Respirable Crystalline Silica

29 CFR 1 Overview What is Crystalline Silica OSHA Fact Sheets available OSHA Regulations Old vs New Definitions Exposure Control Methods Table 1 Alternative Exposure Control Methods Respiratory Protection Housekeeping Written Exposure Control Plan Medical Exam Medical Surveillance Training Requirements Recordkeeping 2 January 2017 1

Course Objectives At the conclusion of this presentations the participant shall be able to: Describe specific terms related to to include Competent Person, Action Level Employee Exposure and HEPA Filter definitions Explain exposure control methods employers must use to protect workers from exposure Identify engineering and work practice controls, their methods and the required PPE to protect workers using Table 1 Describe monitoring options when using alternative exposure control methods Explain housekeeping options using HEPA filtered vacuums, sweeping options and dust collection systems Describe medical examination and surveillance requirements Understand training requirements for workers Identify types of data and information required to be maintained for the record 3 Silica Timeline 1971: OSHA issues initial silica regulation limiting PEL to 250 micrograms per cubic meter. 1974, NIOSH recommends a PEL of 50 μg/m 3 for a 10 hour shift. 1998, OSHA moves occupational exposure to crystalline silica to the prerule stage. September 2013 silica rule is published. The new silica rule was published in the Federal Register on March 25, 2016. June 23, 2016 the final rule went into effect. December 23, 2017 employers are required to comply with all obligations of the standard (except methods of sample analysis) June 23, 2018 construction employers are required to comply with methods of sample analysis. 4 January 2017 2

What is SiO 2 silicon dioxide Also known as free silica Significantly more hazardous than amorphous silica 3 mineralogical forms Quartz most common (9.11.01 illnesses) Cristobalite (polymorph) Tridymite (volcanic rock) 5 What is Defined as 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 sizeselective samplers specified in the International Organization for Standardization (ISO) 7708:1995: Air Quality Particle Size Fraction Definitions for Health Related Sampling. 6 January 2017 3

What is Silicosis: No known cure Chronic (20 40 years) Accelerated (5 15 years) Acute (within 5 years) Lung cancer Tuberculosis (TB) Chronic obstructive pulmonary disorder (COPD) Kidney disease Stomach cancer Autoimmune diseases: lupus and vasculitis 7 What is Symptoms of Silicosis: Shortness of breath Coughing or wheezing Fever Fatigue Loss of appetite Occasional bluish coloring of the skin at the ear lobes or lips. 8 January 2017 4

What is Development of silicosis is dependent on: Size of the crystalline silica dust particle With respirable particles smaller than 5 micrometers being the most hazardous The percentage of crystalline silica in the dust in the air Dustconcentration that is breathed Duration of exposure Silicosis was associated with 13,744 U.S. fatalities from 1968 1990. OSHA estimates 300 U.S. workers currently die each year from Silicosis Tuck points and sand blasting are the #1 silica exposure 9 OSHA s Crystalline Silica Rule: Construction Who is affected by the construction standard? About 2 million construction workers are exposed in over 600,000 workplaces Estimated that more than 840,000 workers are exposed to silica levels that exceed the new PEL Estimated the standards will Save the lives of more than 600 workers each year Prevent more than 900 cases of silicosis each year 10 January 2017 5

OSHA s Crystalline Silica Rule: Construction Exposure to respirable crystalline silica can cause silicosis, lung cancer, other respiratory diseases, and kidney disease Exposure can occur during common construction tasks: Handheld Powered Chipping Tools Grinders Drills Operating Vehicle mounted Drilling Rigs Masonry Saws Milling Operating Crushing Machines Jackhammers Using Heavy Equipment For Demolition 11 OSHA s Crystalline Silica Rule: Construction The construction standard does not apply where exposures will remain low under any foreseeable conditions such as: Mixing mortar Pouring concrete footers Slab foundation Foundation walls Removing concrete formwork 12 January 2017 6

Alternative exposure control methods Measure silica exposure > action level of 25 μg/m3, averaged over an 8 hour day Protect workers exposures > PEL limit of 50 μg/m3, averaged over an 8 hour day Limit workers access to exposure Use dust controls to protect workers Provide respirators to workers when dust controls cannot limit exposures to the PEL Restrict housekeeping practices that expose workers to silica Establish and implement a written exposure control plan Competent Person (Construction) Offer medical exams Chest x ray Every 3 years, wear respirator 30 days Train workers on and ways to limit exposure Keep records of workers silica exposure and medical exams ug/m3 = (micrograms of silica per cubic meter of air) 13 Silica Rule: Construction Table 1 Common construction tasks with dust control Employers know exactly what they need to do to limit worker exposures to silica The dust control measures: Water to keep dust from getting into the air Using ventilation to capture dust In some operations, respirators may also be needed Employers who follow Table 1 correctly are not required to measure workers exposure to silica and are not subject to the PEL 14 January 2017 7

OSHA s Crystalline Silica Rule: General Industry Most abundant substance on earth Commonly found as sand or quartz 100 times smaller than a grain of sand on the beach These tiny particles (known as respirable particles) can penetrate deep into workers lungs and cause silicosis, an incurable and sometimes fatal lung disease Commonly used construction materials including: Concrete Mortar Rocks Bricks Artificial Stone Asphalt Stones Topsoil 15 OSHA s Crystalline Silica Rule: General Industry Construction Foundries Cut Stone and Stone Products What Industries Are Affected? General Industry Dental Laboratories Abrasive Blasting Glass Manufacturing Paintings and Coatings Railroad Transportation Pottery Products Jewelry Production Oil and Gas Operations Structural Clay Products Refractory Products Concrete Products Ready mix Concrete Refractory Furnace Installation and Repair 16 January 2017 8

OSHA Regulations Old vs New New PEL for respirable crystalline silica is 50 micrograms per cubic meter of air (NIOSH recommended same level in 1974) New PEL is half the previous limit for general industry and 5times lower than the previous limit for construction Action Level of 25 micrograms per cubic meter creates the need for employee monitoring if Table 1 is not used. 17 OSHA Regulations Old vs New New rule was issued by OSHA on March 25, 2016. Construction standard requires employers comply by December 23, 2017 Under the general industry and maritime standard, employers have until June 23, 2018 If you perform both Construction & General Industry work then always follow the construction rule, this eliminates the monitoring requirement 18 January 2017 9

Scope and Application 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 as an 8 hour timeweighted average (TWA) under any foreseeable conditions The standard requires employers to: Limit worker exposures to respirable crystalline silica Take other steps to protect workers 19 Definitions A Competent Person An individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace Who has authorization to take prompt corrective measures to eliminate or minimize them A Competent Person can also have other responsibilities The identity of the Competent Person is not required to be named in the written Exposure Control Plan 20 January 2017 10

Definitions Action level A concentration of airborne respirable crystalline silica of 25 μg/m3, calculated as an 8 hour TWA 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 mono dispersed particles of 0.3 micrometers in diameter 21 Definitions 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 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 22 January 2017 11

Definitions 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 (h) Medical surveillance 23 Exposure Control Methods Employers have a choice between: 1. Control methods described in Table 1 Fully and properly implement: Engineering controls Work practices, AND Respiratory protection specified 2. Measure worker exposure to silica and independently decide which dust control measures work best to keep levels below the PEL If a company has a better idea than using Table 1 it needs to be proved by measuring and sampling. 24 January 2017 12

Exposure Control Methods Indoors / Enclosed Area Provide a means of exhaust as needed to minimize the accumulation of visible airborne dust Wet Method Tasks Apply water at flow rates sufficient to minimize release of visible dust Enclosed Cab or Booth Maintained as free as practicable from settled dust Working door seals and closing mechanisms Gaskets and seals that are in good condition and working properly Under positive pressure maintained continuous delivery of fresh air Intake air is filtered through a filter that is 95% efficient Heating and cooling capabilities 25 26 January 2017 13

Exposure Control Methods More than one task on Table 1 during the course of a shift Duration of all tasks > 4 hours Required Respiratory Protection is > 4 hours Duration of all tasks < 4 hours Required Respiratory Protection is < 4 hours 27 Alternative Exposure Control Methods Tasks not listed in Table 1, or When employer does not fully and properly implement the engineering controls, work practices, and respiratory protection described in Table 1 Permissible exposure limit (PEL) Ensure that no employee is exposed to an airborne concentration of respirable crystalline silica in excess of 50 μg/m3 Calculated as an 8 hour TWA 28 January 2017 14

Alternative Exposure Control Methods Exposure assessment Assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level in accordance with either the Performance option Assessing the 8 hour TWA exposure for each employee, OR Any combination of air monitoring data or objective data of exposure Schedule monitoring option Perform initial monitoring to assess the 8 hour TWA exposure Each shift, for each job classification, in each work area 29 Alternative Exposure Control Methods Scheduled Monitoring Option 1. Initial Monitoring Assess the 8 hour TWA exposure Each shift, for each job classification, in each work area Monitoring indicates exposures are below the action level the employer may discontinue monitoring 2. Recent Monitoring Indicates exposures are above the PEL, repeat monitoring within three months Indicates exposures are at or above the action level but at or below the PEL, repeat monitoring within six months 3. Recent (non initial) Monitoring Indicates exposures are below the action level, repeat monitoring within six months until two consecutive measurements, taken seven or more days apart, are below the action level, monitoring may be discontinued 30 January 2017 15

Alternative Exposure Control Methods Reassessment of exposures whenever: Change in the production Process, control equipment Personnel change Work practices with new or additional exposures at or above action level Any reason to believe that new or additional exposures have occurred Methods of sample analysis Evaluated by a laboratory that analyzes air samples for respirable crystalline silica in accordance with the procedures 31 Alternative Exposure Control Methods Notification of assessment results Within five working days after completing assessment Individually notify each affected employee in writing, OR Results posted in an appropriate location accessible to affected employees When exposure assessment indicates exposure is above the PEL Employer shall describe in the written notification the corrective action being taken to reduce employee exposure to or below the PEL Observation of monitoring Affected employees are allowed to observe any monitoring of exposure During observation any required PPE shall be provided at no cost 32 January 2017 16

Respiratory Protection Employer must provide appropriate respirator When specified by Table 1 For tasks not listed in Table 1 Where the employer does not fully and properly implement the engineering controls and work practices Exposures exceed the PEL during installation or implementation of controls or practices Exposures exceed the PEL during tasks, certain maintenance and repair tasks, for which controls or practices are not feasible During tasks where all implemented engineering and work practice controls are not sufficient to reduce exposures to or below the PEL 33 Respiratory Protection When respirators are required the employer shall institute a respiratory protection program in accordance with 29 CFR 1910.134 When using a dust mask, it requires Fit Testing, wearer instructions are on the box Specified exposure control methods Considered to be in compliance when employer fully and properly implement engineering controls, work practices and respiratory protection 34 January 2017 17

Housekeeping Dry sweeping or dry brushing are not allowed where such activity could contribute to employee exposure unless: Wet sweeping, HEPA filtered vacuuming or other methods that minimize the likelihood of exposure are not feasible. Using compressed air to clean clothing or surfaces is not allowed, unless: The compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air No alternative method is feasible 35 Housekeeping Vacuum Filtration for Clean up OSHA requires HEPA filtered vacuuming for cleanup: When cleaning holes from handheld and stand mounted drills When cleaning holes from dowel drilling rigs for concrete To remove loose dust between passes when using walk behind milling machines and floor grinders indoors or in an enclosed area * HEPA Filtered Vacuum is defined as 99.97% efficient @ 0.3 microns 36 January 2017 18

Housekeeping Dust Collectors Required situations: When using handheld power saws Blade diameter < 8 inches, to cut fiber cement board outside When cleaning holes from handheld and stand mounted drills Including impact and rotary hammer drills Using jackhammers and handheld powered chipping tools Using handheld grinders for mortar removal and other uses Must also provide airflow of > 25 cubic feet/minute (CFM) and have a cyclonic pre separator or filter cleaning mechanism 37 Written Exposure Control Plan Elements to be establish and implement: 1. A description of the tasks in the workplace that involve exposure 2. A description of the engineering controls, work practices, and respiratory protection used to limit employee exposure for each task 3. A description of the housekeeping measures used to limit employee exposure 4. A description of the procedures used to restrict access to work areas Plan reviewed and evaluated at least annually and update as necessary Plan readily available for examination and copying, upon request by employee Employer designates a competent person to make frequent and regular inspections of job sites, materials, and equipment 38 January 2017 19

On the Job Exposure Control Plan Task Cut through brick and mortar for a door opening Time to Complete Task 8 hours by two workers Note: Only workers on job site Table 1 Requires 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. Required Respiratory Protection APF10 Respirator Tool / Equipment Handheld Power Saw Plan for Workers 39 Medical Exam Questions: When a pre hire medical exam is provided when does the company s liability start if a condition is discovered? Does the company own the medical treatment? OSHA suggests employers to consult with an Industrial Hygienist to determine monitoring needs and requirements. 40 January 2017 20

Medical Exam When an employee will be exposed to silica dust hazard for more than 30 days in one year: Employer required to offer an employee a medical exam. Employee can voluntarily sign a waiver of refusal of the medical exam. Medical exams required every three years. If employee is exposed 29 days with company X the exposure resets with company Y to 0 days of exposure, exposed days do not carry over. Note: Any exposure of any kind even for one minute or one hour equals one day of exposure. 41 (h) Medical Surveillance Medical surveillance available for employees: That use a respirator for 30 or more days per year Provided at a reasonable time and place Medical examinations and procedures performed by a PLHCP Physician or other licensed health care professional [PLHCP] means 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 42 January 2017 21

Medical Surveillance Initial examination Make available an initial (baseline) medical examination within 30 days after initial assignment Unless the employee has received a medical examination that meets current requirements within the last three years Examination shall consist of: A medical and work history, with emphasis on: past, present, and anticipated exposure to respirable crystalline silica, dust, and other agents affecting the respiratory system; any history of respiratory system dysfunction, including signs and symptoms of respiratory disease (e.g., shortness of breath, cough, wheezing); history of tuberculosis; and smoking status and history A physical examination with special emphasis on the respiratory system A chest X ray A pulmonary function test Testing for latent tuberculosis infection Any other tests deemed appropriate by the PLHCP 43 Medical Surveillance Periodic examinations Make available at least every 3 years, or more frequently if recommended by PLHCP PLHCP shall have copy of this standard along with: A description of the employee s former, current, and anticipated duties as they relate to the employee s occupational exposure to respirable crystalline silica The employee s former, current, and anticipated levels of occupational exposure to respirable crystalline silica A description of any PPE used or to be used by the employee, including when and for how long the employee has used or will use that equipment Information from records of employment related medical examinations previously provided to the employee and currently within the control of the employer 44 January 2017 22

Medical Surveillance Employee is provided written results within 30 days of each medical examination: A statement indicating the results of the medical examination, including any medical condition(s) that would place the employee at increased risk of material impairment to health from exposure to respirable crystalline silica and any medical conditions that require further evaluation or treatment; Any recommended limitations on the employee s use of respirators Any recommended limitations on the employee s exposure to respirable crystalline silica A statement that the employee should be examined by a specialist if the chest X ray provided is classified as 1/0 or higher by the B Reader, or if referral to a specialist is otherwise deemed appropriate by the PLHCP 45 Medical Surveillance PLHCP s written medical opinion for the employer. The employer shall obtain a written medical opinion from the PLHCP within 30 days of the medical examination. The written opinion shall contain only the following: The date of the examination A statement that the examination has met the requirements of this section Any recommended limitations on the employee s use of respirators If the employee provides written authorization, the written opinion shall also contain either or both of the following: Any recommended limitations on the employee s exposure to respirable crystalline silica A statement that the employee should be examined by a specialist 46 January 2017 23

Medical Surveillance Additional examinations When an employee needs to be examined by a specialist, it should be within 30 days The examining specialist is provided with all of the information needed The specialist results of the medical examination provided to employee in writing within 30 days The employer shall obtain a written opinion from the specialist within 30 days of the medical examination Specialist means an American Board Certified Specialist in Pulmonary Disease or an American Board Certified Specialist in Occupational Medicine. 47 Hazardous Communication Training for Hazards Trained in accordance with 1910.1200 Employee has access to labels on containers of crystalline silica Safety data sheets available for review Employee able to demonstrate knowledge and understanding of exposure hazards The health hazards associated with exposure to respirable crystalline silica Hazards to be covered: cancer, lung effects, immune system effects, and kidney effects of exposure Specific tasks in the workplace that could result in exposure to respirable crystalline silica Specific measures the employer has implemented to protect employees from exposure The identity of the competent person designated by the employer The purpose and a description of the medical surveillance program A copy of this standard shall be made available 48 January 2017 24

Recordkeeping Air monitoring data The employer shall make and maintain an accurate record of all exposure measurements taken to assess employee exposure to respirable crystalline silica This record shall include at least the following information: The date of measurement for each sample taken The task monitored Sampling and analytical methods used Number, duration, and results of samples taken Identity of the laboratory that performed the analysis Type of personal protective equipment, such as respirators, worn by the employees monitored Name, social security number, and job classification of all employees represented by the monitoring, indicating which employees were actually monitored The employer shall ensure that exposure records are maintained and made available 49 Recordkeeping The employer shall make and maintain an accurate record of all objective data: The crystalline silica containing material in question The source of the objective data The testing protocol and results of testing A description of the process, task, or activity on which the objective data were based Other data relevant to the process, task, activity, material, or exposures on which the objective data were based 50 January 2017 25

Recordkeeping Medical surveillance Employer makes and maintains an accurate record for each employee covered by medical surveillance The record shall include employee information: Name and social security number A copy of the PLHCPs and specialists written medical opinions A copy of the information provided to the PLHCPs and specialists 51 Summary Definitions Competent Person Action Level Employee Exposure HEPA Filter Explain exposure control methods Engineering and work practice controls Using Table 1 Alternative exposure control methods Housekeeping options HEPA filtered vacuums Sweeping options Dust collection systems Medical examination and surveillance requirements Training requirements for workers Recordkeeping 52 January 2017 26

Additional resources Small entity guidance https://www.osha.gov/publications/osha3902.pdf 53 January 2017 27