Respirable Crystalline Silica Standard. Presented by Joseph Kraham, CIH, CSP Director of Industrial Hygiene AIRIS Wellsite Services

Transcription

1 Respirable Crystalline Silica Standard Presented by Joseph Kraham, CIH, CSP Director of Industrial Hygiene AIRIS Wellsite Services

2 Overview Current Status Perception vs. Reality Reviewing some key sections in OSHA Ruling vs Observed Practices Multi Employer Worksite Citation Data / Graphs

3 OSHA EXPOSURE LEVELS AND RULING OBLIGATIONS PRE JUNE 2016 JUNE 2016 TO JUNE 2018 JUNE 2018 TO JUNE 2021 POST JUNE 2021 PERMISSIBLE EXPOSURE LEVEL (PEL) PEL = 100 µg/m 3 PEL = 50µg/m 3 Action Level = 25 µg/m 3 Exposure Assessment / Objective Data Regulated Area Engineering and Work Practice Controls 60 Exposure Control Plan Respiratory Protection Housekeeping Medical Surveillance* Communication of Hazards 0 PREVIOUS STANDARD NEW STANDARD ACTION LEVEL Recordkeeping *Over PEL 30 Days June 2018 Over AL 30 Days June 2020 Implemented Enforced

4 Scope of this presentation Item Information Who Oil and Gas Industry Pressure Pumpers or Exploration & Production What Where Why When 29 CFR Standard Respirable Crystalline Silica (RCS) Predominantly fracking sites in various field locations in the USA. Data presented to OSHA that led to a significant ruling change due to the hazard of exposure to RCS. This presentation is evaluating 2018 data we have collected. Goal of presentation is to bring up two key points: 1. There is an inverse relationship with Perception and Reality. 2. The purpose of the presentation to share some of these items and to try and provide a conversation about protecting the health of employees.

5 Quick Exercise If you Google Search Typical Fracing Site Results are mostly diagrams to show the process If you Google Search one of your typical moving systems What are the perception / image(s) you see? Google Search Dust at Frac Site

6 OSHA Enforcement Regional Emphasis Program for the Oil and Gas Industry Region 3 (DE, DC, MD, PA, VA, WV) Region 6 (AR, LA, NM, OK, TX) Region 8 (CO, MT, NE, SD, UT, WY) Region 9 (CA, NV, AZ, HI) Multi employer worksite issues known overarching clause that has been cited in several other OSHA standards.

7 Silica Standard for General Industry Current Status In Effect and Enforceable Perception If RCS standard is in it s infancy stage, there is no need to do anything or follow the regulation. OSHA Enforcement Officers are not performing that many conducting inspections / audits of fracking sites. Isn t RCS the contractor s responsibility? Reality Standard is enforceable and there is some limited information published with the construction industry exceeding 100+ citations in the first 6 months. Currently no official Compliance Directive, but multiple regions have a special emphasis on RCS. The absence of published citation data does not mean that audits / inspections are not occurring. OSHA s Multi Employer Work Citation Policy has multiple employer types, but is an established policy with OSHA.

8 The Big Deal is a Small Particle Respirable Crystalline Silica Standard 50 ug/m3 Permissible Exposure Limit 25 ug/m3 Action Level PEL established at 8 hours 11 m 3 AIR BREATHED 1 Day / 24 hours Average person breathes 7 8 L/min

9 The Big Deal is a Small Particle Breathing in silica causes silicosis (smaller particles = greater hazard) Inflammation and scarring in lobes of lungs NO CURE FOR SILICOSIS Acute Silicosis High exposures to silica dust Develops less than 5 years Accelerated Silicosis High exposures to silica dust Develops 5 10 years after exposure Chronic Silicosis Long term exposure to low concentrations of silica dust Develops years after first exposure

10 For reference with scale: Measuring Silica Dust The Scale of µg 1,000,000,000 µg = 1 Kg or 1 lb = 4.53 x 10 9 µg Now suppose time was replacing mass SI unit for weight is the Kg so (g) :: 1,000 seconds = 16 minutes, 40 seconds (mg) :: 1,000,000 seconds = about 11½ days (µg) :: 1,000,000,000 seconds = about 31 years and 8 months *We may not be able to understand the size of something small, but when you take something small and convert it into something tangible, it gives you a better appreciation.

11 Measuring Silica Dust Lifetime of Exposure as PEL/1 Day For reference: 1 ounce of dry sand weighs approximately 0.1 lbs or 46 grams 1 US Tablespoon = 0.5 ounce or 23 grams or 1 US Teaspoon = ounce or ~7.666 grams Exposed to the PEL (50 µg/m 3 ) for: 8 hours per day 5 days per week 50 weeks per year 30 years 50 ug/m3 x 8 hr/day x 5 day/week x 50 week/yr x 30 year = 3,000,000 µg in a lifetime of exposure OR 3 grams *Ignoring denominator of volume for simplicity 1x PEL lifetime = 3g 5x PEL lifetime = 15g 10x PEL lifetime = 30g 50x PEL lifetime = 150g

12 Respirable Crystalline Silica Standard Few key sections to highlight in standard

13 Silica Standard for General Industry 29 CFR Para (c) Permissible Exposure Limit (PEL) The employer shall ensure that no employee is exposed to an airborne concentration of respirable crystalline silica in excess of 50 μg/m 3, calculated as an 8 hour TWA. Perception Reality

14 Silica Standard for General Industry Para (d) Exposure Assessment The employer is required to 29 CFR Assess the exposure of employees who are or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level Assess the 8 hour TWA exposure for each employee on the basis of any combination of air monitoring data or objective data Perception Reality

15 Silica Standard for General Industry 29 CFR Para (d) Exposure Assessment There are two general methods to comply: Scheduled monitoring option: If exposures exceed PEL monitor every 3 months If exposures exceed Action Level but remain at or below the PEL monitor every 6 months Performance option: Employers may rely on exposure monitoring data or objective data sufficient to characterize exposures. How does your data look?

16 How confident are you that your data demonstrates Performance Option? Partial Variance List to consider People Job Title, Pop. Group Size, Task variance, % work inside regulated area, > % PEL, < % PEL, PPE usage, individual behavior, fleet size, management of , enforcement of , previous IH data, medical surveillance, ECPs, Audit data Environmental Precipitation (rain = IH favorite engineering control), Wind (speed, direction, calm %), humidity, temperature, time of day, geographical location, elevation. Sand / Production Frac Type, Pump rate, reliability, stages per day, frequency, mean run time, duration of runs, RCS / RDC ratio, Mesh Size, Total Volume, size of Padsite, sand mine, pad layout, equipment type, # of sources, pneumatic loading Housekeeping Performed, rate, tools, methodology, time spent, personnel rotation

17 Silica Standard for General Industry Para (e) Regulated Areas 29 CFR Wherever an employee's exposure to airborne concentrations of respirable crystalline silica is, or can reasonably be expected to be in excess of the PEL, each employer shall establish and implement either a regulated area or an access control plan. Regulated areas: Must be demarcated such that the boundaries are established. Signage / language often does not match the one specified in (j)(2) Access is limited to authorized employees having duties in the area (enforcement is often an issue) PPE (respiratory protection) must be provided and worn at all times while in the regulated area. Often, sites will only wear PPE while a stage is running.

18 Silica Standard for General Industry Para (e) Regulated Areas 29 CFR Perception Reality No exposure on this side

19 Silica Standard for General Industry 29 CFR Para (g) Respiratory Protection Respirators are required when engineering controls are not available or sufficiently protective. When respirators are required, employers must provide them in accordance with Exposure Monitoring data will provide information on what type of respiratory protection is required. This is often missed with sites. Exposure monitoring data has demonstrated that full face respirators are needed if there are a lack of effective engineering controls.

20 Silica Standard for General Industry 29 CFR Para (g) Respiratory Protection Perception Reality

21 Silica Standard for General Industry Para (h) Housekeeping 29 CFR Compressed air and dry sweeping are not allowed to clean contaminated surfaces. HEPA vacuums or wet sweeping are to be used instead Compressed air can be used with LEV when no alternative method is feasible. SHOVELING SAND is a common practice, but is not allowed under the current language in para (h).

22 Silica Standard for General Industry 29 CFR Para (i) Medical Surveillance Medical surveillance required for any employee exposed above the PEL beginning June 2018 (action level after June, 2020) for 30 days or more per year. Initial medical exam Physical Exam Bloodwork (TB test) Chest X ray Pulmonary Function Test Medical Questionnaire Other tests deemed necessary by PLHCP Periodic medical exam required every 3 years

23 OSHA s Multi Employer Work Citation Policy Directive Number CPL

24 OSHA s Multi Employer Work Citation Policy On multi employer worksites, OSHA recognizes four types of employers: creating, controlling, exposing, and correcting. Creating employer causes a hazardous condition that violates an OSHA standard. Exposing employer is one whose own employees are exposed to the hazard. In certain cases, one employer may be deemed both a creating and exposing employer. Correcting employer is responsible for correcting a worksite hazard and usually installs and/or maintains safety equipment or devices. Controlling employer is the employer who has general supervisory authority over the worksite, including the power to correct safety and health violations or require others to correct them.

25 Data / Graphs IH Data related to Respirable Crystalline Silica (RCS)

26 2018 Assessments by type of System Samples PER Site Visit Boxes Mover Silos 2017 Q Q Q Average Personal / Visit Average Area / Visit Q Q Q Linear (Average Personal / Visit) Linear (Average Area / Visit) YTD Assessments performed Boxes 30 Movers 20 Silos 26 Trend is that Assessments are having a higher number of personal samples and area PER site visit.

27 Boxes Max Personal Sample per Site sites assessed Box Type Personal Samples 9 sites X > PEL (60%) 4 sites X > AL (27%) 2 sites X < AL (13%) Engineering controls were effective in getting below PEL Boxes Max Area Sample per Site Area Samples 12 sites X > PEL (80%) 3 sites X > AL (20%) 0 sites X < AL Overall, effective engineering controls reduce the MAX value consistently around 75 80% max peak value.

28 Movers Max Personal Sample per Site sites assessed Movers Type Personal Samples 9 sites X > PEL (90%) 1 sites X > AL (10%) 0 sites X < AL Engineering controls were effective in getting below PEL Movers Max Area Sample per Site Area Samples 8 sites X > PEL (80%) 0 sites X > AL 2 sites X < AL (20%) Q1 Mover 2 had 0 area samples Q2 Mover 2 had a total of 6 Overload samples (500+) Mover jobs have more variance in data and more OL samples Mover jobs tend to have the highest values

29 Silos Max Personal Sample per Site Silos Max Area Sample per Site sites assessed Silos Type Personal Samples 7 sites X > PEL (53%) 1 sites X > AL (8%) 5 sites X < AL (39%) Engineering controls were effective in getting below PEL AIRIS controls on: Q2 Silo 1 (11) Q2 Silo 3 (27) Q2 Silo 5 (8.4) Q3 Silo 4 had 0 PBZ (area only) Area Samples 9 sites X > PEL (69%) 1 sites X > AL (8%) 3 sites X < AL (23%) Q1 Silo 1 had 0 area samples Q3 Silo 6 all area samples BDL Silo data overall appears to be the most consistent system with regards to sand volume

30 What does this all mean and WHY does it matter? 100% Max Personal By Type of Equipment 80% 60% 40% 90% 20% 60% 27% 53% 39% 0% 13% 10% 0% 8% Boxes Mover Silos Above PEL Above AL Below AL In summary, the majority of sites when evaluating representative data show: 1. Personnel are overexposed (engineering controls are not enforceable until 2021) 2. Sites are not sampling objectively, both in overall number of people sampled and the frequency 3. Employers have inadequate controls/work practices in place

31 In Summary: Perception Reality

32 In Summary: Employers are Required To: 1. Perform IH Sampling to determine scope / sampling 2. Develop a written exposure control plan 3. Use engineering controls (such as water or ventilation) to limit worker exposure to the PEL 4. Provide respirators when engineering controls cannot adequately limit exposure 5. Establish and enforce regulated areas 6. Train workers on silica risks and how to limit exposures 7. Offer medical exams to exposed workers

33 Questions and Comments Office: