Silica Exposure Control Program The University Of Iowa Environmental Health & Safety 122 Grand Avenue Court Iowa City, IA 52242-1000 Phone: 319-335-8501 Date Revised/Reviewed: 5/11/2018
Table of Contents 1. Purpose... 2 2. Scope... 2 3. Policy and Regulation... 2 4. Definitions... 2 5. Roles and Responsibilities... 3 6. Program Requirements... 4 a. Exposure Assessment... 4 i. Initial Exposure Assessment... 4 ii. Periodic Exposure Assessment... 4 iii. Reassessment of Exposures... 5 iv. Employee Notification... 5 b. Regulated Areas... 5 c. Written Exposure Control Plan... 5 d. Engineering and Work Practice Controls... 5 e. Housekeeping... 5 f. Medical Services... 6 g. Hazard Communication... 6 7. Training... 6 8. Reviews and Audits... 7 a. Departmental Reviews... 7 b. EHS Audits... 7 Appendix A - Written Exposure Control Plan... 8 Appendix B 1926.1153(c)(1) Table 1... 9 Appendix C Danger Sign for Posting in Regulated Areas... 16 1 Page
1. Purpose Under the new Occupational Safety and Health Administration s (OSHA) Silica standard (29 CFR 1910.1053), the University is required to have a Silica Exposure Control Program (SECP). The SECP describes the hazards associated with silica dust, outlines the steps to ensure employees who work with or around silica are not exposed to hazardous levels of silica dust, and provides procedures to minimize exposures for common silica related work duties. 2. Scope This program covers University employees who work with silica, establishes the minimum requirements for working with silica, and applies to employees who are exposed over the action level. 3. Policy and Regulation University of Iowa Operations Manual, Part III Human Resources, Division II Standards and Ethics, Chapter 16.4d Policy on Ethics and Responsibilities for University of Iowa Staff. OSHA Regulation, 29 CFR 1910.1053, Respirable crystalline silica. 4. Definitions For the purposes of this section, the following definitions apply: Action Level: a concentration of airborne respirable crystalline silica of 25 μg/m 3, calculated as an 8-hour time weighted average (TWA). Assistant Secretary: the Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor, or designee. Director: the Director of the National Institute for Occupational Safety and Health (NIOSH), U.S. Department of Health and Human Services, or designee. Employee Exposure: the exposure to airborne respirable crystalline silica that would occur if the employee were not using a respirator. High-Efficiency Particulate Air (HEPA) Filter: a filter that is at least 99.97 percent efficient in removing monodispersed particles of 0.3 micrometers in diameter. A P100 or N100 cartridge meets the definition of HEPA. Objective Data: information, such as air monitoring data from industry-wide surveys or calculations based on the composition of a substance, demonstrating employee exposure to respirable crystalline silica associated with a particular product or material or a specific process, task, or activity. The data must reflect workplace conditions 2 Page
closely resembling or with a higher exposure potential than the processes, types of material, control methods, work practices, and environmental conditions in the employer's current operations. Permissible Exposure Limit (PEL): an airborne concentration of respirable crystalline silica in excess of 50 μg/m 3, calculated as an 8-hour TWA. Physician or Other Licensed Health Care Professional (PLHCP): an individual whose legally permitted scope of practice (i.e., license, registration, or certification) allows him or her to independently provide or be delegated the responsibility to provide some or all of the particular health care services required by paragraph (i) of this section. Regulated Area: an area, demarcated by the employer, where an employee's exposure to airborne concentrations of respirable crystalline silica exceeds, or can reasonably be expected to exceed, the PEL. Respirable Crystalline Silica: means 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 respirable-particle size-selective samplers specified in the International Organization for Standardization (ISO) 7708:1995: Air Quality-Particle Size Fraction Definitions for Health-Related Sampling. Specialist: means an American Board Certified Specialist in Pulmonary Disease or an American Board Certified Specialist in Occupational Medicine. 5. Roles and Responsibilities Deans, Directors and Department Heads are responsible to: Designate and empower the department s Health and Safety Coordinator (or Program Coordinator or equivalent) and supervisors. Actively support these procedures within individual units. Ensure an environment where employees are encouraged to follow these procedures. The Department Health and Safety Coordinator is responsible to: Act as an administrative liaison between the department and EHS. Provide administrative oversight of health and safety within the department. Facilitate the correction of safety problems within the department. Supervisors are responsible to: Implement these procedures. Assure that staff is aware of this program and provided with training and the personal protective equipment. Maintain documentation and records as required. 3 Page
Employees are responsible to: Comply with these procedures and any further safety requirements set by supervisors. EHS is responsible to: Provide procedural guidelines, educational offerings, administrative consultations and reviews, and select technical and field services. Exercise surveillance over health and safety issues at the University. Developing training related to silica. Conducting a yearly audit of each department s program. Conducting qualitative assessments to determine the need for a SECP for the department. Conducting exposure monitoring for silica exposure. 6. Program Requirements a. Exposure Assessment i. Initial Exposure Assessment Exposure monitoring will be conducted on any employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level. Some activities at the UI that might have an exposure risk are working with sandstone samples at a geological survey, sand blasting, art involving ceramics, ground and landscaping crews, and cutting cement. Exposure monitoring is not required if the task is listed in 29 CFR 1926.1153(c)(1) and the engineering controls, work practices, and PPE listed are used as listed. (See Appendix B.) ii. Periodic Exposure Assessment If the most recent results are at or above the action level but are below the PEL, monitoring shall be repeated every 6 months. If the most recent results are at or above the PEL, monitoring shall be repeated every 3 months. Periodic exposure monitoring may be discontinued if results from two consecutive sampling periods taken at least 7 days apart show that employee exposure is below the action level. 4 Page
iii. Reassessment of Exposures Whenever a change in the production, process, control equipment, personnel, or work practices may reasonably be expected to result in new or additional exposures at or above the action level, monitoring shall be conducted. iv. Employee Notification Within 15 workdays after the completion of the exposure assessment, employee(s) shall be notified in writing of the results of the assessment or the results will be posted in an appropriate location accessible to all affected employees. If the result is above the PEL, the notification will include the means that are being taken to reduce the exposure to below the PEL. b. Regulated Areas Anywhere the exposure is above the PEL, a regulated area will be established. The regulated area must be separated from other areas in a way to minimize the number of employees exposed. At each entrance of a regulated area, the sign in Appendix C must be posted. Only employees who have work to perform in the area are allowed to enter the area. All employees entering the regulated area must wear a respirator, regardless of the amount time spent in the area. c. Written Exposure Control Plan For each area that has an exposure over the action level, a written exposure control plan must be developed. An outline of a written exposure control plan is in Appendix A. The exposure control plan includes a description of the task(s) being done that involve(s) silica and all of the controls that are in place to minimize potential employee exposures. The plan must be reviewed at least annually. d. Engineering and Work Practice Controls Anywhere the exposure is above the PEL, engineering controls (i.e. wet work, ventilation) or work practice controls (i.e. housekeeping, inspections, scheduling) will be implemented to lower the exposure as much as possible. e. Housekeeping Cleaning of silica dust will be conducted with wet sweeping methods or HEPAfiltered vacuum cleaners. These methods will minimize the likelihood of exposure. 5 Page
Only if other methods are not feasible can compressed air and/or dry sweeping be used. f. Medical Services Any employee who is exposed above the action level for 30 or more days per year will be provided medical surveillance at no cost. The medical surveillance is performed initially and at least every 3 years, unless more frequently recommended by a PLHCP. The medical examination will include medical and work history, a physical exam, chest x-ray, pulmonary function, tuberculosis test, and any other test recommended by the PLHCP. The department will provide the following information to the PLHCP: the employee s duties as they relate to silica exposure, results of air sampling, and the PPE that is used. A written report on the results will be provided to the employee within 30 days. g. Hazard Communication Silica must be included in the department s hazard communication program. This includes properly labeling and having a Safety Data Sheet (SDS). 7. Training Any employee who is exposed to silica above the action level is required to complete a silica safety training course on an annual basis. University employees will complete the ICON course, W535OS Respirable Crystalline Silica Safety, that provides general silica safety training, in addition, site-specific training provided by the department must also be completed. The ICON training course will include the health hazards of silica, how to control silica exposure, and the contents of the OSHA silica standard (1910.1053). The site-specific training will cover the information in Appendix A of this program, including the specific tasks that lead to silica exposure and specific methods used to lower the exposure. ICON training records are maintained in the University s Employee Self Service My Training site. 6 Page
8. Reviews and Audits a. Departmental Reviews Each department shall review its written exposure control plan on an annual basis. The review shall consist of determining if the task and controls are still being used as described and if the plan is effective in reducing silica exposure. b. EHS Audits EHS will audit each department with an SECP on a yearly basis. The audit will cover all aspects of the written program to ensure they are up to date and complete. The audit will also include a walkthrough of the area to check for appropriate labels, warning signs, and housekeeping. 7 Page
Appendix A - Written Exposure Control Plan Department: Plan Creators: Review Date: Description of Tasks: Engineering Controls: Work Practices: Respiratory Protection: Housekeeping Procedures: 8 Page
Appendix B 1926.1153(c)(1) Table 1 Required respiratory protection and minimum assigned protection factor (APF) Equipment/task (i) Stationary masonry saws (ii) Handheld power saws (any blade diameter) Engineering and work practice control methods Use saw equipped with integrated water delivery system that continuously feeds water to the blade. Use saw equipped with integrated water delivery system that continuously feeds water to the blade. minimize dust emissions: 4 hours/shift >4 hours/shift -When used outdoors APF 10 -When used indoors or in an enclosed area. APF 10 APF 10 (iii) Handheld power saws for cutting fiber-cement board (with blade diameter of 8 inches or less) For tasks performed outdoors only: Use saw equipped with commercially available dust collection system. minimize dust emissions Dust collector must provide the airflow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency. (iv) Walk-behind saws Use saw equipped with integrated water delivery system that continuously feeds water to the blade. 9 Page
minimize dust emissions: -When used outdoors. -When used indoors or in an enclosed area. APF 10 APF 10 (v) Drivable saws For tasks performed outdoors only: Use saw equipped with integrated water delivery system that continuously feeds water to the blade. (vi) Rig-mounted core saws or drills Use tool equipped with integrated water delivery system that supplies water to cutting surface. (vii) Handheld and stand-mounted drills (including impact and rotary hammer drills) Use drill equipped with commercially available shroud or cowling with dust collection system. Dust collector must provide the airflow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism. Use a HEPA-filtered vacuum when cleaning holes. (viii) Dowel drilling rigs for concrete For tasks performed outdoors only: 10 Page
Use shroud around drill bit with a dust collection system. Dust collector must have a filter with 99% or greater efficiency and a filter cleaning mechanism. Use a HEPA-filtered vacuum when cleaning holes. APF 10 APF 10 (ix) Vehicle-mounted drilling rigs for rock and concrete (x) Jackhammers and handheld powered chipping tools Use dust collection system with close capture hood or shroud around drill bit with a low-flow water spray to wet the dust at the discharge point from the dust collector. OR Operate from within an enclosed cab and use water for dust suppression on drill bit. Use tool with water delivery system that supplies a continuous stream or spray of water at the point of impact: -When used outdoors. APF 10 -When used indoors or in an enclosed area. OR Use tool equipped with commercially available shroud and dust collection system. Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism: APF 10 APF 10 -When used outdoors. APF 10 -When used indoors or in an enclosed area. APF 10 APF 10 11 Page
(xi) Handheld grinders for mortar removal (i.e., tuckpointing) (xii) Handheld grinders for uses other than mortar removal Use grinder equipped with commercially available shroud and dust collection system. Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic preseparator or filter-cleaning mechanism. For tasks performed outdoors only: Use grinder equipped with integrated water delivery system that continuously feeds water to the grinding surface. OR Use grinder equipped with commercially available shroud and dust collection system. APF 10 APF 25 Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic preseparator or filter-cleaning mechanism: -When used outdoors. -When used indoors or in an enclosed area. APF 10 12 Page
(xiii) Walk-behind milling machines and floor grinders Use machine equipped with integrated water delivery system that continuously feeds water to the cutting surface. OR Use machine equipped with dust collection system recommended by the manufacturer. Dust collector must provide the air flow recommended by the manufacturer, or greater, and have a filter with 99% or greater efficiency and a filtercleaning mechanism. When used indoors or in an enclosed area, use a HEPAfiltered vacuum to remove loose dust in between passes. (xiv) Small drivable milling machines (less than half-lane) Use a machine equipped with supplemental water sprays designed to suppress dust. Water must be combined with a surfactant. Operate and maintain machine to (xv) Large drivable milling machines (half-lane and larger) For cuts of any depth on asphalt only: Use machine equipped with exhaust ventilation on drum enclosure and supplemental water sprays designed to suppress dust. Operate and maintain machine to For cuts of four inches in depth or less on any substrate: 13 Page
Use machine equipped with exhaust ventilation on drum enclosure and supplemental water sprays designed to suppress dust. Operate and maintain machine to OR Use a machine equipped with supplemental water spray designed to suppress dust. Water must be combined with a surfactant. Operate and maintain machine to (xvi) Crushing machines Use equipment designed to deliver water spray or mist for dust suppression at crusher and other points where dust is generated (e.g., hoppers, conveyers, sieves/sizing or vibrating components, and discharge points). Operate and maintain machine in Use a ventilated booth that provides fresh, climatecontrolled air to the operator, or a remote control station. (xvii) Heavy equipment and utility vehicles used to abrade or fracture silicacontaining materials (e.g., hoe-ramming, rock ripping) or used during demolition activities involving silica-containing materials Operate equipment from within an enclosed cab. When employees outside of the cab are engaged in the task, apply water and/or dust suppressants as necessary to (xviii) Heavy equipment and utility vehicles for tasks such as grading and excavating but not including: Apply water and/or dust suppressants as necessary to OR 14 Page
Demolishing, abrading, or fracturing silica-containing materials When the equipment operator is the only employee engaged in the task, operate equipment from within an enclosed cab. 15 Page
Appendix C Danger Sign for Posting in Regulated Areas 16 Page
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