OSHA CRYSTALLINE SILICA STANDARD CRYSTALLINE SILICA STANDARD 29 CFR 1926.1153 1 rpbsafety.com
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HIGH LEVEL OSHA SILICA STANDARD RATIONALE OSHA estimates that the rule will save over 600 lives and prevent more than 900 new cases of silicosis each year, once its effects are fully realized. The Final Rule is projected to provide net benefits of about $7.7 billion, annually. About 2.3 million workers are exposed to respirable crystalline silica in their workplaces, including 2 million construction workers who drill, cut, crush, or grind silica-containing materials such as concrete and stone, and 300,000 workers in general industry operations such as brick manufacturing, foundries, and hydraulic fracturing, also known as fracking. Responsible employers have been protecting workers from harmful exposure to respirable crystalline silica for years, using widely-available equipment that controls dust with water or a vacuum system. 3
HIGH LEVEL OSHA SILICA STANDARD RATIONALE KEY PROVISIONS Reduces the permissible exposure limit (PEL) for respirable crystalline silica to 50 micrograms per cubic meter of air, averaged over an 8-hour shift. Requires employers to: use engineering controls (such as water or ventilation) to limit worker exposure to the PEL; provide respirators when engineering controls cannot adequately limit exposure; limit worker access to high exposure areas; develop a written exposure control plan, offer medical exams to highly exposed workers, and train workers on silica risks and how to limit exposures. 4
HIGH LEVEL OSHA SILICA STANDARD RATIONALE KEY PROVISIONS Provides medical exams to monitor highly exposed workers and gives them information about their lung health. Provides flexibility to help employers - especially small businesses - protect workers from silica exposure. 5
EFFECTS OF RESPIRABLE SILICA Silica dust is hazardous when very small (respirable) particles are inhaled. These respirable dust particles can penetrate deep into the lungs and cause disabling and sometimes fatal lung diseases, including silicosis and lung cancer, as well as kidney disease. Occupational exposure to respirable crystalline silica occurs when cutting, sawing, drilling, and crushing of concrete, brick, ceramic tiles, rock, and stone products. Occupational exposure also occurs in operations that process or use large quantities of sand, such as foundries and the glass, pottery and concrete products industries. OSHA estimates that more than 2.3 million workers in the United States are potentially exposed to dust containing crystalline silica with nearly 90% of those workers employed in the construction industry. 6
EFFECTS OF RESPIRABLE SILICA Industries and operations in which exposure to crystalline silica can occur include, but are not limited to: Construction Glass products Pottery products Structural clay products Concrete products Foundries Dental laboratories Paintings and coatings Jewelry production Refractory products Ready-mix concrete Cut stone and stone products Refractory installation and repair Railroad track maintenance Hydraulic fracturing for gas and oil Abrasive blasting in: Maritime work Construction General industry Lung with Silicosis 7
OSHA SILICA RULE OVERVIEW Permissible Exposure Level: 50 µg/cu.m of air over 8-hr TWA Action Level: 25 µg/cu.m of air over 8-hr TWA Protective Clothing: No requirements Housekeeping: Prohibits use of compressed air, dry sweeping, and dry brushing unless other methods are not feasible - Vacuums Ban on Employee Rotation: Original ban was removed Medical Surveillance: Must be available to employees exposed to silica at or above the PEL for 30 or more days Methods of Compliance: Engineering controls = priority to maintain exposure at or below PEL Supplement with respiratory protection when controls aren t feasible Utilize respiratory protection while engineering controls are being implemented Signage: Required for regulated areas Implementation Date: Construction - September 23, 2017 (Utilize control methods laid out in Table 1 of Construction standard) General Industry & Maritime - June 23, 2018 8
OSHA CONSTRUCTION SILICA STANDARD - TABLE 1 Table 1 matches common construction tasks with dust control methods, so employers know exactly what they need to do to limit worker exposures to silica. Effective control methods included: Excerpt from Table 1: Specified exposure control methods when working with materials containing Crystaline Silica. Equipment/task Engineering and Work Practice Control Methods Required respiratory protection and minimum assigned protection factor (APF) = 4 hrs/shift > 4 hrs/shift Using water to suppress dust Ventilation to capture dust Use of respirators Handheld power saws (any blade diameter) Use saw equipped with integrated water delivery system that continuously feedswater to the blade. Operate and maintain tool in accordance with manufacturer s instructions to minimize dust emissions. When used outdoors. None APF 10 When used indoors or in an enclosed area APF 10 APF 10 9
NEW OSHA FINE SCHEDULE VIOLATION TYPE CURRENT MAXIMUM PENALY 2016 MAXIMUM PENALTY* Other than serious violations $7,000 $12,600 Serious violation $7,000 $12,600 Willful violation $70,000 $126,000 Repeat violation $70,000 $126,000 * assumes 80% catch-up adjustment. First time in 25 years, OSHA has increased monetary penalties for violations Bill allows OSHA to continue to raise fines annually to keep pace with inflation Goal of change is to keep fines up-to-date as a relevant penalty Businesses can expect to see these annual increases by no later than January 15 of each year 10
SILICA STANDARD INITIAL TARGETED FINES - CONSTRUCTION If OSHA sees a white cloud they are going to target four standards to cite as a starting bundle package (additional citations may occur): 1926.1153(c) Specified exposure control methods - $12,500 1926.1153(g) Written exposure control plan - $12,500 1926.1153(h) Medical surveillance - $12,500 1926.1153(i)(2) Employee information and training - $12,500 Total - $50,000 11
CHALLENGE OF NEW PEL How much is 50 μg/m3? One gram of respirable silica sand (equivalent to an artificial sweetener packet) would generate an exposure level above the new PEL in a space the size of a football field, 13 feet high. 12
OSHA STANDARD: (F) METHODS OF COMPLIANCE Mandatory hierarchy of controls Must use engineering and work practice controls Unless employer can demonstrate controls are not feasible When feasible controls are not sufficient: Use them anyway to reduce exposures ELIMINATION SUBSTITUTION ENGINEERING CONTROLS Physically remove the hazard. Replace the hazard. Isolate people from the hazard. Supplement with respirators Respirators cannot be used as primary control* Employee rotation IS allowed ADMINISTRATIVE CONTROLS PPE Change the way people work. Protect the worker with Personal Protective Equuipment. *NOTE: Respirators are required during implementation of controls. 13
OSHA COST/BENEFIT ANALYSIS OSHA had determined that the BENEFIT:EXPENSE ratio is roughly 8:1 Table 1.4: Annualized Benefits, Costs and Net Benefits of OSHA s Final Silica Rule Discount Rate 3% Anualized Costs Engineering Controls (Includes Abrasive Blasting) $661,457,000 Respirators $32,884,000 Exposure Assessment $96,241,000 Medical Surveillance $96,354,000 Familiarization and Training $95,936,000 Regulated Area $2,637,000 Written Exposure Control Plan $44,273,000 Total Annualized Costs (point estimate) $1,029,782,000 Annual Benefits: Number of Cases Prevented* Fatal Lung Cancers (midpoint estimate) 124 Fatal Silicosis & Other Non-malignant Respiratory Diseases 325 Fatal Renal Disease 193 Silica-related Mortality 642 $6,398,160,000 Silicosis Morbity 918 $2,288,753,000 Monetized Annual Benefits (midpoint estimate)* $8,686,913,000 Net Benefits $7,657,131,000 * Results are estimates based on assumptions outlined in Section VII.G, Benefits and Net Benefits. Source: U.S. Department of Labor, Occupational Safety and Health Admiistration, Directorate of Standards and Guidance. 14
TROUBLE SPOT IDENTIFICATION (INDOOR) SPOT THE CLUES! Visual Indicators: Non-Visual Indicators: Employee improvised solutions: duct tape covering holes, holes in duct tape (indicate someone not communicating issue), etc Visual horizontal surfaces (dust collection points) Sand transfer points Flash photos in dark areas - light reflects off respirable silica dusk in the form of orbs Glue traps - set overnight to get a sense of issue Incense candle - gives you a sense of airflow with smoke and smell Leaking sand Ventilation obstructions Burned-in sand creates silica dust during grinding 15
HOW CAN RPB HELP? RPB has several solutions that can help you with this standard. Contact us today to discuss your needs, 1-866-494-4599 or visit our website rpbsafety.com 16
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WHAT RESPIRATOR TO SELECT The benefits of a Powered Air loose fitting vs Negative Pressure respirators. A negative pressure device could be a disposable respirator, a half mask respirator or a full-face mask. A Powered Air loose fitting system will offer higher protection than a negative pressure device. The main difference being that a powered system utilizes a motor, battery and fan which do the work for the wearer. A negative pressure device unfortunately normally requires the wearer to utilize other forms of face protection such as eye protection, head protection and, face protection and hearing protection. The challenge here is gaining compatibility. Eye protection and face protection normally mist up when using such devices, similarly they can also break the seal of the mask rendering it useless. A negative pressure device is dependent on the wearer being clean shaven for it to protect them, A Powered Air System can offer complete head/eye/hearing and respiratory protection with total compatibility. Being loose fitting means operators can have facial hair and NO fit testing is required. Ensure you select a respirator that suits your workforce. 18
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