 hours/shift > 4 hours/shift (x) Jackhammers and handheld powered chipping tools Use tool with water delivery system that supplies a continuous stream or spray of water at the point of impact: -When used outdoors None APF 10. -When used indoors or in an enclosed area APF 10 APF 10. OR Use tool equipped with commercially available shroud and dust collection system Operate and maintain tool in accordance with manufacturer s instructions to minimize dust emissions Dust collector must provide the air flow recommended by the tool manufacturer, or manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism: -When used outdoors None APF 10. -When used indoors or in an enclosed area APF 10 APF 10. ENGINEERING CONTROLS FOR TABLE 1 Tasks performed indoors or in enclosed areas, provide a means of local exhaust to minimize the accumulation of visible airborne dust Tasks performed using wet methods, apply water flow rates sufficient to minimize release of visible dust Tasks performed that include an enclosed cab or booth, ensure that the enclosed cab or booth: - Is maintained as free as practicable from settled dust - Has door seals and closing mechanisms that work properly - Has gaskets and seals that are in good condition and working properly - Is under positive pressure with continuous delivery of fresh air - Has intake air filter that is 95% efficient in µm range (MERV-16 or better) - Has heating and cooling capabilities 7

8 WHAT DO YOU MEAN THE TABLE ASSISTS WITH SELECTING RESPIRATORY PROTECTION? The employer is still responsible for conducting personal air sampling on workers. Sampling must be performed in accordance with OSHA sampling methods and analysis requirements. Sampling is to provide objective data showing workers are not being exposed above the Action Level or Permissible Exposure Level for Crystalline Silica Sampling must reflect workplace conditions that will be encountered by employer s operations. WHAT ABOUT THOSE TASKS THAT ARE NOT LISTED IN TABLE 1? Alternate Exposure Control Method If not performing a task in Table 1, or where the employer does not fully & properly implement engineering controls, work practices, and respiratory protection listed, the following is required: - Assure no employee is being exposed above PEL for Crystalline Silica - Perform exposure monitoring of employees by one of two methods: - Performance Option of Monitoring - Scheduled Option of Monitoring 8

9 ALTERNATE EXPOSURE CONTROL METHOD PERFORMANCE OPTION This is a combination of air monitoring data or objective data (industry data, prior exposure assessments, research, etc.) Industry data from tool manufacturers, industry partners Recommended that employer generates their own data and develop their own table of alternative control methods. Table developed should identify task being completed, type of material being impacted, work practices and engineering controls, and results of sampling data. ALTERNATIVE EXPOSURE CONTROL METHOD SCHEDULED OPTION Traditional Personal Air Sampling Method Collect personal samples from breathing zones of workers with the highest expected exposure Samples to be collected from each job classification in each work area If multiple employees performing same task in same work area, a fraction of the workers being sampled would be appropriate Review of initial monitoring results - If <25 µg/m³, sampling can be discontinued for 6-12 months -If 25 µg/m³, but 50 µg/m³, re-test within 6 months -If >50 µg/m³, re-test within 3 months Where two consecutive tests within 6 months show <25 µg/m³, testing may be discontinued. 9

10 ALTERNATIVE EXPOSURE CONTROL METHOD CONTROLS TO LIMIT EXPOSURES Wet & Dry Methods Local Exhaust Ventilation Fans (not recommended) Work Activities - Training/Preparation - Handling - Employee Positioning Respiratory Protection Hygiene Practices Isolation Material Substitution PROHIBITED PRACTICES Dry sweeping or brushing Use of compressed air to clean clothing or surfaces that can lead to exposure Use of dry sweeping is allowable if other methods (HEPA-vacuum, wet sweeping, or other method) has been attempted and shown not to be feasible. Use of compressed air with ventilation system that captures dust allowable (but not very feasible) 10

11 REGULATED AREAS FOR CRYSTALLINE SILICA A regulated area shall be established and demarcated whenever disturbing materials that can cause airborne respirable crystalline silica Area shall be demarcated from rest of work area to minimize the number of employees that can exposed to airborne respirable crystalline silica within the regulated area Regulated areas shall be demarcated with OSHA-approved signage AIR SAMPLING METHODS Sampling is performed using 37-mm, 5.0 µ, pre-weighted, PVC-filtered sampling cassettes. Sampling cassettes are used in conjunction with a Dorr- Oliver cyclone apparatus. Low-volume pumps are calibrated to collect at a rate of 1.7 liters per minute. Recommended minimum amount of sampling time is 480 minutes (8 hours), even if task impacting silica does not last that long. Samples should be analyzed by OSHA Method ID-142 by a properly accredited laboratory. Results provided in µg/m³ units to ease comparison to Action Level and PEL. Recommended a third-party hygienist perform sampling. 11

12 REQUIRED ANNUAL REVIEW OF PLAN & EFFECTIVENESS Include review of the work practices and engineering controls being performed Notes regarding equipment used, manner equipment is being used, and potential changes to limit worker exposures as possible Clearly identify samples, worker tested, and task performed on chain of custody Recommend including analysis of dust present on samples for general knowledge and determine if work practices / engineering controls are sufficiently removing dust in work area Testing has to be performed anytime work practices or engineering controls are changed for a task AIR SAMPLING RESULTS Within 5 working days, results of personal air sampling results must be provided to employees by the employer Results shall be delivered to all affected employees in writing Results can be delivered directly to affected employees or posted in an appropriate area that is accessible to all affected employees Employer must provide affected employees, or their representatives, an opportunity to observe any monitoring of employee exposure to respirable crystalline silica. If results are found above PEL, the notification shall include written corrective steps being taken to reduce employee exposures to, or below, the PEL 12

13 RESPIRATORY PROTECTION / MEDICAL SURVEILLANCE Any employees that may be required to wear respiratory protection as part of their duties must be enrolled in the employer s written respiratory protection program Written respiratory protection programs must comply with requirements of 8 CCR 5144 Employer shall provide at not cost to employee, a medical surveillance examination for any employee that will be required to wear a respirator for 30 or more days per year Initial medical exam required with tri-annual periodic re-examinations required Requirements of employer s written respiratory protection plan may be more stringent and would have to be complied with as well. Employer must provide employee with any necessary respiratory protection to perform their duties. Hazard Communication Training Provided by a Competent Person Includes numerous topics including health hazards, specific tasks in the workplace that cause exposure, steps taken to protect employees, requirements of 8 CCR , etc. Shall be provided at initial employment as required by 8 CCR 5194 Recommended training is provided annually at minimum No set length of training either do as part of annual IIPP/Safety training or with other Hazardous Materials training TRAINING OF EMPLOYEES 13

14 REQUIRED RECORDKEEPING Competent Person or Designated Program Director must perform recordkeeping of documents associated with the Standard - Air Monitoring Data - Objective Data - Medical Surveillance Records Records shall be stored for 30 years past termination of employee WRITTEN EXPOSURE CONTROL PLANS Employers are required to establish and implement a written exposure control plan that contains multiple elements. Plan may be designed by a person deemed a Competent Person or with assistance from third-party consultant. 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. The competent person must have the knowledge and ability necessary to fulfill the responsibilities set forth in subsection (g). Section (g) is requirement for written exposure control plan 14

15 WRITTEN EXPOSURE CONTROL PLAN CONTENTS Description of tasks performed in work place that may cause exposure to crystalline silica Tasks shall include written description of engineering controls, work practices, and respiratory protection used to limit exposure to employees Inclusion of housekeeping methods to limit employee exposures, including those practices that are prohibited Description of steps to be taken to demarcate and regulate work areas to restrict access to work areas to limit exposures WRITTEN EXPOSURE CONTROL PLAN REQUIREMENTS The exposure plan must be reviewed annually to evaluate effectiveness REVIEW OF THIS EVALUATION IS HOW Cal/OSHA PLANS TO ENFORCE THIS REGULATION they are not going to try to catch you doing things wrong they are going to ask you for a copy of your annual review you need to have all the required documentation and an opinion of how well you written policies are working (which is almost exclusively based on your air sample results). Plan shall be updated as necessary to increase effectiveness Plan shall be readily available for exam and copying by employees, designated representatives, Chief and the Director. Employer must have a Competent Person designated to make frequent and regular inspections to implement and update the Silica Handling Plan. 15

16 THANK YOU! REMEMBER SILICA IS OFTEN IN MATERIALS THAT CAN CONTAIN ASBESTS, LEAD, CHROMIUM, AND OTHER HAZARDOUS MATERIALS Any Questions? 16