Silica Health Standard Subpart Z 29 CFR 1926.1153
Topics Scope and Definitions Specified & Alternative Exposure Controls Respiratory Protection Housekeeping Written Exposure Control Plan Medical Requirements Communication of Hazard Recordkeeping
Crystalline Silica
Health Effects Silicosis Chronic Accelerated Acute COPD (Chronic Bronchitis, Emphysema) Tuberculosis Lung Cancer IARC, 1997 NTP, 2000 Renal Disease
Scope & Application
Scope & Definitions Scope Any Construction Task > Action Level Definitions Action Level = 25 µg/m 3 Objective Data Competent Person
Exposure Limit 29 CFR 1926.55 (Mineral Dust Table) 250 mppcf % Silica + 5
New Exposure Limits At 100% SiO 2, Current PEL is 238 µg/m 3 Action Level (AL) = 25 µg/m 3 Permissible Exposure Limit (PEL) = 50 µg/m 3 New PEL is a Reduction of ~ 80%
NIOSH (REL) 3/4 Teaspoon of Silica In The Volume Of A Football Field (64,000 yds 3 ) is 57 µg/m 3 REL = 50 µg/m 3
Exposing Activities Cutting Grinding Sawing Drilling Crushing Abrasive Blasting Road Building Drywall Sanding
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Exposure Controls
Hierarchy of Controls Engineering Administrative/Work Practices PPE
Engineering Controls
Engineering Controls Substitution Ventilation Water
Steel Grit Substitution Abrasive Blasting Slag - Black Beauty Glass Beads Walnut Shells Dry Ice
Ventilation
EZ-Drill
Paving
Water
Administrative Controls
Administrative Controls Employee Rotation Time Limit for Exposure Body Positioning Medical Surveillance Hygiene Housekeeping
Personal Protective Equipment
PPE Respirators Eye Protection Safety Glasses Face Shield Gloves
Respirators
Respiratory Protection Must Comply With 29 CFR 1910.134 Table 1 Specifies Respirators by Assigned Protection Factors (APFs) Or, Alternative Exposure Control s Air Monitoring Determines Respirator
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LHSFNA http://www.lhsfna.org/index.cfm/controlling-silica-exposure/
Assigned Protection Factors = 10 = 25 = 10 = 50 = 1,000 OSHA = 50 NIOSH
Selection Exposure = APF Needed PEL
Eye Protection
Glasses & Goggles
Face Shields
Housekeeping
Housekeeping No Dry Sweeping No Dry Brushing Unless These Are Not Feasible Wet Sweeping HEPA-Filtered Vacuuming Other Methods
Housekeeping No Compressed Air To Clean Clothing To Clean Surfaces Unless Compressed Air is Used in Conjunction With a Ventilation System That Effectively Captures the Dust Cloud Created by the Compressed Air Or, No Alternative Method is Feasible
http://www.clothescleaningsystems.com/
Exposure Control Plan
Exposure Control Two Options Table 1, That Specifies: Engineering Control Work Practices Respirators by (APFs) Alternative Exposure Control Air Monitoring Determines Respirator With Engineering and Work Practices Used Two Options: Performance & Scheduled
Exposure Assessment Performance Option Assess the 8-Hour TWA Exposure for Each Employee on the Basis of Any Combination of Air Monitoring Data or Objective Data Scheduled Monitoring Option 8-Hour Exposure Assessment Breathing Zone Representative #, Each Task, Each Area & Each Shift Highest Exposure ( Worst Case )
Initial Exposure Assessment < AL, No Further Monitoring > AL but < PEL, Repeat in 6 Months > PEL, Repeat Every 3 Months
Exposure Reassessment Changes Reasonably Expected to Result in New or Additional Exposures > AL Production Process Control Equipment Personnel Work Practices Any Reason to Believe That New or Additional Exposures > AL Have Occurred
Air Sampling Method of Analysis Compliance with Appendix A Employee Notification Within 5 Days After Exposure Assessment In Writing or Post in Area >PEL, Employer Describes Corrective Actions Observation of Monitoring Methods of Compliance Engineering & Work Practice Controls Abrasive Blasting (29 CFR 1926.57)
Written Exposure Control Plan
Written Exposure Control Plan Shall Include: Naming a Silica Competent Person Frequent & Regular Inspections of Job Sites, Materials, & Equipment Implement the Written Exposure Control Plan Description of Exposed Tasks
Written Exposure Control Plan Shall Include: Description of Engineering Controls, Work Practices, & Respiratory Protection for Each Task Description of Housekeeping Measures Description of Procedures Used to Restrict Access to Work Areas, When Necessary, to Minimize the Number of Employees Exposed & Their Level of Exposure, Including Exposures Generated by Other Employers or Sole Proprietors
Written Exposure Control Plan Employer Shall: Review & Evaluate Effectiveness at Least Annually & Update as Necessary Make Plan Readily Available for Examination & Copying
Medical Surveillance
Medical Surveillance Use Respirator for 30 or More Days per Year Initial Within 30 Days Periodic Every 3 Years Unless, Within 3 Years from Previous Employer
Contents Medical & Work History Physical Exam Chest X-Ray (B Reader) PFT Tb Evaluation Any Other Tests PLHCP Requests
Tuberculosis Testing
Medical Surveillance Provide to PLHCP Duties Exposure Levels PPE Previous Medical
Medical Surveillance Written Medical Report (Employee) Written Medical Opinion (Employer)
Communication of Hazard
Communication of Hazard HAZCOM Each Employee Can Demonstrate Knowledge and Understanding Health Hazards Specific Tasks Engineering Controls, Work Practices, and Respirators to be Used
Communication of Hazard Each Employee Can Demonstrate Knowledge and Understanding Contents of This Section Identity of the Competent Person Purpose and a Description of the Medical Surveillance Program Must Make a Copy of This Section Readily Available Without Cost to Each Employee Covered By This Section
Recordkeeping
Recordkeeping 29 CFR 1910.1020 Exposure Data & Objective Data Maintained for 30 Years Medical & Respirator Evaluations Maintained Duration Plus 30 Years
Recordkeeping 29 CFR 1904.4
Dates
Final Date March 24, 2016 Effective June 23, 2016 Dates Implementation (Construction) June 23, 2017 Methods of Sample Analysis June 23, 2018
Lawsuits Industry National Stone, Sand & Gravel Association (NSSGA) NSSGA Partnered With Its Georgia Affiliate Filing in the 11 th Circuit in Georgia American Foundry Society and the National Association of Manufacturers Filing in the 5 th Circuit Other Industry Groups Had Filed Challenges in the 8 th & 10 th Circuits Labor UAW, USWA, AFL-CIO Filing in the 3 rd Circuit North American Building Trades Unions Filing in D.C.
Resources OSHA https://www.osha.gov/silica/ Construction Safety Council http://www.buildsafe.org/ (708) 449-8600 Politico Article http://www.politico.com/agenda/story/2016/03/the-regulation-that-tookfour-decades-to-finalize-000078 John Dimos, MS, CIH John@JohnDimosCIH.com (708) 217-8658
http://www.cpwr.com/ http://www.elcosh.org/document/1816/1120/d000658/guide1.html
CPWR http://plan.silica-safe.org/
CSC ECP Class November 9, 2016 December 6, 2016
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