Creating a Written Silica Control Plan

Health & Safety Webinars Creating a Written Silica Control Plan March 13, 2018 NON-FERROUS FOUNDERS SOCIETY

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Sample Respirable Silica Program Our company has established a Respirable Silica Control Program that includes all employees exposed to respirable crystalline silica at or above the OSHA Action Level. The program includes sampling of the air to determine levels of employee exposures, engineering and work practice controls we have implemented to reduce silica exposures, medical examinations to check on employees' health, respiratory protection and employee training. The purpose of this program is to prevent occupational disease, primarily silicosis, due to silica exposures in the workplace. The program applies to employees in the following departments in our company. The safety and health manager, is the program coordinator, and will review and update the program, as necessary. 3

Employee Responsibility Under this program, affected employees will be informed of the possible health effects of silica exposure; the control measures implemented to reduce exposures; the purpose and selection of respiratory protection and instructions on how to fit, use and care for this equipment; and the purpose of medical monitoring. Compliance with our company's safety and health requirements, including the Silica Control Program, is a condition of employment. Failure to comply with the requirements of this program will result in disciplinary action outlined in the company's safety and health program

Why Silica is Used at our Foundry Silica is introduced into the foundry environment because of its ability to withstand contact with molten metal and not burn or change its physical properties. Silica is used in making molds, cores, and as a component of the refractory used in the lining material of the melting furnaces and transport and pouring ladles. Our company has made engineering changes and implemented a control program in the areas of the operations where silica is used and exposure is possible, to reduce the employees exposure to airborne silica.

The foundry has dust/fume control systems, as well as general ventilation systems as an important part of our control program. These systems have been successful in reducing the exposure of the employees to silica to below the permissible exposure limit (PEL) of 50 ug/m3, when they are operating at design levels. However, since these systems can be affected by maintenance problems and employee work practices, there are operations where the facility continues to require that employees wear respiratory protection to provide assurance that there is protection from potential exposure to airborne silica. In addition, there continues to be a respiratory protection program as well as a Silica Program (as described in the remainder of this plan) for those persons who are exposed to respirable silica above the action level and those who may be exposed above the PEL due to break downs, nonroutine tasks, or jobs where there is currently no feasible way to reduce the exposure to respirable silica to below the PEL.

The engineering controls for the reduction of airborne respirable silica are described in these plans. There are direct mechanical exhaust systems for all foundry dust/fume sources that can be controlled by this method. There are permitted bag filter dust collector systems that provide the exhaust air for the specific operations throughout the foundry.

Definitions What is Respirable Silica and What are OSHA Exposure Limits Employee Exposure means the exposure to airborne respirable crystalline silica that would occur if the employee were not using a respirator. 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. Permissible Exposure Limit (PEL) means a concentration of airborne respirable crystalline silica of 50 µg/m 3 or 0.05 mg/m 3, calculated as an 8-hour Time Weighted Average (TWA). Action level means a concentration of airborne respirable crystalline silica of 25 μg/m 3, calculated as an 8-hour TWA

Air Monitoring Monitoring or testing of the air is used to evaluate how much respirable silica may be in the employee s personal breathing zone. This air sampling is conducted on representative employees in each department/job category on each shift to evaluate 8-hour time-weighted average exposures to respirable crystalline silica. Testing of the area by other means that will also show employee exposures can also be used to determine levels of respirable silica. The results of these tests are then used to determine the employees who are included in the Silica Control Program.

Employees who are exposed to respirable silica for thirty days or more in a year at or above the Action Level are included in the Silica Control Program. The Action Level is a concentration of airborne respirable crystalline silica of 25 µg/m 3 or 0.025 mg/m 3, calculated as an 8-hour Time Weighted Average (TWA). Employees at or above the Permissible Exposure Limit (PEL) are included in the Silica Control Program. The PEL is a concentration of airborne respirable crystalline silica of 50 µg/m 3 or 0.05 mg/m 3, calculated as an 8-hour TWA.

Air monitoring test results Will identify which equipment, employee locations, and areas that have effective engineering control measures. Will aid in determination and selection of appropriate respirators for employees to provide protection from exposure in areas where engineering control is not effective or feasible.

How Often Are Employee Exposures Monitored? If the first or any later testing indicates that employee exposures are at or above the OSHA Action Level, but below the OSHA PEL, monitoring will be repeated within six months of the most recent monitoring. At or are above the OSHA PEL, monitoring will be repeated within three months of the most recent monitoring. Air sampling or monitoring will continue at the required frequency until at least two consecutive measurements, taken at least seven days apart, are below the Action Level.

How Often Are Employee Exposures Monitored? Employees will be informed of air sampling results within 15 working days after completion of the laboratory analysis and receipt of the results. Affected employees will be notified of the air sampling results either individually in writing, or by the posting of the results in an appropriate location that is accessible to all affected employees.

Engineering and Work Practice Controls If silica exposures are at or above the OSHA PEL, feasible engineering and/or work practice controls will be implemented to reduce employee exposures to levels below the Permissible Exposure Limit or as low as is feasible. Our goal is to control employee exposures to below the permissible exposure limit set by OSHA or to eliminate the sources of exposure.

Engineering and Work Practice Controls However, there may be areas or operations where this is not feasible. In these areas, we will reduce levels to as low as feasible and establish personal protective equipment programs including mandatory use of respirators and monitor employee health as a part of our medical surveillance program. The methods we have established to control exposure to respirable silica are described for each affected occupation on the Silica Exposure Control Plan that has been developed for that job or occupation

Regulated Areas Access or entry into areas where employee exposures to airborne concentrations of respirable crystalline silica are, or can reasonably be expected to be, at or above the OSHA PEL will be designated as Regulated Areas. Access to Regulated Areas is limited to: 1. authorized persons required by work duties to be in the regulated area, 2. designated representatives of employees observing monitoring procedures, 3. any person authorized by the Occupational Safety and Health Act. Regulated areas are marked with warning signs. The warning signs are posted at or near entrances to work areas, and in work areas where a potential respirable crystalline silica exposure exists. These signs will read:

DANGER RESPIRABLE CRYSTALLINE SILICA MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS WEAR RESPIRATORY PROTECTION IN THIS AREA AUTHORIZED PERSONNEL ONLY

Silica Exposure Control Plans A written Silica Exposure Control Plan for occupations/jobs has been developed for affected jobs or occupations. These plans contains the following information: 1. A description of the tasks in the workplace that involve exposure to respirable crystalline silica; 2. A description of the a. engineering controls, b.work practices and respiratory protection used to limit employee exposure to respirable crystalline silica for each task 3. A description of the housekeeping measures used to limit employee exposure to respirable crystalline silica. The safety director will review and evaluate the effectiveness of the written exposure control plan at least annually and update them as necessary. These Silica Exposure Control Plans are available for examination and copying, upon request, to each employee and their designated representatives.

. ABC Foundry 123 Main Street Any town, USA 34567 Silica Exposure Control Plan. Source/Material: Task: Pedestal Grinder: Using abrasive wheel mounted on pedestal to remove unwanted silica Silica used as molding material sand adhering to casting surface Equipment and Control(s): Hood mounted on pedestal grinder to provide exhaust to dust control system. General ventilation Respiratory Protection Task/Control Description: Grinder operators remove crystalline silica (sand) adhering to casting surface with brasive wheel permanently mounted. Grinders are in an area separated from the rest of shop (wall with opening sufficient to allow movement of castings in and out to the department. Room (Cleaning and Finishing Department) is designated as a Regulated area. The room is equipped with local exhaust ventilation. Operator wears a Half-mask APR respirator (N-95), face shield, safety glasses, gloves, and hearing protection. Compressed air is not to be used to clean floor or equipment. Regulated Area: The Grinder area of the Cleaning and Finishing Department (as marked) is identified as a Regulated Area. Warning signs are posted at all entrances to the room. Unauthorized employees are restricted from entering the area. Any persons authorized to enter the restricted area while in operation, or during cleaning activities, will be provided with appropriate respiratory protection. Individuals not authorized for respirator use will not be allowed to enter the restricted area while in operation, or during cleaning activities that can generate airborne respirable crystalline silica Training: Employees are trained in silica hazard, proper work procedures to control dust, proper use of safety equipment, and respirator use. Training is provided through combination of tool box safety talks (conducted by supervisory personnel) and formal classroom training (conducted by safety and health staff.) Housekeeping: Dry sweeping will be prohibited where feasible. Wet sweeping, HEPA filtered vacuuming or other methods will be used, unless not feasible. Compressed air will not be used to clean equipment or worker clothing. HEPA vacuum will be provided to clean clothing. Medical Surveillance: All employees exposed to respirable crystalline silica at or above the OSHA Action Level of 30 µg/m 3 for 30 or more days per year will be included in the Medical Surveillance Program which includes initial examination (medical history, physical examination with emphasis on respiratory system, chest x-ray, pulmonary function test, testing for latent tuberculosis infection, and any other tests deemed necessary by the physician). Periodic examinations will also be provided at least every three years. Other Considerations: Hearing protection will be provided for employees in the Cleaning and Finishing Deparment. Eye Protection must be worn (safety glasses and face shields) while grinding. For Person Responsible for preparing/updating the Plan: John/JaneSmith, Safety/EHS Manager

Housekeeping The following housekeeping control measures have been established to reduce airborne dust exposures. 1. Cleaning equipment, work surfaces and floors with compressed air and dry sweeping silica are prohibited unless a.the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air or b.there are no other feasible methods available. 2. HEPA- filtered vacuuming and washing down with water are used where feasible in place of dust-producing methods. The use of WATER must be limited to only those areas where the water will not come into contact with molten metal or present a hazard. 3. Maintaining surfaces free of accumulation of silica dust and rapid spill cleanup to help reduce the potential for silica dust to become airborne.

Employee Training As part of our Hazard Communication Program, employees will be informed of the presence of silica in the workplace and the specific operations that could result in exposure to respirable crystalline silica above the OSHA Personnel Exposure Limit The training of employees will include: The health hazards associated with exposure to respirable crystalline silica 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 to respirable crystalline silica, including engineering controls, work practices, and respirators to be used The purpose and a description of the medical surveillance program required

Medical Surveillance Program All employees exposed to crystalline silica above the OSHA Action Level will be included in the medical surveillance program. Our company has contracted with <Name> to perform baseline and periodic medical examinations, evaluate chest x-rays and advise of any action needed as a result of the evaluation. The medical examination is performed by a licensed or certified physician. The chest x-rays are classified according to the 1970 ILO International Classifications of radiographs of Pneumoconiosis by a NIOSH certified class "B" reader. What is included in the Medical Surveillance Program Our medical surveillance program is available at no cost to the employees included in our program. The tests and exam will be scheduled at a reasonable time and place for each employee who will be occupationally exposed to respirable crystalline silica at or above the action level for 30 days or more days per year.

Initial Exams An initial examination is made available to develop a baseline, within 30 days after initial assignment, unless the employee has received a medical examination that meets the requirements of this section within the last three years. The examination will consist of: (i) 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

Initial Exams (ii) A physical examination with special emphasis on the respiratory system (iii) A chest X-ray (a single posteroanterior radiographic projection or radiograph of the chest at full inspiration recorded on either film (no less than 14 x 17 inches and no more than 16 x 17 inches) or digital radiography systems) interpreted and classified according to the International Labour Office (ILO) International Classification of Radiographs of Pneumoconioses by a NIOSH-certified B Reader

Initial Exams (iv) A pulmonary function test to include forced vital capacity (FVC) and forced expiratory volume in one second (FEV1) and FEV1/FVC ratio, administered by a spirometry technician with a current certificate from a NIOSH-approved spirometry course (v) Testing for latent tuberculosis infection (vi) Any other tests deemed appropriate by the Physician

Periodic exams At least every three years, or more frequently if recommended by the physician, medical exams that include the following will be made available to employees exposed to respirable silica at or above the action level for 30 days or more in the year Tests are the same as for initial exams except there is no requirement, for a test for latent tuberculosis

What will be given to the Physician to evaluate a Worker s Silica Exposure We are required to give the following information to the physician responsible for the medical surveillance exams: 1) a copy of the OSHA Silica standard 2) A description of the employee s former, current, and anticipated duties as they relate to the employee s occupational exposure to respirable crystalline silica 3) The employee s former, current, and anticipated levels of occupational exposure to respirable crystalline silica 4) A description of any personal protective equipment used or to be used by the employee, including when and for how long the employee has used or will use that equipment 5) Information from records of employment-related medical examinations previously provided to the employee and currently within the control of the employer.

What will be the Physician Report to the Employee Include The Physician will give a written medical report to the employee and explain the results of the exam within thirty days of the examination.. The written report will contain: 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

What will be the Physician Report to the Employee Include The Physician will give a written medical report to the employee and explain the results of the exam within thirty days of the examination.. The written report will contain: Any recommended limitations on the employee s exposure to respirable crystalline silica A statement that the employee should be examined by a specialist (pursuant to paragraph (i)(7) of this section) if the chest X-ray provided in accordance with this section is classified as 1/0 or higher by the B Reader, or if referral to a specialist is otherwise deemed appropriate by the Physician

WRITTEN MEDICAL REPORT FOR EMPLOYEE EMPLOYEE NAME: DATE OF EXAMINATION: TYPE OF EXAMINATION: [ ] Initial examination [ ] Periodic examination [ ] Specialist examination [ ] Other: RESULTS OF MEDICAL EXAMINATION: Physical Examination [ ] Normal [ ] Abnormal (see below) [ ] Not performed Chest X-Ray [ ] Normal [ ] Abnormal (see below) [ ] Not performed Breathing Test (Spirometry) [ ] Normal [ ] Abnormal (see below) [ ] Not Performed Test for Tuberculosis [ ] Normal [ ] Abnormal (see below) [ ] Not performed Other: [ ] Normal [ ] Abnormal (see below) [ ] Not performed Results reported as abnormal: [ ] Your health may be at increased risk from exposure to respirable crystalline silica due to the following:

RECOMMENDATIONS: [ ] No limitations on respirator use [ ] Recommended limitations on use of respirator: [ ] Recommended limitations on exposure to respirable silica: Dates for recommended limitations, if applicable: to [ ] I recommend that you be examined by a Board Certified Specialist in Pulmonary Disease or Occupational Medicine [ ] Other recommendations* *These findings may not be related to respirable crystalline

RECOMMENDATIONS: Your next periodic examination for silica exposure should be in: [ ] 3 years [ ] Other: Examining Provider: Date: Provider Name: Office Address:

What will be the Physician Report to the Employer Include The employer will get from the Physician a written medical opinion within 30 days of the medical examination that contains 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.

WRITTEN MEDICAL OPINION FOR EMPLOYER EMPLOYER: EMPLOYEE NAME: DATE OF EXAMINATION: TYPE OF EXAMINATION: [ ] Initial examination [ ] Periodic examination [ ] Specialist examination [ ] Other: USE OF RESPIRATOR: [ ] No limitations on respirator use [ ] Recommended limitations on use of respirator: Dates for recommended limitations, if applicable: to The employee has provided written authorization for disclosure of the following to the employer (if applicable): [ ] This employee should be examined by an American Board Certified Specialist in Pulmonary Disease or Occupational Medicine [ ] Recommended limitations on exposure to respirable crystalline silica: Dates for exposure limitations noted above: to

NEXT PERIODIC EVALUATION: [ ] 3 years [ ] Other: Examining Provider: Date: Provider Name: Provider s specialty: Office Address: Office Phone: [ ] I attest that the results have been explained to the employee. The following is required to be checked by the Physician or other Licensed Health Care Professional (PLHCP): [ ] I attest that this medical examination has met the requirements of the medical surveillance section of the OSHA Respirable Crystalline Silica standard ( 1910.1053(h) or 1926.1153(h)).

The Employee can release the exam results to the Employer The Employee can release the exam results to the Employer if the employee provides written authorization. The written opinion must 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 (pursuant to paragraph (i)(7) of this section) if the chest X-ray provided in accordance with this section is classified as 1/0 or higher by the B Reader, or if referral to a specialist is otherwise deemed appropriate by the Physician

AUTHORIZATION FOR CRYSTALLINE SILICA OPINION TO EMPLOYER This medical examination for exposure to crystalline silica could reveal a medical condition that results in recommendations for (1) limitations on respirator use, (2) limitations on exposure to crystalline silica, or (3) examination by a specialist in pulmonary disease or occupational medicine. Recommended limitations on respirator use will be included in the written opinion to the employer. If you want your employer to know about limitations on crystalline silica exposure or recommendations for a specialist examination, you will need to give authorization for the written opinion to the employer to include one or both of those recommendations. I hereby authorize the opinion to the employer to contain the following information, if relevant (please check all that apply): a. Recommendations for limitations on crystalline silica exposure b. Recommendation for a specialist examination OR I do not authorize the opinion to the employer to contain anything other than recommended limitations on respirator use. Please read and initial: I understand that if I do not authorize my employer to receive the recommendation for specialist examination, the employer will not be responsible for arranging and covering costs of a specialist examination. Name (printed) Signature Date

Respiratory Protection All employees exposed to crystalline silica above the OSHA Permissible Exposure Limit will be included in the respiratory protection program. Appropriate respirators are selected based on the employee exposure levels. Employees will be fit tested to ensure an adequate fit. Employees are then trained in the use and care of respiratory protection as part of the training program.

Recordkeeping Records are maintained, and made available to employees upon request, for all medical examinations, air sampling surveys and training sessions. Air sampling survey information includes sampling and analytical methods; type of personal protective equipment, if any, in use at the time of sampling; and the monitoring results. Records will be maintained for at least 30 years following termination of a worker's employment. Each employee is able to obtain information on their exposure and medical examinations.

Additional Information All employees or their designated representatives can obtain further information on the written program, the OSHA Respirable Crystalline Silica standard, and/or records of air monitoring results or medical exams at the Safety and Health Office.

Questions and Answers

Non-Ferrous Founders Society Safety & Health Training Program For further information about this or other training programs: Non-Ferrous Founders Society 1480 Renaissance Drive, Suite 310 Park Ridge, IL 60068 847/299-0950 http://www.nffs.org