Respirable Crystalline Silica Strategies for Compliance Effective Exposure Control Plans Abby Ferri, CSP, The Ferri Group Mark Cunningham, BC Business Manager, Nilfisk, Inc.
Presenters Abby Ferri, CSP is the President of The Ferri Group LLC, holds a Masters Degree in Environmental Health and Safety, is an OSHA Outreach Trainer for Construction, and a Certified Safety Professional (CSP). She is responsible for risk control, program development, training and regulatory compliance for construction, manufacturing, energy, beverage, hospitality, and retail clients throughout the United States and Canada. Abby is also an Adjunct Instructor in the Construction Management Program at Dunwoody College of Technology. Her previous experience includes managing corporate safety, health, and environment programs as Safety Director for a civil engineering contractor and managing risk control services for nationwide accounts as a Risk Control Consultant for large insurance carriers. Mark Cunningham, Nilfisk Inc., Business Development Manager, Building Construction, has more than 30 years experience in various facets of the building and construction industry, Mark is uniquely aware of the many hazards associated with job sites, industrial facilities, bridge and marine construction, and infrastructure. With Nilfisk, he is responsible for market strategy and product development specific to solving silica dust challenges in the building and construction, general industry, maritime and fracturing markets. Steve Mitchell, Nilfisk Inc., Sales Training Manager, is responsible for training internal and external Nilfisk associates on applications, regulations and products related to industrial cleaning and dust mitigation through the Americas. He has worked with hundreds of companies and helped them map their way to compliance. Nilfisk is a leading supplier of cleaning equipment globally.
Disclaimer Nilfisk, Inc., The Ferri Group and the presenters here are NOT authorized to approve equipment for your facility or job site. The opinions discussed in this webinar are our OPINIONS alone. You should consult with your employer or designated competent person before determining the safest, approved solution for your facility.
Learning Objectives Describe the requirements of an RCS Exposure Control Plan Review understand Table 1 Understand your requirements for exposure assessment Understand requirements for and appropriate tools for dust mitigation and housekeeping Identify resources for further study
Just in case QUICK BACKGROUND ON NEW STANDARD
Effective Dates June 23, 2016: 1926.1153 is effective Sept 23, 2017: All obligations, except for methods of sample analysis (Appx A) June 23, 2018: Methods of sample analysis
Where to find the rule 606 pages, final rule + preamble https://www.federalregister.gov/articles/20 16/03/25/2016-04800/occupationalexposure-to-respirable-crystalline-silica 26 page regulatory text https://www.osha.gov/silica/silicaconstruct ionregtext.pdf
Exposure levels Expressed as 8-hour TWA PEL = 50 micrograms/m 3 Action Level = 25 micrograms/m 3 OSHA says exposure at this level is still significant, but is lowest level feasible
Exclusions If exposure stays below 25 micrograms/m 3 as 8- hour TWA under any foreseeable conditions
Objective Data If under 25 micrograms/m 3 exception, no objective data required to support. When done in isolation, do not generate significant exposures: Mixing mortar Pouring concrete footers, foundation Removal of concrete formwork
OSHA s Objective Data OSHA s exposure monitoring found < AL Drilling holes in concrete or masonry Other tasks involving silica exposure done by carpenters, plumbers, and electricians occasional, brief exposures to RCS
OSHA s Objective Data Dry drilling on a wall on lower level of a concrete parking garage with poor air circulation 300 micrograms/m 3, 15 minutes 19 micrograms/m 3 8-hour TWA
OSHA - Drywall Finishing Per the Preamble, not included in Table 1 <0.5% silica found in drywall compounds from retail stores tested by NIOSH Use silica-free materials or engineering controls
TABLE 1
Table 1 Fully and properly implemented Not required to separately comply with PEL, exposure assessment, or methods https://theferrigroup.co/resources/
1926.1153(c)(1) Table 1 18 instances of equipment/task, engineering and work practice controls, and respiratory protection with APF Water delivery systems, dust collection, and HEPA-filtered vacuums. 99% or greater efficiency or filter-cleaning mechanisms specified
Table 1 Suggested Approach Identify tasks that could expose employees to RCS Compare task list to Table 1 Implement Table 1 controls Suggest using contract language to ensure subs responsible for following Table 1
1926.1153(c)(1) Table 1 Indoor or enclosed area tasks require means of exhaust to minimize accumulation of visible airborne dust Work practice controls to limit entry to indoor/enclosed areas with RCS exposure GC//Area ventilation? Business decision.
Emphasis on Engineering Reliable, predictable, consistent Can monitor continually and easily Not susceptible to human error Lowers exposure for others
Wet/HEPA Methods Not safe and effective in all situations Standard allows for dry sweeping, dry brushing, or compressed air for cleaning OSHA expects this to be extremely limited Must use ventilation + compressed air
Alternative Exposure Control When tasks are not listed on Table 1 When employer does not fully and properly implement Table 1 controls
Alternative Exposure Control Performance Option Assess 8-hour TWA for each employee using air monitoring and/or objective data
Alternative Exposure Control Scheduled Monitoring Option (part 1) Initial 8-hour TWA for each employee, 1 or more breathing zone samples, each shift, each job, each work area Representative samples may be done
Alternative Exposure Control Scheduled Monitoring Option (part 2) If initial monitoring < Action Level, discontinue monitoring. If at or above AL, but at or below PEL, repeat within 6 months. If above PEL, repeat monitoring w/in 3 months
Alternative Exposure Control Scheduled Monitoring Option Most recent, non-initial below AL, repeat within 6 months until 2 consecutive measurements, 7 or more days apart, are <AL Monitoring can then be discontinued unless otherwise required.
Alternative Exposure Control Scheduled Monitoring Option Reassess when changes in production, process, controls, personnel, or work practices could result in new or + exposures or if exposures could have occurred. Labs must follow Appendix A.
Employee Notification Within five working days In writing Post results Include corrective actions when over PEL
CHOOSE THE RIGHT TOOLS FOR DUST CONTROL
Local Exhaust Ventilation Systems (LEV) Recommended for construction applications with concrete grinders, cut-off saws and tuck-pointing LEV dust control includes a shroud that encloses most of the grinding wheel, a length of flexible hose, and an industrial vacuum cleaner System can reduce respirable crystalline silica dust exposure by 5-20 times Source: Centers for Disease Control and Prevention
Housekeeping Procedures Prohibits the use of the following methods for cleaning surfaces and clothing*: Compressed air Dry brushing Dry sweeping Promotes the use of wet methods and HEPA-filtered vacuuming for all housekeeping involving silica dust collection * Unless recommended methods are not feasible
Vacuum Filtration Requirements For cleanup, high-efficiency particulate air (HEPA) filter. According to OSHA s definition, a HEPA filter is 99.97% efficient in removing particles of 0.3 micron in diameter. True HEPAs are individually tested and certified by a 3 rd party. For dust collectors, filters with a capture efficiency of 99 percent or greater for respirable particulate (Example, filter efficiency range from 99% @ 0.5 micron to 99.97% @ 3 micron)
Importance of Filtration Multi-stage/graduated filtration HEPA/ULPA efficiency Filter cleaning options Maintenance indicators Large surface area (Low ATC Air-to-Cloth ratio)
Dust Collection at Grinder Requirements Minimum 25 CFM per inch of grinding blade diameter Equipped with a cyclonic preseparator to collect large debris before the air reaches the filters or be equipped with a filter cleaning mechanism (like PullClean or InfiniClean)
Additional Vacuum Requirements Central vacuum systems allowed, but must discharge respirable crystalline silica outside of the workplace The hose connecting the tool to the vacuum must be intact and without kinks or tight bends that would prevent the vacuum from providing the air flow recommended by the tool manufacturer
Features of Industrial Strength Vacuums Rugged, durable construction Collection options Wet/dry models Ergonomic design Auto tool outlet Low decibel level Pressure gauge
Recommended Work Practices Keep the exhaust entry point flat against the surface. Shake the hose as needed to loosen the settled dust and prevent the hose from clogging. Work against the rotation of the blade. The tool must be flat and positioned so that the dust from grinding is blown into the exhaust hose. Change vacuum cleaner bags before they leak, break, or cause too much resistance to air flow. Put the vacuum cleaner below the work level to keep dust from falling out of the hose. Even when the amount of hazardous dust has been decreased by the control, less restrictive respirators may still be necessary. Source: Centers for Disease Control and Prevention
1926.1153(g) WRITTEN EXPOSURE CONTROL PLAN
Identification of Tasks Tasks that involve RCS exposure Use current scope, tasks, JHA/JSAs
Description of Controls Refer to Table 1 For tasks not on Table 1, indicate controls that will be used and where/if engineering controls are not feasible
Controls Engineering and work practice controls unless not feasible If controls do not reduce exposure to at or below PEL = respiratory protection
(Respiratory Protection) Comply with 1910.134 when Table 1 requires respirators Wear when Table 1 controls not fully and properly implemented Wear when installing or implementing feasible engineering and work practice controls When PEL is exceeded
(Respiratory Protection) Employer is in compliance when respiratory protection is worn as prescribed in Table 1 and following 1910.134
Housekeeping Measures Include any instances that compressed air, dry sweeping, or dry brushing will be used.
Procedures to Restrict Access Multi-Employer Worksites OSHA expects employers or competent person(s) to work with GC to avoid high exposures of employees working alongside others generating RCS. OSHA suggestion: work scheduling to avoid exposure
Review Availability of Plan Indicate how plan will be available for viewing, copying, etc by employees, designees, OSHA Review as operations change
Competent Person Designate a CP who can implement the employer s written exposure control plan regardless of size of employer Smaller companies may need more people trained to competency level
Respirable Crystalline Silica SUMMARY
Exposure Control Program Identify tasks with RCS Compare the tasks to Table 1 Update Respiratory Protection Program if needed Invest in efficient, compliant tools Implement Alternative Controls Conduct training Evaluate Adjust
Resources Special Emphasis Program (1996), Silica etool: https://www.osha.gov/dsg/etools/ silica/spec_emph_prog/spec_em ph_prog.html ASTM E2625-09 Standard Practice for Controlling Occupational Exposure to RCS for Construction and Demolition Activities: http://www.astm.org/standards/e 2625.htm
Resources CPWR Create-A-Plan: http://plan.silica-safe.org/ https://www.osha.gov/silica/ http://www.cdc.gov/niosh/topics/silica/ http://news.nilfiskcfm.com, search Silica for up-to-date info on the standard
Questions Thank You Abby Ferri, CSP www.theferrigroup.co Text: 612 567 9981 @theferrigroup AbbyCSP Mark Cunningham www.nilfiskindustrialvacuums.com Mark.Cunningham@nilfisk.com @nilfiskvacsus Nilfisk Industrial Vacuums