CHAPTER 39: SILICA AWARENESS 511
Purpose To reduce team member exposure to airborne crystalline silica to below the OSHA Permissible Exposure Limit (PEL) by means of substitution, engineering controls, work methods and administrative controls. Scope This program applies to all JT Thorpe and Son employees. When work is performed on a nonowned or operated site, the operator s program shall take precedence, however, this document covers JTT employees and contractors and shall be used on owned premises, or when an operator s program doesn t exist or is less stringent. Definitions Carcinogen: A substance that causes the development of cancerous growths in living tissue. One of the groups that rates cancer risk is the International Agency for Research on Cancer (IARC). The IARC lists materials as: Group 1 - known carcinogenic to humans Group 2A - probably carcinogenic to humans Group 2B - possibly carcinogenic to humans Crystalline Silica: The crystalline forms of silicon dioxide (SiO2). Quartz is the most common form. Cristobalite and Tridymite are two other crystalline forms that might be encountered. These crystalline forms are the dangerous ones. Permissible Exposure Limit (PEL): This is the OSHA allowable concentration limit in air that a team member can be exposed to for an eight-hour day. Pulmonary Function Test (PFT): Pulmonary function test. This test is designed to determine how well your lungs are working. Respirable: Particles small enough to be drawn deep into the lungs and that are below 10 microns in size (too small to be seen by the naked eye). Competent Person - A designated JTT employee who has the authority to take prompt corrective actions and has received training and certification equivalent to OSHA s 1926.1153 Respirable crystalline silica and competent in: Identifying respirable crystalline silica hazards in the workplace. Selecting appropriate control strategies for respirable crystalline silica exposure. The contents of the OSHA respirable crystalline silica regulations. Work practices for safe demolition and installation that can be developed into a written exposure control plan. Silicosis: A progressive disease of the lungs that reduces the ability of the lungs to extract oxygen from the air. It is caused by exposure to respirable crystalline silica dust particles. The damage cannot be reversed. 512
Key Responsibilities Managers/Supervisors Create a crystalline silica exposure mitigation plan for control of exposure on job site, with similar information in work order. Ensure owners or operators are notified of JTT s respirable crystalline silica plan. Ensure proper employee training is completed. Ensure that all requirements of this program are understood and followed by those working under his/her direction. Perform duties of the Competent Person for silica work, or designate someone (that is trained) to the position. Protect workers from respirable crystalline silica exposures below the permissible exposure limit of 50 µg/m3, averaged over an eight-hour day. Employees All employees are required to act in strict compliance with the requirements of this program and delay or discontinue work if there is ever an unresolved concern regarding exposure to respirable crystalline silica. Each employee that may be exposed to the hazards of crystalline silica shall be trained on the hazards and enrolled in the medical surveillance program prior to starting work. Employees who perform housekeeping activities during and after construction shall be covered by the crystalline silica construction standard and JTT policy. Procedure Health Effects Exposure to respirable crystalline silica can cause silicosis, lung cancer, other respiratory diseases, and kidney disease. General This safety policy and procedure covers all operations that have the potential of creating exposure for personnel (JT Thorpe and Son Inc., subcontractor, client, other craft, or general public) to dusts containing crystalline silica. Identifying Silica Hazards Crystalline silica is a natural constituent of the earth s crust and is a basic component of most refractory s, concrete, brick, granite, some blasting grit, and grouting materials. People may be exposed to crystalline silica hazards when around activities like: Abrasive blasting Jack hammering (demolition of refractory) Removal of refractory (muck out) Ramming of refractory Drilling of refractory Mixing of refractory, concrete, or grout Concrete drilling Sawing concrete, concrete blocks, or bricks Chipping or scarifying concrete and refractory Moving or dumping piles of refractory, concrete, rock, or sand 513
Housekeeping activities (shoveling, sweeping, vacuuming, etc.) Demolition involving any of these materials Using coatings containing crystalline silica Removing coatings containing crystalline silica Before any activity begins, project personnel must assess the work and identify possible exposures. Remember whenever available consult the SDS(s) for the materials with which you are dealing. Even materials containing small amounts of crystalline silica may be hazardous if they are used in ways that produce high dust concentrations. Establishing a Job Specific Silica Protection Plan Training Documented training will include: Information about the potential health effects and symptoms of exposure to respirable crystalline silica. Safety data sheets for silica, refractory, and applicable products containing silica. Purpose and set up of regulated areas marking the boundaries of work areas containing silica dust. Discussion of the importance of substitution, engineering controls, work practices, good housekeeping, and personal hygiene in reducing crystalline silica exposure. Use and care of appropriate PPE including respirators. Expected exposures, controls in place to minimize exposure, and how to set up, use, maintain, etc. the controls to be used. The contents of this safety policy and procedure. Hygiene. Availability of air monitoring and medical surveillance results. Substitution, Engineering Controls, and Work Practices In order to control the hazards of crystalline silica, you must first look at alternate methods of doing the work, engineering controls, and work practice controls to reduce the exposure to crystalline silica to below the OSHA Permissible Exposure Limit (PEL). The job specific plan will contain information on what methods, engineering and work controls were considered, why or why not they are feasible, and which controls the job is going to use. This requires us to use feasible engineering or work practice controls to reduce team members exposure to below the PEL. Some possible substitution or engineering controls: Substituting non-silica containing materials for use while abrasive blasting. Alternative methods (i.e. ordering/using material that is already mixed, in a bucket). Local exhaust (directed at the site where tear out is occurring and above where the mixer is located). General ventilation (following the NIOSH requirements for ventilation for the appropriate air exchange in a confined space). Vacuum methods with HEPA filters (vacuum shrouded tools like grinders or saws). Dust control appliances (HEPA filter or HEPA vacuum to control refuge dust). Containment (covered structures around mixing stations and clean-up areas). Use of water hoses, spray booms, etc. Use of tools with dust control systems (water on saws or drill bits etc.). Some possible work practice (administrative) controls: Working during hours other crews are not. Restricting access to the work areas. Good housekeeping practices (not allowing dust to build up, etc.). All HEPA filtering systems shall be cleaned per the manufactures requirement Specific standard operating procedures that minimizes dust produced by a task. 514
These are only some suggestions; there are other controls we can use. Some combination of these or other controls may allow us to reduce the exposure to below the PEL. The object is to keep as much dust as possible out of the air. Each situation may be unique, but communicating how issues with silica were controlled will allow JTT to practice this policy in an effective manner. Remember that you must use feasible controls even if they do not completely reduce the exposure to below the PEL. Initial Assessment and Exposure Monitoring Once all feasible engineering and administrative controls have been decided, you must determine what PPE is needed to supplement the controls. An initial assessment must be made to determine what the expected exposures will be. For respiratory protection this initial assessment will be based on following table of silica dust generating work activities that has been compiled from representative data. 515
Respirator Protection Factor Typical Silica Activity None N/A Housekeeping (wet method) Half face with HEPA filters 10 Housekeeping (dry method) Half face with HEPA filters 10 Saw cutting (wet method) Half face with HEPA filters 10 Drilling refractory (wet method) 50 Power tools with dust collection None N/A Other activities not creating visible dust (stacking brick) 50 Chipping refractory Jack hammering Half face with HEPA filters PAPR with HEPA filters 50 Mucking out 10 Mixing refractory (open air) 50 Applying refractory (creating particles and dust) 50 Power tools without dust collection 50 Mixing refractory (enclosed hooch) 50 Vacuum abrasive blasting 500 and 1000 Abrasive blasting Personal Protective Equipment PPE for work around silica containing dust includes: Disposable or reusable work clothing to keep from spreading the dust or bringing the dust home. Leather gloves. Safety glasses (spoggles or goggles may be appropriate). Respiratory protection (exposure has to be below the recommended PEL). Until the level of team member exposure to crystalline silica is known to be below the PEL or if the use of feasible engineering and work practice controls is not sufficient to reduce the exposure to below the PEL, respiratory protection is required in accordance with JT Thorpe and Son Inc. s respiratory protection program. Hygiene Good hygiene is as important as PPE in protecting team members from toxic materials. To ensure team members protect themselves and their families, the following practices are required: Do not eat, drink, or use tobacco products in work areas where silica-containing dust is present. Wash your hands and face before eating, drinking, or smoking. Use disposable or washable work clothing at the work site. Contaminated work clothing shall never be taken off site. 516
If work clothing is to be washed, make sure to handle it in such a manner as to not put the dust back into the air. Place it into plastic bags labeled Caution-clothing contaminated with silica dust. Provide hand-washing facilities at the work site. Park personal vehicles away from sources of silica dust. Regulated Areas In operations producing dust containing or suspected of containing crystalline silica, care must be taken to also protect people and places not involved with the work. This may mean blocking off the area (with tape or plastic fencing, etc.) and posting signs or in some cases using containment with ventilation and HEPA exhaust depending on location and type of work. People without the proper PPE are not allowed in the regulated area. The size of the area should be determined by the competent person based on visible emissions, wind direction, and work practice. Coordination of such activities and work scheduling to insure management of the regulated work area, should be coordinated with the client. Signs should be posted at all possible access points: Danger Crystalline Silica Inhalation Hazard No Smoking, Eating, or Drinking Authorized Personnel only Housekeeping Areas shall be kept as free from accumulated dust as possible. Use methods that do not reintroduce dust into the air (wet methods, HEPA vacuums, etc.) Medical Surveillance Program All JTT employees who for a combined total of 30 or more days per year are engaged in silica containing work or who are exposed at or above the permissible exposure limit for a combined 30 days or more per year shall be included in the JTT medical surveillance program. All team members with potential exposure to crystalline silica must be current with JTT s respirator medical surveillance. They must have had the pre-placement physical including the respirator questionnaire (with the silicosis portion) and a baseline PFT. The respirator and silicosis questionnaires must be completed annually. Medical exams will be offered including chest X-rays and lung function tests every three years for workers who are required by the standard to wear a respirator for 30 or more days per year. In the event that silica induced pulmonary disease is suspected, the team member must be removed from potential exposure to silica containing dusts until a final medical determination is made Waste Disposal By itself, dust containing crystalline silica is not regulated as a hazardous waste unless it is mixed with or contains something else that makes it a hazardous waste. Make sure that you do not create an additional airborne crystalline silica hazard when collecting, emptying, or disposing of the material. 517
Record Keeping In accordance with 29 CFR 1910.20, medical records shall be maintained for at least thirty years after a team member s termination of employment. All exposure monitoring (air sampling, etc.) results shall be kept for thirty years. The results of exposure monitoring shall be reported in writing to the team members it represents or posted in a location available to the team members. If the results are above the PEL, include the actions that will be taken to reduce the exposure. All exposure monitoring worksheets, results, and other pertinent information should be kept on site and a copy sent to the manager of health and environmental hazards. 518
J.T. THORPE & SON, INC. Silica Awareness Test NAME: SIGNATURE: 1. T F Silica is always visible. Circle the letter with the most correct answer: T if the statement is TRUE and F if the statement is FALSE. INCIDENT INVESTIGATION AND REPORTING 2. What are the correct methods to control silica exposure? a. Wet Method b. Wear a respirator c. Substitute a product with less silica d. Buying premixed products e. All of the above 3. T F Silicosis is reversible if you go to the doctor. 4. T F Wearing a respirator is the best way to protect yourself from silica 5. Which of the following products or process expose workers to silica a. Refractory b. Saw cutting concrete c. Sweeping d. Grout e. All of the above 6. T F Contaminated clothing, coveralls and Tyvek suits can be shook outside to remove silica dust. 7. T F Good housekeeping will prevent silica exposure. 8. Which of the following are not part of JT Thorpe s Silica Awareness Policy? a. PFT and being Fit Tested for Resp. Protection b. Best Practices c. Hope for the best d. Training of effected employees. Trained by: Date Trained EMPLOYEE SAFETY ORIENTATION PROGRAM TRAINING OUTLINE 519