As of March 2016 OSHA has released their final rule on respirable crystalline silica. The new regulations will require the construction industry to comply by June 23, 2017, general industry maritime must comply by June 23, 2018 and the fracking industry must fully comply by June 23, 2021. It will affect 2 million construction workers and 300,00 in general industry and maritime sectors, including hydraulic fracturing.
What is Crystalline Silica?
Crystalline silica is 100 times smaller than ordinary sand on a beach and makes up 70 percent of the planet’s crust (naturally occurring substance). The chemical compound is Silicon dioxide (SiO2) It is found in almost all mines – including coal. What’s the impact to health? Over-exposure is possible in occupations such as mining, construction, fracking, oil and gas, transportation, sandblasting, concrete manufacturing, demolition, and even dentistry. Crystalline silica is classified as Group One Human Carcinogen by IARC in 1997 (also by NTP) – warning must be included on SDS of silica-containing products.
How Are Workers Exposed?
Respirable dust means the particle is small enough to penetrate the respiratory system and therefore can’t be expelled. It is inhaled by workers during work activities and the particles will harm lungs. It is most often inhaled when cutting, sawing, grinding, drilling, and crushing the materials.Also, the dust is present during extraction, processing, transfer for storage and transit, or use on a well pad of sand.
Where Do We Find Silica?
Crystalline silica is present as an ingredient in the following:
- brick and mortar
- dimensional stone (granite, sandstone)
- engineered stone products (countertops etc.)
- stone aggregate
- asphalt filler
- roofing granules
- plastic composites
- wallboard joint compounds, paint, plaster, caulking and putty.
Health Findings in OSHA Rule
The United States averages Over 600 deaths per year are attributed to silica in the United States and 900 new silicosis cases prevented by rule. Crystalline Silica is categorized as respiratory toxin that causes silicosis, COPD and lung cancer. There are three types of silicosis: Chronic (15-20+ yrs), Accelerated (5-10 yrs), and Acute (months-2 yrs). OSHA also links occupational silica exposure with kidney disease. The rule states more than 50 peer-reviewed studies were evaluated and found links between silica exposure and lung cancer in at least 10 industries.
OSHA’s 2016 GI/Maritime Rule
Includes provisions for:
- Measuring worker exposures to silica if at or above 25 ug/m3 action level and workers get notification of results within 15 working days
- Using engineering controls (e.g., water, ventilation) and work practices to limit exposures from exceeding 50 ug/m3 over 8 hr time-weighted average workday
- Limiting access to areas where workers could be exposed above the PEL
- Using respirators when necessary after implementing engineering and administrative controls
- Restricting housekeeping practices that expose workers to silica if feasible alternatives are available
- Medical exams for highly exposed workers
- Worker training on work ops that result in exposure and ways to limit exposure; and
- Recordkeeping of workers’ silica exposure and medical exams
Exposure Monitoring – GI
Initial exposure monitoring should assess an eight hour TWA for silica exposure of representative employees for each job classification (picking EE with highest expected exposure). If initial monitoring shows below AL, employer may discontinue monitoring for those employees. If the most recent monitoring indicates exposure is greater than AL but less than PEL, repeat monitoring within six months. If the most recent monitoring indicates exposures are greater than PEL, repeat within three months. Where non-initial monitoring indicates exposures are less than AL, repeat monitoring within six month until two consecutive assessments are less than AL … then discontinue monitoring.
Exposures should be reassessed when a change in production, process, control equipment, personnel or work practices indicate new or additional exposures above AL, or if ER has reason to believe exposures above AL have occurred. A sample analysis must conform to Appendix A. An employee representative has the right to observe air monitoring and must be provided with appropriate PPE at no cost. Exposure records and medical surveillance must be maintained and made available in accordance with 29 CFR 1910.1020.
Under both standards, employers must provide baseline and medical exams every three years for workers exposed above the PEL for 30 or more days per year.
Physicians and other medical professionals who manage medical surveillance programs are expected to have a thorough understanding of silica-related diseases and health effects. Required exam components include:
- Medical and work history, with an emphasis on past, present and anticipated exposures
- Physical examination at baseline and every three years thereafter
- TB testing
- Pulmonary function testing administered by a NIOSH-certified spirometry technician
- Chest X-ray, must be interpreted by a NIOSH Certified B Reader
Additional optional tests may be performed on a case-by-case basis. The examiner must explain results to the examinee and provide a written medical report within 30 days. The report must identify any medical condition(s) that would place the employee at increased risk of material impairment to health and any medical conditions that require further evaluation or treatment. The report must include recommended limitations on exposures and respirator use.
For detailed medical exam requirements, contact Taylor Made Diagnostics or refer to Appendix B to §1926.1153 – Medical Surveillance Guidelines.
Each covered employee must be trained, under OSHA’s Haz Com Standard (29 CFR 1910.1200) on hazard of RCS containing products and have access to labels and SDSs.
Workers must also be trained on:
- Health hazards associated with exposure to RCS
- Specific tasks in workplace that could result in exposures
- Specific measures ER has implemented to protect EE from exposure, including engineering and WPC, and respirators to be used
- Contents of OSHA rule
- Purpose and description of medical surveillance program
Written Exposure Control Plan
An exposure control plan must have a description of tasks involving exposure to respirable crystalline silica; a description of engineering controls, work practices, and respiratory protection used to limit worker exposure for each task – engineering and WPC must be used unless employer demonstrates not feasible and a description of housekeeping measures used to limit employee exposure – dry sweeping, dry brushing, and use of compressed air not allowed (unless compressed air is part of ventilation system that captures dust cloud).
The ER must review and evaluate the effectiveness of the written plan at least annually and update as necessary. The plan must be available for exam and copying by OSHA representative.
Employers must establish a regulated area if worker exposures are expected to be above PEL, and demarcate the area from rest of workplace so as to minimize the number of exposed employees.Must post signs at all entrances with:
DANGER – RESPIRABLE CRYSTALLINE SILICA. MAY CAUSE CANCER. CAUSES DAMAGE TO LUNGS. WEAR RESPIRATORY PROTECTION IN THIS AREA. AUTHORIZED PERSONNEL ONLY.
Access must be limited to persons who are authorized by the employer and are required by work duties to be present. Anyone who is the employee’s designated representative to observe monitoring or anyone authorized by OSH Act or regulators may also be in area. Each person in the regulated area must be provided by the employer with an appropriate respirator and it must by used while in the regulated area.
Contact TMD today if your business needs additional information on how to protect your employees’s health. As well, if you have additional questions on how to comply with the OSHA rule, give us a call at (757) 494-1688. We are glad to help in any way we can!