Review of 1926.1153: OSHA’s Silica Standard for Construction

1. Review of 1926.1153:OSHA’s Silica Standardfor Construction

2. Outline • What type of silica are we talking about? • Where do we find it and who does it impact? • What are the health effects? • What does the new standard require? • How do we best control the dust? • Water, ventilation, enclosures, respirators • What must we convey to employees? • What records do we keep?

3. Brief History on Silica Standard • US DOL first highlighted hazards of respirable crystalline silica in the 1930’s • First silica standard set in 1971 when OSHA was created • Standard did not adequately protect workers from disease • Rule first proposed in September 2013 • Over 2000 comments- amounting to 34,000 pages of material

4. Scope • Applies to all exposures to respirable crystalline silica (RCS) except where employee exposure will stay below the OSHA Action Level (25 ug/m3; 8-hour time-weighted average exposure) under any foreseeable condition. Commonly Involved Materials: • Sand • Concrete • Mortar • Block (CMU) • Terrazzo • Stone/Rock (granite, quartz, etc.) • Thinset, grout, stucco, color hardners Exemption Examples: limited mixing concrete for post holes; pouring concrete footers, slab foundation and foundation walls; removing concrete formwork  reasonably expected to be < 25 ug/m3

5. Types of Silica “It’s Not Just Dust” • Reactive particles • Crystalline silica • SiO2 • “Free silica” • 3 most common forms: • quartz, tridymite, and cristobalite • Regulated • Amorphous silica • Glass; “free-flowing or anti-caking” additive for paints, powders • Non-regulated

6. “Regular Dust” vs “Respirable Dust” Respirable dust: <10 microns (µm) 100 times smaller than ordinary beach sand Photo credit: http://blog.eyewire.org/wp-content/uploads/2012/11/micron-scale.jpg

7. Respiratory System Diagram credit: pulmonary alveolus. (2016). In Encyclopædia Britannica. Retrieved from https://www.britannica.com/science/pulmonary-alveolus

8. 1) Lung Disease • Silicosis: • Incurable lung disease that can lead to disability and death • Nodular pulmonary fibrosis (lung scarring) • Progression can occur even if exposure removed Signs & Symptoms: shortness of breath, dry cough, wheezing, weakness • Classes of Silicosis • Acute (weeks-5 years) • Accelerated (5-15 years) • Chronic (15 years+) Diagram credit: Bob Glenn

9. 1) Lung Disease (cont’d) • Lung Cancer: known human carcinogen • COPD: i.e. bronchitis and emphysema • Tuberculosis (TB): • An infectious disease • Both exposure to silica and silicosis are risk factor for contracting/developing TB • Exposure to silica can increase the risk for latent TB to convert to active TB • Silica-exposed employees are 3-30 times more likely to develop active pulmonary TB • Certain populations at increased risk for TB: • African-American, Hispanics, Asians • Co-morbid medical conditions • Incarcerate • Homeless • Foreign-born

10. Additional Health Effects: 2) Kidney (Renal) Disease 3) Immune System Disease Autoimmune diseases: Where the body’s immune system attacks healthy cells Scleroderma Lupus Rheumatoid arthritis • Slightly soluble in blood, which is how it can migrate in the body from the lung to the kidney’s

11. Permissible Exposure Levels • Permissible Exposure Level (PEL): • 50 ug/m3 • Action Level (AL): • 25 ug/m3 From UK HSE Time to Clear the Air: Protect Your Lungs When Using Cut-Off Saws http://www.pavingexpert.com/pdf/KerbCutting_PDF.pdf

12. OSHA’s Crystalline Silica Standard29 CFR 1926.1153 • Exposure Determination • Use of OSHA’s predetermined list of tasks and control strategies (Table 1) --- OR --- • Completion of exposure assessment (air monitoring/objective data) • Written Exposure Control Plan • Designation of Competent Person • Provision of Medical Surveillance • Training • Recordkeeping Requirements

13. Tasks/Equipment Covered Under Table 1 • Dowel drilling rig for concrete • Vehicle-mounted drilling rigs for rock/concrete • Jackhammers and handheld powered chipping tools • Handheld grinders (mortar removal) • Handheld grinders (other uses) • Walk-behind milling machines and floor grinders • Stationary Masonry Saws • Handheld power saws • Handheld power saws for cutting fiber cement boards • Walk-behind saws • Drivable saws • Rig-mounted core saws or drills • Handheld & stand-mounted drills (including impact and rotary hammer drills)

14. Tasks/Equipment Covered Under Table 1 • Heavy equipment and utility vehicles used for grading and excavating. • Small drivable milling machines (<half-lane) • Large drivable milling machines (≥half-lane) • Crushing machines • Heavy equipment and utility vehicles used to abrade, fracture or demolish silica-containing materials

15. Exposure Determination • Determine applicability of the standard • What materials are used? • What tasks are completed and are they on Table 1? • Does the task/equipment used always comply with the listed engineering controls and work practice control methods listed on Table 1? • Modify task/equipment as necessary to comply with Table 1 (if possible) • No air monitoring required if in compliance with listed Table 1 controls • If unable to modify (or fully and properly implement)  Go to Step 2 • Identify any tasks performed that are NOT included on Table 1 • Determine exposure levels using 1 of 2 options • Perform representative air monitoring (following scheduled monitoring approach) • Use existing representative objective data or combine with air monitoring data

16. Option A: Table 1 Compliance Table 1 is Non-Negotiable. Each component must be fully and properly completed in order to be in compliance. • Pay attention to: • Location (indoors or enclosed area, outdoors) • AND’s & OR’s • Respiratory protection

17. Option A: Table 1 (Continued) • Follow specified control measures • Pay attention to duration of time task is performed • Pay attention to indoors/enclosed areas and exhausted dust • Pay attention to water flow rates • Cabs/Booths (gaskets, seals, positive pressure, filtration, conditioned air) -OR- • Assess and limit the exposure of employee using the “Alternative Exposure Control Methods”

18. Option B: Evaluation by objective data • Air monitoring data from industry-wide surveys, or • Calculations based on the composition of a substance (found in SDS) • The data must reflect workplace conditions • May be able to use this to show there is no potential for exposures >AL

19. Written Exposure Control Plan • Descriptions of: • Tasks creating exposure • Specific Engineering controls/work practices/respiratory protection used to limit exposure • Housekeeping measures • Procedures to restrict access to work areas (when necessary) – including exposures generated by other employers • Reviewed annually

20. Competent Person Inspections • OSHA expects “routine observations” of dust-generating tasks to be made by the CP • If increases in visible dust occur, the competent person’s assigned role is to take prompt, corrective action. • Capable of identifying existing and foreseeable silica hazards in workplace AND who has authorization to take corrective measures • Make frequent and regular inspection of jobsites, materials, and equipment to implement the written ECP

21. Control Options • Substitution • Water Suppression • Capture, Contain and Exhaust the Dust • Respiratory Protection • Minimizing the number of employees exposed Task 16: Crushing Machine

22. Water Delivery Systems • OSHA is requiring the use of an “integrated water delivery system” supplied by the equipment manufacturer for several pieces of equipment on Table 1. • Purpose: they are more likely to control dust emissions effectively by applying water at the dust-generating site and less likely to interfere with other tool components or safety devices. But • Not intending to prohibit use of other dust suppression methods. • May implement other controls or wet method configurations if determined that the employers alternative is more appropriate. However: • Must conduct exposure assessments and comply with the PEL as required by paragraph (d)

23. Dust Collection Systems • OSHA is requiring the use of “commercially available dust collection system” for several pieces of equipment on Table 1 • Purpose: These pieces of equipment are appropriately designed for the tool being used and will be effective in capturing the dust generated from the tool/task AND won’t introduce additional safety hazard BUT • Not intending to prevent employers from using custom-made products or after-market manufacturers equipment that are intended to fit the make and model of the tool. Goal is to prevent ineffective “on-site improvisation” • Employer is free to improvise and use controls not “commercially available,” however: • MUST conduct exposure assessments and comply with the PEL as required by paragraph (d)

24. (c)(2)(ii) – Table 1 Wet Methods • “For tasks performed using wet methods, apply water at flow rates sufficient to minimize visible dust” • How much water? • OSHA judged that adequate dust control requires a constant spray of water to the work area.

25. “Enclosed Cabs” (c)(2)(iii) When tasks are completed including an enclosed booth or cab, ensure the following: • Limited settled dust • Properly functioning doors and door seals • Good condition gaskets & seals • Positive pressure via continuous supply of fresh air • Intake air passes through a 95% efficient filter (0.3-10 µm range) – example: MERV-16 or better rating • Can heat and cool

26. Control Take-Aways • Employees must be able to demonstrate proper use • Plan appropriately for disposal of collected dusts • Clean-up from wet methods • Clean-up from vac systems • Know what to do if intended controls aren’t working/available

27. Housekeeping • Required when: “Cleaning could contribute to employee exposure to RCS” • Cleaning up particles from high energy type tasks • Not intended to apply to cleaning up ordinary soil or large debris. • No dry brushing or dry sweeping • Unless wet sweeping or HEPA-vacuuming is infeasible (must be able to demonstrate why it’s infeasible) • No cleaning of surfaces or clothing with compressed air • Unless something is used to capture dust cloud

28. Training of Employees on Silica Exposure • Include silica in Haz Com program • Containers with silica must be labeled and have SDSs • Training must include: • Health Hazards: cancer, lung effects, immune system effects, and kidney effects associated with exposure to silica • Tasks where employees might be exposed and Controls in place • The contents of the silica standard • The purpose and a description of the medical surveillance program • Copies of the silica standard should be available to employees

29. Respiratory Protection and the Silica Standard 29 CFR 1910.134

30. Objectives • Definitions: What is a respirator? • Table 1 Requirements and selecting the correct respirator for silica • Respiratory Protection Standard Requirements • Resources

31. Refresher: Two Classes of Respirators • 1) Air-purifying respirators - respirators with an air-purifying device that remove air contaminants (such as dusts, fumes, mists, vapors, or fibers)before the air is inhaled. The dirty air isdrawn through an air-purifying element and “cleaned” before it reaches the lungs. • 2) Atmosphere-supplying respirators - provide clean breathing air from an uncontaminated source Most likely to use under this standard

32. Refresher: Two Operational Modes 1) Negative Pressure– A type of respirator where the wearer has to do the work of breathing in and drawing the dirty air through the cleaning element. 2) Positive Pressure - A type of respirator where flow of clean air is supplied into the facepiece/mask via a blower/airline. Most likely to use under this standard

33. Refresher: Air Purifying Respirators • Tight-fitting respirator • Negative pressure • Only for use against particles • One of most common types used in construction “Dust Mask” or “N95” or “Particulate Filtering Facepiece” OSHA APF = 10

34. Refresher: Air Purifying Respirators • Tight-fitting respirator • Negative pressure • Uses replaceable filters, canisters, or cartridges • 2nd most common type Half Mask OSHA APF = 10

35. Refresher: Air Purifying Respirators • Tight-fitting respirator • Negative pressure • Uses replaceable filters, canisters, or cartridges • Provides eye protection Full Face Respirator OSHA APF = 50

36. Refresher: Air-Purifying Respirator • Loose-fitting respirator • Positive Pressure • Uses replaceable filter (mounted in helmet) • Provides head protection • Powered Air Purifying Respirator (PAPR) PAPR (helmet) OSHA APF = 25 or 1000

37. Elements of a Respiratory Protection Program-per 1910.134- 1. Selection 2. Medical evaluation 3. Fit testing 4. Use 5. Maintenance and care 6. Breathing air quality and use 7. Training 8. Program evaluation A Program is REQUIRED: 1) When respirators are necessary due to air contaminant overexposure 2) When respirators are required by the employer 3) If another OSHA Standard requires respirator use – i.e. the silica standard Must update program as necessary to reflect changes in workplace conditions that affect respirator use Must designate a program administrator

38. Respiratory Protection Training • Conducted annually • Address: • Procedures for selecting appropriate respirators • Medical evaluations for respirator users • Fit-test procedures for tight fitting respirators • Procedures for proper routine and/or emergency use respirators • Cleaning, storing, inspecting, repairing, & maintenance • Ensure adequate quality, quantity, and flow ofbreathing air • Respiratory hazards to which employees are exposed • How to wear, use, and care for their respirators

39. Where Respirator Use is Not Required…but Optional • Employer may provide respirators at employee’s request or permit employees to use their own respirators, if employer determines that such use in itself will not create a hazard • If voluntary use of only “disposable filtering face-pieces/N95s/Dust masks” is permissible, employer must at minimum provide users with the information contained in Appendix D (at minimum) • Voluntary use of any other type of respirator beyond a disposable filtering face-piece requires full implementation of Respiratory Protection Program

40. Employee Will Be Exposed To Silica and REQUIRED to wear a respirator Employer must receive documentation that Employee is Medically Fit To Wear a Respirator Employee must Receive Respiratory Protection Training Conduct the Initial Medical Surveillance Exam to Comply with Silica Standard BEFORE EMPLOYEE STARTS DOING WORK Before Day 30 Repeat Medical Surveillance Every THREE years Employee must be fit tested for respirator (including N-95/dust mask) Employee Must Receive Training on the Hazards of Working with Silica- including Haz Com and the Silica Exposure Control Plan

41. Medical Surveillance Requirements • Construction: • when use of a respirator is required (by the silica standard) for more than 30 days a year The initial (baseline) exam must be made available within 30 days of initial assignment UNLESS the employee has received an equivalent medical exam within the last 3 years AND THEN Periodic examinations must be made available at least every 3 years

42. Medical Evaluation of Employee • A medical and work history • Emphasis on: • Past, present, and anticipated exposure to RCS and other airborne chemicals in workplace • History of respiratory system dysfunction (shortness of breath, wheezing, cough, history of TB) • Smoking status and history • A physical examination, with special emphasis on the respiratory system • Initially and every three years • Includes heart, extremities, and other organ systems

43. 48-72 hour reading window Medical Evaluation of Employee • Tuberculosis (TB) testing (either skin or blood test) • Initial exam • PLHCP can order additional tests or test at a greater frequency • Pulmonary function testing must be performed on the initial and every three years • 2 tests (Forced vital capacity – FVC; and forced expiratory volume in 1 second – FEV1) • Must be administered by spirometry technician • A Chest X-Ray • Initial examination and every three years • Must be read by a NIOSH-certified B Reader • Required referral to Board Certified Specialist in pulmonary disease or occ med depending on x-ray result • Any other additional test • Professional judgement of PLHCP Images: CDC

44. Medical Surveillance: Reports PLHCP must provide separate reports for employer and employee • Employee: • Results must be explained and a written report provided (30 days) • Contains: • Results of exam • Including any condition placing the employee at increased risk AND any conditions requiring additional follow-up • Limitations on respirator use • Limitations for exposure • Additional referral to specialist (if warranted) • Employer: • Written medical opinion within 30 days • Contains ONLY: • Date of exam • Certification that exam met requirements • Limitations on respirator use • IF EMPLOYEE PROVIDED WRITTEN AUTHORIZATION: • Limitations for exposure • Additional referral to specialist (if warranted)

45. Records Retention for Documents • Medical evaluation (respiratory protection) and medical surveillance (silica) records must be retained for at least the duration of employment plus thirty years. • 29 CFR 1910.1020—Access to employee exposure and medical records • These records also must be made available to the employee or to his or her designated representative. • Fit test records for respiratory protection must be maintained until next test. • Exposure records- 30 years (air sampling results) – specific information required to be stored – NOT JUST THE RESULTS

46. Recordkeeping • Air monitoring records: • Date samples taken • Tasks monitored • Sampling and analytical methods used • Number, duration, and results of samples • Lab used for analysis • Type of PPE used (including respirators) • Name, SSN, and job classification of all employees represented by the monitoring AND which ones were actually monitored

47. Training of Employees on Silica Exposure • Include silica in Haz Com program • Containers with silica must be labeled and have SDSs • Training must include: • Health Hazards: cancer, lung effects, immune system effects, and kidney effects associated with exposure to silica • Tasks where employees might be exposed and Controls in place • Identity of the competent person(s) • The contents of the silica standard • The purpose and a description of the medical surveillance program • Copies of the silica standard should be available to employees

48. Additional Resources (Construction) • www.osha.gov/silica • Regulatory Text: https://www.osha.gov/silica/SilicaConstructionRegText.pdf • Fact Sheet: https://www.osha.gov/Publications/OSHA3681.pdf • FAQ’s: https://www.osha.gov/silica/Silica_FAQs_2016-3-22.pdf • Small Entity Compliance Guide: https://www.osha.gov/Publications/OSHA3902.pdf • NIOSH: • https://www.cdc.gov/niosh/topics/silica/

49. Additional Resources (Construction) • Washington State Department of Labor & Industries “Silica in Construction Training Kit”: • http://www.lni.wa.gov/SAFETY/TRAININGPREVENTION/TRAININGKITS/SILICAINCONSTRUCTION/DEFAULT.ASP • ASTM E2625 • Standard Practice for Controlling Occupational Exposure to Respirable Crystalline Silica for Construction and Demolition Activities (www.astm.org) • The Center for Construction Research and Training (CPWR): • www.silica-safe.org (includes Create-A-Plan)

50. Additional Resources • OSHA’s Free, confidential, non-enforcement safety and occupational health consultation program: • https://www.osha.gov/dcsp/smallbusiness/consult.html