OSHA s Construction Standard for Occupational Exposure to Respirable Crystalline Silica 29 CFR 1926.1053 Joseph Coble ScD, CIH Director, Office of Technological Feasibility Directorate of Standards and Guidance Sven J. Rundman III Supervisory Industrial Hygienist Office of Health Enforcement Directorate of Enforcement Programs Occupational Safety and Health Administration Washington, DC
Health Effects Exposure to respirable crystalline silica has been linked to: Silicosis Lung cancer Chronic obstructive pulmonary disease Kidney disease
New Permissible Exposure Limit (PEL) Old PEL = 10 mg/m 3 (% Silica + 2) New PEL = 50 µg/m 3 as an 8-hour TWA Action Level = 25 µg/m 3 as an 8-hour TWA
Construction Standard 29 CFR 1926.1153 (a) Scope (b) Definitions (c) Specified exposure control methods OR (d) Alternative exposure control methods (1) PEL (2) Exposure Assessment (3) Methods of Compliance (e) Respiratory protection (f) Housekeeping (g) Written exposure control plan (h) Medical surveillance (i) Communication of silica hazards (j) Recordkeeping (k) Dates
Methods Protecting of Compliance Employees Hierarchy of Controls Hierarchy of Controls
Respirable Crystalline Silica Standard for Construction Two Choices For Employers: 1. Specified Exposure Controls 2. Alternative Exposure Controls Other Requirements: All employers
Construction Specified Exposure Control Methods Table 1 in the construction standard lists 18 tasks/tools with effective dust control methods and, in some cases, respirator requirements. Employers that fully and properly implement controls on Table 1 do not have to: Conduct exposure assessments for employees engaged in those tasks. Comply with the PEL.
List of Table 1 Tools/Tasks Stationary masonry saws Handheld power saws Handheld power saws for fiber cement board Walk-behind saws Drivable saws Rig-mounted core saws or drills Handheld and stand-mounted drills Dowel drilling rigs for concrete Vehicle-mounted drilling rigs for rock and concrete Jackhammers and handheld powered chipping tools Handheld grinders for mortar removal (i.e. tuckpointing) Handheld grinders for other than mortar removal Walk-behind milling machines and floor grinders Small drivable milling machines Large drivable milling machines Crushing machines Heavy equipment and utility vehicles to abrade or fracture silica materials Heavy equipment and utility vehicles for grading and excavating
TABLE 1: SPECIFIED EXPOSURE CONTROL METHODS WHEN WORKING WITH MATERIALS CONTAINING CRYSTALLINE SILICA Equipment / Task (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. When used outdoors. When used indoors or in an enclosed area. Operate and maintain tool in accordance with manufacturer s instructions to minimize dust emissions. Required Respiratory Protection and Minimum Assigned Protection Factor (APF) 4 hours /shift None APF 10 > 4 hours /shift APF 10 APF 10
Handheld Power Saw
Wet Methods 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. Check for: An adequate supply of water for dust suppression is used; The spray nozzle is working properly to apply water at the point of dust generation; All hoses and connections are intact. Cutting block using water to control the dust
Vacuum Dust Collection Systems 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 greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism. Check that: The shroud is intact and installed in accordance with the manufacturer s instructions; The hose connecting the tool to the vacuum is intact and without kinks or tight bends; The filter(s) on the vacuum are cleaned or changed in accordance with the manufacturer s instructions; and The dust collection bags are emptied to avoid overfilling.
Respiratory Protection Requirements on Table 1 Respirators are required where exposures above the PEL are likely to persist despite full and proper implementation of the specified engineering and work practice controls. Where respirators required, must be used by all employees engaged in the task for entire duration of the task. Provisions specify how to determine when respirators are required for an employee engaged in more than one task.
Alternative Exposure Control Methods Performance Option Must assess before work begins. Scheduled Monitoring Option Must assess as soon as work begins. Exposures assessed using any combination of air monitoring data or objective data sufficient to accurately characterize employee exposure to respirable crystalline silica. Can be within a range (i.e. between AL and PEL). If monitoring indicates: Initial below the AL: no additional monitoring Additional monitoring must be repeated: AL but PEL (within 6 months); or above PEL (within 3 months) When two consecutive non-initial results, taken 7 or more days apart, are below the AL, monitoring can be discontinued. Reassess if circumstances change.
Objective Data Includes air monitoring data from: Industry-wide surveys; Data provided by equipment manufacturers, trade or professional associations; or Calculations based on the composition of a substance. Demonstrates: Employee exposure associated with a particular product or material or a specific process, task, or activity. Reflects 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.
Other Provisions (e) Respiratory protection (f) Housekeeping (g) Written exposure control plan (h) Medical surveillance (i) Communication of silica hazards (j) Recordkeeping (k) Dates
Written Exposure Control Plan Employers must: Prepare and implement plan addressing: Exposure sources and Controls for each task Housekeeping measures to limit exposure Restricting access, when necessary to limit exposures Neil Lippy/Hoar Construction/elcosh.org Review plan yearly Make it available
Medical Surveillance For employees who will be required to wear a respirator under the standard for 30 or more days a year. Offered: Within 30 days of assignment Every three years to workers who continue to be exposed above the trigger. Exam includes medical and work history, physical exam, chest X-ray, and pulmonary function test (TB test on initial exam only).
Multi-Employer Worksites OSHA Instruction CPL 02-00-124: Multi-Employer Citation Policy, December 10, 1999 The policy provides specific information on the need to coordinate and communicate the hazardous conditions that workers might be exposed to when working with respirable crystalline silica. More than one employer may be citable for a hazardous condition that violates an OSHA standard.
Construction Compliance Guidance Interim Enforcement Memo Compliance Directive is being drafted. https://www.osha.gov/lawsregs/standardinterpretations/2 017-10-19 Construction Industry FAQs https://www.osha.gov/dsg/t opics/silicacrystalline/const ruction_info_silica.html
Top 10 Federal Silica Standards Cited Construction (1926.1153) 1) (d)(2)(i) - Exposure Assessment 2) (c)(1) - Table 1 3) (g)(1) - Written Plan 4) (f)(1) - Hazard Communication 5) (e)(1) - Respiratory Protection 6) (i)(2)(i) - Info & Training 7) (i)(2)(i)(a) - Health Hazard 8) (g)(4) - Competent Person 9) (h)(1)(i) - Medical Surveillance 10) (i)(2)(i)(b) - Specific Task
OSHA Website Safety and Health Topics Page https://www.osha.gov/dsg/topics/silicacrystalline/
Guidance Materials Small Entity Compliance Guide NIOSH Silica Safety and Health Topics https://www.cdc.gov/niosh/t opics/silica/ CPWR Silica Safe Website http://www.silica-safe.org/ Tool Manufacturers Instructional Videos Operator Manual www.osha.gov/publications/osha3902.pdf
Summary Identify tasks where anticipated exposures can exceed AL. Conduct employee exposure assessments or follow Table 1. Establish written exposure control plan and designate competent person. Implement feasible dust controls to reduce exposures. Require use of respiratory protection if exposures exceed PEL. Prohibit use of compressed air and dry sweeping for cleaning. Offer medical surveillance for employees required to wear respiratory protection >30 days/year. Train employees on hazards and control methods. Maintain records.
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