Silica Training

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1. Slide 1

   RESPIRABLE CRYSTALLINE

   • SILICA
   • A Review of OSHA’s New Standard
   • (29. CFR. 1926.1153)
2. Slide 2

   Acknowledgement

   • UNITED STATES
   • DEPARTMENT OF LABOR
   • Occupational Health and Safety Administration (OSHA)
   • Susan Harwood Training Grant
   • SH-29666-SH6
   • This material was produced under a grant (SH-29666-SH6) from the Occupational Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does it mention of any trade names, commercial products, or organizations implying endorsement by the U.S. Government.
3. Slide 3

   Disclaimer

   • The materials presented herein are for information and awareness purposes. In no instances and under no conditions should they be used as a reference for compliance with the OSHA Respirable Crystalline Silica
   • Standard ( 29 CFR 1926.1153). The link to obtain a copy of the standard is provided below.
   • OSHA RESPIRABLE CRYSTALLINE SILICA STANDARD (29 CFR 1926.1153)
4. Slide 4

   Overview

   • Introduction
   • Worker Rights under OSH Act
   • Respirable Crystalline Silica and Silica Exposures
   • Silica Exposure Associated Health Risks
   • New OSHA Standard on Respirable Crystalline Silica
   • Permissible Exposure Limit and Action Level for Construction
   • Scope and Definitions
   • Compliance Dates
   • Silica Exposure Control Methods for Construction
   • Specified Exposure Control Methods
   • Engineering Controls
   • Workplace Controls
   • Table 1 Details
5. Slide 5

   Overview – cont.

   • Mandatory Requirements for Silica Exposure Control
   • Respiratory Protection
   • Housekeeping
   • Written Exposure Control Plan and Competent Person
   • Medical Surveillance
   • Communication of Silica Hazards (HazCom)
   • Recordkeeping
   • Alternative Exposure Control Methods
   • Exposure Assessment and Reassessment
   • Performance and Scheduled Monitoring Options
   • Methods of Sample Analysis
   • Employee Notification
   • Methods of Compliance – Hierarchy of Controls
   • Ventilation (29 CFR 1926.57)
   • Compliance Summary
6. Slide 6

   Purpose of This Training

   • OSHA has issued a new standard (CFR 1926.1153) to curb respirable crystalline silica related diseases in the US workers by limiting their exposure to respirable crystalline silica
   • The training provided here aims at
   • Increasing workers’ awareness of the serious health hazards of silica dust
   • Providing the knowledge necessary to perform work safely when there is silica exposure, and ways to limit silica exposure to levels below the Permissible Exposure Limit (PEL)
7. Slide 7

   The Training Process – Step by Step

   • SIGN-UP
   • PRETEST
   • to measure trainee's existing knowledge
   • SILICA TRAINING MODULE
   • COVERAGE
   • POSTTEST
   • to measure the knowledge gain
   • OPINION SURVEY
   • to give feedback for improvement
8. Slide 8

   SIGN-UP

   • PLEASE FILL OUT THE SIGN-UP SHEET
9. Slide 9

   PRETEST

   • PLEASE START THE PRETEST
   • ( maximum 15 MIN)
10. Slide 10

    Worker Rights under OSH Act

    • Workers are entitled to safe and healthful working conditions. The OSH ACT provides workers with the right to:
    • Ask OSHA to inspect their workplace
    • Review employers’ records of work-related injuries and illnesses
    • Get copies of their medical records
    • Receive information and training about hazards and their
    • prevention, using applicable OSHA standards.
11. Slide 11

    OSH Act – cont.

    • Worker Rights under
    • Workers may file a complaint with OSHA.
    • Employers may not retaliate by taking unfavorable personnel action against them for whistleblowing.
    • For more information refer to the hyperlink below Whistleblow ers’ Rights
    • Whistleblower laws require that complaints be filed with OSHA within certain time limits following the alleged retaliation.
12. Slide 12

    Right to Know

    • Federal Hazard Communication Standard, Title 29, Part 1910.1200 of the Code of Federal Regulations (29 CFR 1910.1200) mandates that “Workers have the right to know and understand the hazardous chemicals they use and how to work with them safely.”
    • Employer must make this information available to employees.
    • The hazard communication standard applies to any business, including manufacturers that use hazardous chemicals, regardless of the number of individuals employed.
13. Slide 13
    • What is Respirable Crystalline
    • Silica?
    • Crystalline silica is a common mineral found in many naturally occurring and man-made materials used at construction sites - Examples:
    • Sand
    • Concrete
    • Brick
    • Block
    • Stone
    • Mortar
    • Sili
    • c on Di o xide SiO
    • 2
14. Slide 14

    Silica? – cont.

    • What is Respirable Crystalline
    • Respirable crystalline silica – very small particles (1/100 the size of beach sand
    • or smaller), generated by high-energy operations like
    • Cutting
    • Sawing
    • Grinding
    • Drilling
    • Crushing and abrasive blasting
    • (of silica containing materials)
    • Handheld masonry saw without dust controls creates silica dust while cutting cinder blocks. (Photo courtesy of New Jersey Department of Health).
15. Slide 15

    Silica Exposure Industries, Occupations And Materials

    • INDUSTRY
    • OCCUPATIONS
    • MATERIALS
    • Ab r a sives
    • Co n cre te
    • Dirt
    • Grin din g, abradin g, bu ffi n g, an d
    • Filter Aid s
    • co n cre te w o rk)
    • De m o litio n
    • Electr on ics in d u str y
    • Min in g
    • San dblastin g (High Risk)
    • Ma ch in ist
    • Millw r igh t
    • San dblaste r (High Risk)
    • Ste e lw o rke r
    • Mica
    • Min e ral Pro du cts
    • Pain ts
    • Per lite
    • Pla stic Filler s
    • San ds
    • Silicate s
    • Sla g
    • Soa p ston e
    • So il
    • Source: OSHA’s Silica eTool
16. Slide 16

    Construction Activities Likely to Cause Silica Exposure

    • Construction activities that may result in severe silica exposure include, but are not limited to:
    • Jack hammering
    • Masonry building construction
    • Masonry or concrete building demolition
    • Brick and concrete block cutting and sawing
    • Tuckpointing
    • Tunneling
    • Earthwork and rock crushing
    • Road construction and repair
    • Rock/well drilling
    • Earth-drilling rigs operated with no dust controls may produce high levels of silica in the air. (Photo courtesy of NIOSH).
    • Abrasive blasting with sand or other silica-containing materials
    • Abrasive blasting on silica containing materials eg. concrete.
    • Concrete mixing and drilling or mixing concrete for post holes
    • Pouring concrete footers, slab foundation, and foundation walls
    • Removing concrete form work.
    • Others
17. Slide 17

    Warning!!!

    • ALWAYS REMEMBER
    • SILICA IS MORE THAN JUST A DUST !
18. Slide 18

    Health Risks Associated with Silica Exposure

    • Exposure to respirable crystalline silica has been linked to
    • Silicosis – An irreversible, often disabling, and sometimes fatal fibrotic lung disease
    • Typically occurs after many years of low to moderate
    • exposures to silica dust.
    • If one has silicosis, Tuberculosis (TB) may also be developed
    • Lung cancer
    • Occurs after exposures to very high concentrations of silica
    • Chronic obstructive pulmonary disease (e.g., bronchitis )
    • Kidney and immune system diseases
19. Slide 19

    Types of Silicosis

    • There are 3 types of silicosis:
    • Acute form:
    • Intense exposure to respirable dust of high crystalline silica content for a relatively short period (few months to less than 2 years)
    • Accelerated form:
    • Resulting from about 5-15 years of heavy exposure to respirable dusts of high crystalline silica content
    • Chronic form:
    • Most common form
    • Less intense exposure and usually more than 20 years
    • Source: Docket OSHA-2010- 0034
20. Slide 20

    Symptoms of Silicosis

    • Shortness of breath
    • Fever
    • Bluish skin at the ear lobes or lips
21. Slide 21

    Silicosis Mortality Rate

    • Over time, silicosis-related mortality has diminished in the US but has not been stopped.
    • One of the biggest industry concerns is that little or no improvements have been made since the 1990’s.
    • Especially in the past decade, mortality rate for silicosis has remained relatively constant.
    • Therefore, revamping of related regulations became necessary
    • Source: Norms database (www.cdc.gov)
22. Slide 22

    Silicosis Statistics

    • The predominant industries:
    • Manufacturing (85%)
    • Construction (8%)
    • Mining (4%)
23. Slide 23

    Authorities on Silica Regulation

    • Prevention and elimination of silicosis and silica-related disease in United States are priorities of
    • National Institute for Occupational Safety and Health (NIOSH)
    • Occupational Safety and Health Administration (OSHA)
    • Mine Safety and Health Administration (MSHA)
    • American Lung Association
24. Slide 24

    Silica Related OSHA Standards and Directive Applicable to Construction Industry

    • Several OSHA standards and directives cover operations that may expose workers to silica, including
    • The new
    • Air Contaminants (29 CFR 1910.1000)
    • Hazard Communication (29 CFR 1910.1200)
    • Respiratory Protection (29 CFR 1910.134)
    • Ventilation (29 CFR 1926.57)
    • published standard dedicated solely to Respirable
    • Crystalline Silica
    • Respirable Crystalline Silica (29 CFR 1926.1153)
    • OSHA’s Directive CPL 03-00-007 - National Emphasis
    • Program- Crystalline Silica- has detailed information on
    • Silica hazards
    • Guidelines for air sampling
    • Guidance on calculating PELs for dust containing silica
    • Other compliance information (OSHA’s Directive CPL 03-00-007)
25. Slide 25

    OSHA’s New Respirable Crystalline

    • Silica Standard
    • Hazards associated with Silica exposure has been recognized since the 1930s
    • New rule updates silica exposure regulations previously established in 1971 for general industry
    • Construction is now covered separately
    • OSHA estimates that the new standards will cut exposure for vulnerable workers as much as 5 times
26. Slide 26

    New OSHA Standard - Permissible Exposure Limit and Action Level for Construction Industry

    • Permissible Exposure
    • Limit (PEL)
    • 8-hour time-weighted average exposure limit (TWA 8 )
    • Action Level
    • (AL)
    • 50 μg/m 3 TWA 8 in the air
    • 25 μg/m 3 TWA 8 in the air
    • Illustration: courtesy U.S. EPA
    • If dust containing silica is visible in the air, there is a higher likelihood/chance that permissible exposure limit (PEL) is exceeded !
27. Slide 27

    The safest amount of silica in the air is zero.

    • How Much Silica Dust is Too Much?
    • It only takes a very small amount of very fine respirable silica dust to create a health hazard.
    • DEMONSTRATION/ILLUSTRATION
    • Rule-of–thumb:
    • if dust containing silica is visible in the air, there is a higher chance of overexposure.
28. Slide 28

    Applies to all occupational exposures to respirable crystalline silica in construction work

    • OSHA Silica Standard Scope and Application
    • Exception:
    • The standard does not apply if the exposure is below the allowed AL as an 8-hour time-weighted average (TWA) under any foreseeable conditions
29. Slide 29

    OSHA Silica Standard

    • Definitions
    • Permissible Exposure Limit (PEL): The maximum amount or concentration of a chemical that a worker may be exposed to under OSHA regulations. ( 50 μg/m 3 )
    • Time Weighted Average (TWA) : The time-weighted average exposure for the work shift.
    • Action Level: Exposures at or above this concentration (25 μg/m 3 8-hour TWA), trigger requirements for exposure assessment (std applies).
    • Competent Person: Designated person capable of identifying existing and foreseeable respirable crystalline silica hazards, and has authorization to take prompt corrective measures to eliminate/minimize them. Must have knowledge and ability to implement exposure control plan.
30. Slide 30

    OSHA’s Silica Standard

    • Definitions
    • Employee Exposure: Exposure to airborne respirable crystalline silica if employees were not using a respirator.
    • High - Efficiency Particulate Air (HEPA) Filter: 99.97 percent efficient in removing mono-dispersed particles of 0.3 μm in diameter (used for vacuuming in housekeeping)
    • Objective Data: Information demonstrating employee exposure to respirable crystalline silica from a particular product, material, process, task, or activity examples.
    • Data must reflect workplace conditions (types of material, control methods, work practices, and environmental conditions in the employer’s current operations)
31. Slide 31
    • OSHA’s Silica Standard Definitions – cont.
    • Physician or Other Licensed Health Care Professional [PLHCP]: An individual whose legally permitted scope of practice (i.e., license, registration, or certification) allows him/ her to independently provide or be delegated the responsibility to provide some or all of the particular health care services.
    • Specialist: An American Board Certified Specialist in Pulmonary Disease or Occupational Medicine.
32. Slide 32

    When are Employers Required to Comply with the New Standard?

    • The Final Rule has been in effect since June 23, 2016 for all industries, after which industries have one to five years to comply with most requirements, based on following schedule:
    • Construction - June 23, 2017, one year after effective date
    • Enforcement now begins on September 23, 2017
    • General Industry and Maritime - June 23, 2018, two years after effective date
    • For construction, all obligations for compliance commence one year after effective date, with the exception that certain requirements for laboratory analysis commence two years after effective date
    • In the oil and gas industry, obligation for engineering controls commences 5 years after effective date for hydraulic fracturing operations
    • In general industry and maritime, obligation for employers to offer medical surveillance commences
    • 2 years after effective date for employees exposed above PEL
    • 4 years after effective date for employees exposed at or above action level
33. Slide 33

    Silica Exposure Control Methods for Construction

    • The first step for an employer is to determine if the standard applies to his/her work.
    • If the work is covered by the standard, the new standard provides flexible alternatives. Employers can either choose;
    • Specified exposure control methods
    • Use a control method laid out in Table 1 of the construction standard; or
    • Alternative exposure control methods
    • Measure workers’ exposure to silica and independently decide which dust control methods work best to limit exposures to the PEL in their workplaces
34. Slide 34

    OSHA’s Silica Standard

    • Specified Exposure Control Methods
    • Table 1 ( can be viewed at https://www.osha.gov/pls/oshaweb/owadisp.sh ow _document?p_table= STANDARDS&p_id=1270)
    • Lists 18 common tasks covering various types of tools or equipment found on construction sites
    • Describes the engineering controls (Specified Exposure Control
    • Methods) when working with materials containing silica
    • Employers who comply with Table 1 are not required to conduct exposure assessments, or comply with the PEL threshold for those employees engaged in tasks creating exposures.
    • Complying with Table 1 means fully and properly implementing
    • the engineering controls
35. Slide 35

    OSHA’s Silica Standard

    • Specified Exposure Control
    • Methods – cont.
    • Employees engaged in Table 1 tasks include
    • the equipment operator; helpers, laborers and other employees who are assisting with the task; or any other employee responsible for completing the task.
    • “Fully and properly implemented” means controls are in place, are properly operated and maintained according to manufacturers’ instructions, and employees understand how to use them.
36. Slide 36

    Engineering Controls for Silica Exposure

    • If silica is generated, OSHA requires engineering controls involving a mechanical process to eliminate exposure to silica dust
    • 2 main methods are used to control silica dust while operating
    • Integrated Water Delivery Systems (IWDS)
    • Water is supplied to equipment by
    • a pressurized container,
    • a constant water source e.g. a hose connected to a faucet
    • Using water will usually reduce levels to below the PEL in construction activities
    • Vacuum Dust Collection Systems (VDCS)
    • Good method for reducing silica exposures, but may not reliably keep exposure below PEL
    • VDCSs include dust collector (hood or shroud), vacuum, hose and filter(s).
    • Handheld masonry saw using water for dust control while cutting cinder blocks. (Photo courtesy of New Jersey Department of Health).
37. Slide 37

    Engineering Controls for Silica Exposure – cont.

    • Respiratory Protection - LAST LINE OF DEFENSE
    • When VDCSs and wet cutting are not feasible, or do not reduce silica exposures to PEL, workers need respiratory protection.
    • Respirators must fit properly to prevent leaks around the edges
    • Fit-testing must be done with the same make, model, style, and size of respirator that will be used before first wearing a respirator
    • Only wear the model and size of respirator that you were fit tested with
    • It is not permitted to have
    • Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function
    • Any condition that interferes with the face-to-facepiece seal or valve function
38. Slide 38

    Engineering Controls for Silica

    • Exposure -
    • Integrated Water Delivery Systems
    • IWDS are required for several types of equipment
    • when using such tools and equipment
    • An adequate supply of water for dust suppression is needed (at the flow rates specified by the manufacturer)
    • The spray nozzle must be working properly to apply water at the point of dust generation
    • The spray nozzle should not be clogged or damaged
    • All hoses and connections must be intact.
    • Handheld masonry saw using water for dust control while cutting cinder blocks. (Photo courtesy of New Jersey Department of Health).
39. Slide 39

    Engineering Controls for Silica Exposure

    • Integrated Water Delivery Systems – cont.
    • When using wet methods, effective control of the dust depends on the following factors
    • Dust particle size
    • Dust particle velocity
    • Higher the velocity, higher the flow rate
    • Spray nozzle size and location
    • Use of surfactants or other binders
    • Handheld masonry saw using for dust control while
    • Environmental factors (water hardness, humidity, water
    • cutting cinder blocks. (Photo courtesy of New Jersey
    • weather, etc.)
    • Department of Health).
    • Therefore, it is necessary to follow manufacturers’ instructions when determining the required flow rate for dust suppression systems.
40. Slide 40
    • Engineering Controls for Silica Exposure Integrated Water Delivery Systems – cont.
    • Also;
    • Limit the secondary exposure by cleaning up any slurry generated, and the procedure should be described in the employer’s Written Exposure Control
    • Plan
    • In cold temperatures, where there is a risk of water freezing, additional work practices should be followed
    • e.g., insulating drums, wrapping drums with ice melting heat tape, or environmentally-friendly antifreeze additives
    • Electrical Safety - Use ground-fault circuit interrupters
    • (GFCIs) and watertight, sealable electrical connectors for electric tools and equipment on construction sites
    • Handheld masonry saw using water for dust control while cutting cinder blocks. (Photo courtesy of New Jersey Department of Health).
41. Slide 41

    Engineering Controls for Silica Exposure - Vacuum Dust Collection Systems

    • Commercially available dust collection systems (i.e., Local Exhaust Ventilation) are required for several equipment
    • Must effectively capture dust generated by the tool being used
    • Must not introduce new hazards, such as obstructing or interfering with safety mechanisms
    • VDCSs include a dust collector (hood or shroud), vacuum, hose and filter(s)
    • Use a vacuum with enough suction to capture dust at the cutting point.
    • Use a HEPA filter in the vacuum exhaust, and a pre-filter or cyclonic separator to improve vacuum efficiency.
    • Use a hose size recommended by the manufacturer.
    • Use a hood or shroud that is recommended by the manufacturer.
    • Grinder with attached VDCS. (Photo courtesy of the University of Washington). Detail of grinder with VDCS attachment. (Courtesy of NIOSH).
    • Source: OSHA Small Entity Compliance Guide for the Construction Silica Standard
42. Slide 42

    Engineering Controls for Silica Exposure - Vacuum Dust Collection Systems – cont.

    • For best results, employees must
    • Keep the vacuum hose clear and free of debris, kinks and tight bends
    • Follow the manufacturer’s directions on how to reduce dust buildup on the filter.
    • Change vacuum-collection bags as needed.
    • Set up a regular schedule for filter cleaning and maintenance.
    • Avoid exposure to dust when changing vacuum bags and cleaning or replacing air filters.
    • Keep the grinder at the appropriate angle.
    • Minimizing the gap between the shroud and uncut mortar. (Illustration courtesy of NIOSH).
    • Worker grinding without dust controls. Note the use of shielded Powered Air- Purifying Respirator. (Photo courtesy of CPWR).
43. Slide 43

    Workplace Controls for Silica Exposure

    • Along with the engineering controls, OSHA also requires workplace controls to eliminate exposure to silica dust
    • Safety program and training
    • Employers must train employees covered by the standard on
    • Health hazards associated with silica exposure
    • Specific workplace tasks that could expose employees to silica
    • Specific measures the employer is implementing to protect employees
    • The contents of the silica standard.
    • Training must be provided at the time employees are assigned to a position involving exposure to silica
    • Additional training must be provided if
    • the employer asks an employee to perform a task that is new to that employee
    • the employer introduces new protections
    • an employee is working in a manner that suggests he or she has forgotten what was learned in training.
44. Slide 44

    Exposure – cont.

    • Workplace Controls for Silica
    • Housekeeping
    • Standard limits the use of certain cleaning methods to prevent unnecessary exposures to employees
    • When likely to contribute to exposure, employers must not allow
    • Dry brushing or dry sweeping
    • Using compressed air for cleaning of surfaces or clothing, unless accompanied by a ventilation system that effectively captures the dust
    • The above methods can be used, when other methods such as wet sweeping and/or HEPA-filtered vacuuming are not feasible, the employer must be able to show why cleaning methods that decrease employee exposures are not feasible
    • Regulated Areas for Construction
    • Restrictions for access to work areas, to minimize numbers of employees exposed to respirable crystalline silica
45. Slide 45

    TABLE 1 Summary -

    • Silica Control Compliance for Construction
46. Slide 46

    TABLE 1 Summary -

    • Silica Control Compliance for Construction – cont.
47. Slide 47

    TABLE 1 Summary - Silica Control Compliance for Construction – cont.

48. Slide 48

    TABLE 1 Summary - Silica Control Compliance for Construction – cont.

49. Slide 49

    TABLE 1 Summary -

    • Silica Control Compliance for Construction – cont.
    • Earthmoving using a dozer equipped with enclosed operator cab.
    • DISLAIMER: This Table is for training and awareness purposes only. It should not be used as a standard for compliance purposes.
50. Slide 50

    Mandatory Requirements for Silica Exposure Control – Detailed Summary

    • All construction employers covered by the standard are required to
    • Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur
    • Provide respiratory protection when required;
    • Designate a competent person to implement written exposure control plan
    • Restrict housekeeping practices that expose workers to silica, where feasible alternatives are available
    • Offer medical exams 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
    • Train workers on work operations that result in silica exposure and ways to limit exposure
    • Keep records of workers’ silica exposure and medical exams
51. Slide 51

    Respiratory Protection

    • Must comply with requirements of the Silica Standard and with OSHA’s Respiratory Protection Standard (29 CFR 1910.134).
    • Assigned Protection Factor (APF) means the workplace level of respiratory protection that a respirator or class of respirators is expected to provide to employees when the employer implements a continuing, effective respiratory protection program as specified by the Respiratory Protection Standard.
    • EMPLOYERS MUST
    • PROVIDE
    • AND EMPLOYEES MUST USE
    • APPROPRIATE RESPIRATOR
    • (APF)
    • IF IT IS REQUIRED BY THE SILICA STANDARD
    • OR
    • ENGINEERING CONTROLS
    • CAN NOT GET EXPOSURES
    • BELOW PEL
52. Slide 52

    Compliance with OSHA 29 CFR

    • 1910.134 – Respiratory Protection
    • Standard
    • Providing employees with appropriate respirators requires compliance with OSHA 29 CFR
    • 1910.134 - Respiratory Protection Standard, which requires
    • A written respiratory protection program
    • Medical evaluation to determine if the employee is fit to wear a respirator
    • Employee Training in proper use, limitations, and storage of the respirator selected for use
    • Fit testing to determine that the respirator selected for use fits properly
    • Procedures and schedules for respirator maintenance
    • APF=10
    • Needs to be fit tested
53. Slide 53
    • Respiratory Protection – cont.
    • Table 1 specifies the type or class of required respirator that is expected to be provided to employees with a minimum assigned protection factor (APF)
    • Air-purifying respirator with dust cartridge
    • Supplied air respirator
    • Employer shall ensure that all filters and cartridges used in workplace are labeled and color coded
    • Labels must be NIOSH approved
54. Slide 54
    • Respiratory Protection – cont.
    • In implementing Table 1, respiratory protection is required under
    • the following conditions according to the new Respirable Silica
    • Standard
    • Where exposures exceed the PEL during periods necessary to
    • install or implement feasible engineering and work practice controls
    • Where exposures exceed the PEL during tasks, such as some
    • maintenance and repair tasks, for which engineering and work practice controls are not feasible
55. Slide 55

    Written Exposure Control Plan

    • All employers covered by the standard must develop and implement a Written Exposure Control Plan. (SAMPLES can be generated at Silica-safe.org or can be viewed in OSHA Small Business Compliance Guide)
    • This includes employers who fully and properly implement the specified exposure controls in Table 1.
    • Written exposure control plans must include and describe
    • Tasks involving exposure to silica
    • Engineering controls, work practices, and respiratory protection for each task
    • Housekeeping methods used to limit exposure
    • Procedures used to restrict access to work areas, when necessary, to limit the number of employees exposed to respirable crystalline silica
    • The Plan must be reviewed and evaluated at least once a year and updated as necessary
    • It must be available to each employee covered by the standard, their designated representative, and representatives from OSHA or NIOSH, upon request.
56. Slide 56

    Written Exposure Control Plan – Competent Person

    • The employer must designate a competent person to implement the written exposure control plan
    • Competent person is an individual capable of
    • Identifying existing and foreseeable silica hazards;
    • Is authorized to promptly eliminate or minimize these hazards; and
    • Has the knowledge and ability to implement the written exposure control plan.
    • He/she makes frequent and regular inspections of job sites, materials, and equipment
    • The standard does not require specific training for a competent person.
    • COMPETENT
57. Slide 57

    Medical Surveillance

    • Employers must offer medical examination to workers who will be required to wear a respirator under the standard for 30 or more days a year.
    • Medical Surveillance is intended to
    • Identify respirable crystalline silica-related diseases so that employees with those diseases can take actions to protect their health
    • M ina • Determine if an employee has any condition, such as
    • a lung disease, that might make him or her more
    • sensitive to respirable crystalline silica exposure
    • Determine the employee’s fitness to use respirators
    • Note that it is different than medical evaluations needed to comply with OSHA 1910.134
58. Slide 58

    Medical Surveillance – cont.

    • What are included in the medical examination?
    • Medical and work history
    • Physical exam
    • Chest X-Ray
    • Lung function test
    • Any other tests deemed appropriate by the PLHCP (as medically necessary and related to respirable crystalline silica exposure)
    • Tuberculosis Test (TB test)
    • Frequency of Medical
    • Examinations
    • Within 30 days of initial assignment
    • Every three years from the last examination, or more frequently if recommended by the PLHCP, if the employee will continue to perform tasks that require respirator use under the silica standard for 30 or more days per year
59. Slide 59
    • Medical Surveillance -
    • Requirements
    • The standard requires a written medical report be provided to the employee as well as detailed information related to employee's health, any work restrictions, and recommendations for any further evaluation or treatment.
    • Sam
    • ple
    • For Med
    • ms ical
    • Ap
    • in p
    • The employer does not receive a copy of this report. t
    • en dix
    • he
    • Sta
    • HIPAA (Health Insurance Portability and Accountability Act
    • da f
    • of 1996)
    • rd
    • The standard requires employer to obtain a written medical opinion from PLHCP
    • the date of the examination;
    • a statement that the examination has met the requirements of the silica standard; and any recommended limitations on the employee’s use of respirators.
    • If employee provides written authorization, written opinion provided to employer may also include recommended limitations on employee's exposure to respirable crystalline silica, and referral to a specialist.
60. Slide 60

    Communication of Silica Hazards

    • Employers are required to comply with OSHA Hazard
    • Communication Standard- HCS (29 CFR 1910.1200).
    • HCS requires employers to inform employees about hazardous chemicals in the workplace, such as respirable crystalline silica, through their written hazard communication programs.
    • Written hazard communication programs must describe how the requirements for container labels, safety data sheets (SDSs), and employee training will be met.
    • Employers must address at least the health hazards on cancer, lung effects, immune system effects, and kidney effects as part of the hazard communication program for respirable crystalline silica.
61. Slide 61

    Communication of Silica

    • Hazards – cont.
    • Under the HCS, employers must
    • Inform employees about the general requirements of HCS
    • Train employees on how the presence or release of hazardous chemicals in the work area is detected
    • Train employees on the details of the workplace-specific hazard communication program developed by the employer, such as container labels, the workplace labeling system, SDSs, and how employees can get and use hazard information.
    • Employers must make a copy of the respirable crystalline silica standard available to each employee covered by the standard at no cost to the employee.
62. Slide 62

    Communication of Silica

    • Hazards - Safety Data Sheets
    • (SDS)
    • SDSs contain data for all materials or products containing hazardous substances
    • If a material or product contains crystalline silica in
    • SILICA
    • quantities greater than 0.1%, there must be a safety
    • CONTAINING
    • data sheet for it
    • MATERIALS
    • Manufacturer's responsibility: Manufacturers SAFETY DATA
    • must obtain or develop a safety data sheet for each
    • SHEET
    • hazardous chemical they produce or import
    • (SDS)
    • Employer's responsibility: Employers must ensure access to safety data sheets for all hazardous materials at the workplace
63. Slide 63

    Recordkeeping

    • Per OSHA’s Access to Employee Exposure and Medical Records regulation (29 CFR
    • 1910.1020), employers must maintain records for
    • Medical records (PLHCP written medical opinion to employer)
    • RECORDS TO MAINTAIN
    • Air monitoring data - if employers perform air monitoring to comply with the standard.
    • Objective data - if employer relies on objective data
    • Medical records
    • Exposure and medical records must be kept and made available to
    • Employees, their representatives, and OSHA
64. Slide 64

    Alternative Silica Exposure Controls

    • Employers opting for not to implementing Table 1 must follow the alternative exposure control methods approach
    • This approach involves
    • Assessing employee exposure to silica
    • Limiting exposure to the PEL using feasible engineering and work practice controls
    • Providing respiratory protection when necessary.
65. Slide 65

    Exposure Assessment

    • Employers following alternative exposure control methods must assess the 8-hour TWA exposure for each employee
    • Purposes of assessing employee exposures include
    • Identifying where exposures are occurring
    • Helping the employer select control methods and ensure their effectiveness
    • Preventing employees from being exposed to silica above the PEL
    • Providing employees with information about their exposure levels
    • Giving the PLHCP performing medical examinations information about employee exposures
66. Slide 66

    TWA Exposure Calculation

    • The TWA exposure for an 8-hour work shift is calculated as
    • TWA = (Ca Ta + Cb Tb+ . . . +Cn Tn) ÷ 8 where C is the silica concentration (µg/m 3 ), and T is the exposure duration (in hours) at concentration C
    • Example:
    • Given: 2 hours exposure at 100 µg/m 3 ; 2 hours exposure at 50 µg/m 3 ; and 4 hours exposure at 10 µg/m 3
    • TWA = (2 x 100 + 2 x 50 + 4 x 10) ÷ 8 = 42.5 µg/m 3
    • Because 42.5 µg/m 3 is higher than 25 µg/m 3 , this employee’s TWA exposure would be above the action level, but below the PEL of 50 µg/m 3 .
67. Slide 67

    Exposure Assessment Options

    • The standard applies to the three forms of respirable crystalline silica that are covered by the standard
    • Quartz - by far the most common form of silica found in construction
    • Cristobalite (less common)
    • Trydimite (less common)
    • Options for assessing exposures are
    • Performance option
    • Scheduled monitoring option
68. Slide 68

    Exposure Assessment – Performance Option

    • Performance Option gives flexibility to determine silica exposure for each employee based on any combination of air monitoring data or objective data (must reflect workplace conditions)
    • Air monitoring data are obtained by following the procedures and requirements in Appendix A of the Standard
    • Objective data is information that demonstrates employee exposure to silica associated with a particular product or material, or a specific process, task, or activity.
    • Examples of objective data
    • Air monitoring data from industry-wide surveys
    • Historic air monitoring data
    • Calculations based on the composition of a substance
69. Slide 69

    Performance Option - Employer Responsibilities

    • Employers under the Performance Option must
    • Conduct the exposure assessment before work begins
    • Reassess exposures whenever a change in production, process, control equipment, personnel, or work practices may reasonably be expected
    • Be able to demonstrate that employee exposures have been accurately characterized
    • Make sure that the exposure assessment reflects the exposures of employees on each shift, for each job classification, in each work area
70. Slide 70

    Exposure Assessment – Scheduled Monitoring

    • This option guides employers as to when Option
    • and how often they must perform exposure monitoring to measure employee exposures.
    • Under this option, employers must make sure that
    • Results represent the employee’s TWA exposure to silica over an eight-hour workday
    • Samples are collected from the employee’s breathing zone
    • Samples are collected outside respirators so that they represent the exposure that would occur without the use of the respirator
    • Initial monitoring is conducted as soon as work begins, so exposure levels and control measures can be determined
    • Exposure monitoring includes, at a minimum, one full-shift sample taken for each job function in each job classification, in each work area, and on each shift.
    • Characterizing each employee’s exposure may involve monitoring all exposed employees, or a smaller number of employees (using representative sampling).
71. Slide 71

    Scheduling Option - Monitoring Frequency

    • Under the scheduled monitoring option, decision on the frequency of monitoring depends on the results of initial monitoring
    • If the initial monitoring shows exposures are below the action level, no further monitoring is required
    • Between AL and PEL, the employer must repeat monitoring within six months of the most recent monitoring
    • Above the PEL, the employer must repeat monitoring within three months of the most recent monitoring.
72. Slide 72

    Reassessment of Exposures

    • Employer must reassess exposures whenever a change in production, process, control equipment, personnel, or work practices may occur, potentially resulting in increased exposure to silica at or above the action level (AL).
    • Employers do not have to conduct additional monitoring simply because a change has occurred, unless the AL threshold is exceeded. Example - Reassessment is not required when a task is moved from an indoor to an outdoor location, or when a product is replaced with that has lower silica content (check SDS to determine % silica) keeping the same process.
    • Note that the reverse is not true! Moving from outdoor to indoor location, or a new product with higher silica concentration may critically change employee exposure requiring reassessment.
73. Slide 73

    Methods of Sample Analysis

    • Employers must make sure that all air samples taken to meet the requirements of the Silica Standard are analyzed by a laboratory that follows the procedures given in Appendix A of the Standard.
74. Slide 74

    Employee Notification

    • Employers must notify each affected employee of the results of the exposure assessment within 5 working days of completing it.
    • “Affected” means all employees whose exposures were assessed, including employees whose exposures were represented by other employees’ exposure measurements, and those whose exposure assessments were based on objective data.
    • Employers must either notify each employee in writing or post the results in a location accessible to all affected employees
75. Slide 75

    Employee Notification with Corrective Action

    • When an exposure assessment reveals exposures above the PEL, the written notification must also describe the corrective action the employer is taking to reduce employee exposures to or below the PEL.
    • Corrective actions include engineering controls. However, if engineering controls are not feasible or the employer needs more than 5 days to identify the right engineering controls, respiratory protection is the corrective action that would be described in the written notification.
76. Slide 76

    Observation of Monitoring

    • The employer must let affected employees or their designated representatives observe any air monitoring of employee exposure to silica.
    • When needed, employer must provide protective clothing and/or equipment (i.e. respirator) at no cost to the observer, and make sure that the observer uses such clothing or equipment.
    • If observation can be done from outside the hazardous areas, no protective clothing or equipment would be needed.
77. Slide 77

    Methods of Compliance

    • The methods of compliance section of the standard requires employers to protect employees following the hierarchy of controls, which relies on
    • Engineering and work practice controls for reducing exposures, and only allows for respirator use, in addition to those controls, when feasible engineering controls cannot reduce employee exposures to levels below PEL
    • Even when employers demonstrate the infeasibility of engineering and workplace controls, they must still use feasible controls to reduce exposures to the lowest possible level, and then use respiratory protection along with those controls.
78. Slide 78

    Methods of Compliance – cont.

    • Employers who follow either of the exposure control methods
    • (Table 1 or alternative) must provide respiratory protection.
    • Respiratory protection is necessary under the following conditions
    • Where exposures exceed the PEL during periods necessary to
    • implement feasible engineering and work practice controls
    • Where exposures exceed the PEL during tasks, such as some
    • maintenance and repair tasks, for which engineering and work practice controls are not feasible
79. Slide 79

    Abrasive Blasting

    • The Methods of Compliance section also cross-references other OSHA standards that apply to abrasive blasting.
    • In addition to complying with requirements to use engineering controls and work practices according to the hierarchy of controls, construction employers that conduct abrasive blasting operations using silica-containing blasting agents or conduct abrasive blasting on structures that contain silica must also comply with other relevant standards, such as the ventilation standard for construction (29 CFR 1926.57), which contains requirements for ventilation and personal protective equipment, including respirators.
80. Slide 80

    COMPLIANCE WITH THE STANDARD

    • A SUMMARY
    • Source: OSHA Small Entity Compliance Guide for the Construction Silica Standard
81. Slide 81

    Additional Resources

    • Additional resources for trainees:
    • OSHA Silica Website <https://www.osha.gov/silica/>
    • OSHA silica exposure brochure <https://www.osha.gov/dte/library/silicosis/si_gi.pdf>
    • OSHA Safety and Health Topics Page <https://www.osha.gov/dsg/topics/silicacrystalline/index.html>
    • OSHA Small Business Compliance Guide
    • <https://www.osha.gov/Publications/OSHA3902.pdf>
    • CPWR Silica Website <https://www.silica-safe.org>
82. Slide 82
    • ANY QUESTIONS?
83. Slide 83

    POSTTEST

    • PLEASE START THE POSTTEST
    • SILICA
    • TRAINING
    • (15 MIN)
84. Slide 84

    Q/A SESSION

    • INTERACTIVE
    • POSTTEST Q/A
    • SILICA TRAINING
    • (PLEASE
    • GRADE YOUR
    • PRETEST AND POSTTEST)
85. Slide 85

    OPINION SURVEY

    • PLEASE FILLOUT THE OPINION
    • SURVEY
    • SILICA AND
    • TRAINING
    • HAND IN THE TRAINING PACKAGE
    • TO THE TRAINING COORDINATOR
86. Slide 86

    THANK YOU!