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Page 1: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Explanation of the Standards

Page 2: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Silica

Silicon dioxide

Amorphous

Semiconductors

Used in electronics

Crystalline

Quartz

Found in masonry

Page 3: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Effects of Silica

Toxicity depends on

Particle surface characteristics

Age of fractured surfaces of the crystal

Presence of impurities

Coating on the particle

Lung disease (silicosis)

Bronchitis

Emphysema

COPD

Page 4: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Effects of Silica

Kidney disease

Immunological effects

Activation of latent tuberculosis

A Group 1 carcinogen: carcinogenic to humans

by IARC

Page 5: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Exposures

Occupations

Mining

Manufacturing

Construction

Shipyard

Heavy equipment operation

Abrasive blasting

Processes

Sandblasting

Sand-casting in foundries

Mining

Tunneling

Cement cutting

Demolition

Masonry work

Granite cutting

grinding

Page 6: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

History

1980s: OSHA placed a special emphasis on prevention of silicosis in foundries

1996: OSHA implemented a Special Emphasis Program to reduce workplace

incidence

2008: OSHA implemented a National Emphasis Program to reduce or eliminate

health hazards

2016 Two new standards

Page 7: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Interim Period

Allowing employers to

Become familiar

Plan

Implement

Design

Install engineering controls

Work practice controls

Respiratory protection

General Industry: interim period ends 6/23/18

Page 8: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Interim Period

Compliance officers will

Review exposure monitoring records

Conduct monitoring to determine employee exposure

Continue to use the old formula: 10 mg/m3/ %SiO2 +2

Review other standards

PPE

Respiratory protection

Medical records

Hazcom

Page 9: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Dates

Beginning on June 23, 2018, employers must offer medical surveillance to

general industry and maritime employees who will be exposed above the PEL

of 50 µg/m³ for 30 or more days a year.

On June 23, 2020, this requirement expands to include employees who will be

exposed at/or above the 25 µg/m³ action level (AL) for 30 or more days a

year.

Additionally, employers of workers conducting hydraulic fracturing operations

in the oil and gas industry have an additional three years (until June 23, 2021)

to implement engineering controls to limit exposures to the new PEL.

Page 10: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

(a) Scope and Application

One standard covers General Industry and Maritime

One standard covers Construction

Standards apply to apply to occupational exposure in which

respirable crystalline silica is present in an occupationally

related context

Not to employees to ambient levels of silica unrelated to

occupational activities

Does not apply to sorptive clays

Page 11: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

General Industry and Maritime

In compliance if GI/Maritime follows the Construction standard

In compliance with ALL the provisions of the construction standard

And the task is indistinguishable from a construction task listed in Table 1 and

Usually during maintenance and repair activities

Involve an activity described in Table 1

Same nature and type as the construction tasks

The task will not be performed regularly in the same environment and

conditions

Not performed in a relatively stable and predictable environment

Page 12: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

GI and Construction

Both cover quartz, cristobalite and tridymite

The GI standard has a different limit for cristobalite and tridymite than for quartz

Page 13: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Definitions

Action Level: 25 ug as an 8 hr. TWA

Triggers requirements for periodic exposure monitoring

Periodic exposure measurements required when the AL is exceeded

Provides employers with additional assurance that employees are being protected

Where exposure measurements are above ½ the PEL, the employer cannot be reasonable confident the

employee is not exposed above the PEL on days when no measurements are taken

Benefits of

As exposures are lowered, risk of adverse health effects decreases

Economic benefit: avoid costs of periodic monitoring when exposures are below the action level

The action level will result in further reduction in risk beyond that provided by the PEL

Page 14: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Definitions

Competent Person

Designation of a CP is required in the Construction Standard

A person designated by the employer who is capable of

Identifying existing and predictable RCS hazards in surroundings

Has authorization to take prompt corrective measures to eliminate them

Written access control plan requires that a competent person identify areas where respirable crystalline silica exposures are, or can reasonably be expected to be in excess of the PEL

No particular training requirements. Must have

Knowledge and experience necessary to identify in advance tasks where exposures are reasonably expected to exceed the PEL

Employees notified of presence

Employer can take steps to limit access and provide respiratory protection

Page 15: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Definitions

Employee Exposure:

Exposure to employee that would occur if the employee were not using a respirator

High-efficiency particulate air (HEPA) filter

99.97 % efficient (0.3 micrometers)

Objective Data:

Information, such as air monitoring data from industry-wide surveys or calculations

Demonstrates employee exposure to rcs associated with a particular product, material,

process, operation or activity

Must reflect workplace conditions closely resembling the

Process, types of material, control methods, work practices and environmental conditions

“closely resembling” allows data reflecting past exposures to be used to predict current exposures,

not more protective

Page 16: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Definitions

Regulated Area:

An area, demarcated by the employer, where an employee’s exposure to airborne

concentrations of respirable crystalline silica exceeds or can be reasonably expected to

exceed, the PEL

Respirable Crystalline Silica (RCS)

Airborne particles that contain quartz, cristobalite and/or tridymite

Page 17: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Definitions

Physician or other licensed health care professional (PHLCP)

Licensed

Regulated Area

Demarcated by the employer

An area where concentrations exceed or may be expected to exceed the PEL

Page 18: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

One more Definition

“Any Foreseeable Conditions”

Situations that can reasonably be anticipated

Malfunction or failure of engineering controls

Equipment fails sometimes

Page 19: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Scope

Applies to all occupational exposures to RCS in construction work, except

where employee exposure will remain below 25 ug/m3 as an 8 hour TWA

under any foreseeable conditions

The standard does not apply where employee exposure will remain below 25

ug/m3 as an 8 hour TWA

Certain tasks can reasonably be anticipated to remain below 25 ug/m3.

Minimal exposure to RCS

Mixing concrete for post holes

Pouring concrete footers, slab foundation and foundation walls

Removing concrete formwork

Page 20: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Not Generally be Expected to Exceed 25

ug/m3

Occasional, brief exposures, incidental to their primary work

Carpenters, plumbers, electricians

Occasionally drill holes

Exposures would have to be very high for an 8 hour TWA to be above 25 ug/m3

Hole drillers using hand held drills, if the duration of exposure is 15 minutes

or less, the 8 hour TWA can reasonably be anticipated to remain under 25

ug/m3

Page 21: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Permissible Exposure Limit (PEL)

50 µ/𝑚3 as an 8 hour Time Weighted Average (TWA)

Current PELs based on levels of dust and percentage of silica in

the dust.

10 mg/𝑚3 divided by % silica +2

Construction PEL is obsolete, based on millions of particles per

cubic foot of air (mppcf)

Have to convert to mg/𝑚3.

If a sample were pure silica(100%), the equivalent PEL would be 250

µ/𝑚3

New PEL addresses the airborne particles that reach the gas-

exchange region of the lung

Page 22: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

PEL

The PEL is still significantly high enough to cause disease

It is the lowest OSHA feels is technologically feasible

50 µ/𝑚3 can be measured with a good degree of accuracy

Employers must use hierarchy of controls: engineering controls and work

practice controls to reduce the levels as much as possible

Many industries won’t be able to achieve 25 µ/𝑚3 with engineering controls

and work practices alone

Page 23: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Exposure Assessment: Construction

If the employer fully implements engineering controls, work practices

and respiratory protection in Table 1, no exposure assessment is

required.

Does not have to comply with the PEL

Indoor work, must provide a means of exhaust as needed to minimize

the accumulation of dust

Using wet methods, use correct flow rates

Page 24: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods For employees engaged in a task identified

on Table 1

Employer fully and properly implement

Engineering controls

Work practices

Respiratory protection for the task on Table 1

or

Assess and limit the exposure of the

employee to RCS

Equipment/Task Engineering and Work Practice

Control Methods

Respirator

Requirements and Minimum Assigned Protection

Factor (APF) for 4 Hours or Less

Respirator

Requirements and Minimum Assigned Protection Factor

(APF) for More Than 4 Hours

Stationary masonry

saws

Use saw equipped with integrated

water delivery system that continuously feeds water to the blade.

Operate and maintain tool in

accordance with manufacturer’s instructions to minimize dust emissions.

(None required)

(None required)

Handheld power saws (any blade diameter)

Use saw equipped with integrated water delivery system that

continuously feeds water to the

blade.

Operate and maintain tool in accordance with manufacturer’s

instructions to minimize dust emissions:

- When used outdoors

(None required)

(APF 10 required)

When used indoors or in an enclosed area

(APF 10 required)

(APF 10 required)

Handheld power saws for

cutting fiber-cement board

(with blade diameter of 8

inches or less)

For tasks performed outdoors only:

Use saw equipped with

commercially available dust collection system.

Operate and maintain tool in

accordance with manufacturer’s instructions to minimize dust emissions.

Dust collector must provide the

airflow recommended by the tool

manufacturer, or greater, and have a filter with 99% or greater efficiency.

(None required)

(None required)

Silica In Construction: 1926.1153

Table 1

Page 25: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods

“Fully and Properly Implement”?

Indicators of controls that are fully and properly implemented:

Dry dust collection system

Shroud or cowling installed and intact

No kinks or bends in the hose

Visible dust not being emitted

Filters

Dustbags

Water-based dust suppression system?

Employees understand how to use the controls

Page 26: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods

OSHA’s goal was to provide a set of effective, easy to understand and readily

implemented controls

The tasks are the performed with common equipment

Responsible for most of the exposures to RCS

Characterizing exposures in construction

Simplified compliance

Creates a greater awareness of the appropriate controls

Page 27: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods

Whose responsibility is it to see that the controls have been fully and properly

implemented?

Page 28: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods

Employees “Engaged” in a task. Which employees?

Operator?

Laborers?

Others working close-by?

Include in the Exposure Control Plan

Potential exposures to other people

Example: an employee directing traffic around another who is jack

hammering, more than 4 hours per day.

Page 29: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods No table entries for tunnel operations

No table entry for abrasive blasting

If the task is not on the list, comply with paragraph

(d)

Page 30: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods

Water delivery and dust collection systems

Must be commercially available dust collection systems

Eliminates do-it-yourself onsite improvisation

Must be integrated with the tool (made with/for the tool)

What if you find a solution that works better than the controls listed in Table

1?

Page 31: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods Filtering systems

HEPA filters are not required

99% will capture most particles in the respirable range

“Means of Exhaust” for tasks performed indoors

Minimize dust accumulations

Maybe use dilution ventilation to increase air movement

Use water at sufficient flow rates

OSHA doesn’t specify

Check manufacturer’s recommendation

Page 32: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified

Exposure Control Methods

Enclosed cab or booth requirements

Free from settled dust

Wipe surfaces

Doors sealed and closing mechanisms that work

properly

Gaskets and seals in good condition

Well sealed around windows, joints in walls, floors

Be under positive pressure

Intake air that is filtered through 95% filter

Why is it important to have air conditioning and

heating?

Page 33: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Construction: Specified Exposure

Control Methods Respiratory protection is limited to situations in which OSHA

has determined the exposure will likely be greater than 50

ug/m3

Most tasks are performed outdoors. Exposures are less

outdoors.

Page 34: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Table 1: “Less than or Greater than 4

hours” Time starts when the operator begins using the tool

Continues until the task is completed

Includes breaks

Includes clean up time

Page 35: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Table 1: “Less than or Greater than 4

hours” Unforeseen circumstances

Example:

Employer makes a good-faith judgment a job

will take less than 4 hours

Problem arises, and job will now take more

than 4 hours

As soon as it becomes evident the job will

exceed 4 hours, employer must provide

respiratory protection (not wait until 4 hours

are up, then give respirator)

Page 36: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Table 1

If employee performs more than one task on Table 1 and total duration

of all tasks is > 4 hours, the required protection for each task is the

respiratory protection specified for more than four hours per shift.

If the total duration of all tasks on Table 1 combined is less than 4

hours, the respiratory protection for each task is the respiratory

protection specified for less than four hours per shift.

Page 37: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Example 1

Operating a handheld power saw for 6 hours

indoors. No other operation listed in Table 1 for

the rest of the day.

Respirator required?

Indoors?

Page 38: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Example 2

Using a hand held power saw, outdoors, for 3 hours.

No respiratory protection required

Using a hand held power saw, outdoors for 4 ½ hours?

Use respirator with APF 10 protection factor

Page 39: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Example 3

Using hand held grinder outside for 3 hours, and a chipping hammer for

two hours

Respirator with APF 10 not needed for the grinding work

Respirator with APF 10 need for the chipping hammer work

Additionally, for workers who engage in two or more discrete operations

from Table 1 for a total of more than four hours during a single work shift,

employers that rely on Table 1 must provide, for the entire duration of each

operation performed,

the respirator specified in the “>4 hrs/day” column for that operation, even

if the duration of that operation is less than four hours.

If no respirator is specified for an operation in the “>4 hrs/day” column,

then respirator use would not be required for that part of a worker's shift.

Page 40: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Specified Control Methods

Stationary masonry saws

Integrated water delivery system

Continuously feeds water to the blade

Operate and maintain in accordance with manufacturer’s instructions to minimize dust emissions

Full and proper implementation of water controls:

Adequate supply

Spray nozzle is working properly

Nozzle not clogged or damaged

Hoses intact

Page 41: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Specified Control Methods

Handheld power saws (any blade diameter)

Equipped with an integrated water delivery system

Commercially developed specifically for the type of tool

in use

Continuously feeds water

Maintain in accordance with manufacturer’s instructions

Flow rates

Table 1 doesn’t specify a minimum flow rate

Apply at the flow rate specified by the manufacturer

Page 42: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Additional Ventilation

When using tools indoors or in enclosed spaces

Dust concentrations can build up

Provide additional exhaust as needed to minimize the accumulation of visible airborne dust

Indoors or enclosed areas

A work area with only a roof that doesn’t affect the dispersal of dust: not enclosed

An open top structure with three walls and limited air movement or a roof that limits dispersal would be considered enclosed

Provide

Portable fans

Ventilation systems

Systems that increase air movement and assist in the removal of dust

Page 43: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Specified Control Methods

Handheld power saws for cutting fiber-cement board

(blade diameter 8” or less)

Must have a commercially available dust collection

system

Filter with 99% or greater efficiency

Operate and maintain in accordance with the

manufacturer’s instructions

Air flow rate recommended by the manufacturer

These saws must only be used outdoors

Page 44: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Specified Control Methods

Requirements for

Walk behind saws

Drivable saws

Rig-mounted core saws or drills

Handheld and stand-mounted drills (including impact

and rotary hammer drills)

Dowel drilling rigs for concrete

Vehicle mounted drilling rigs for rock and concrete

Jackhammers and handheld powered chipping tools

Handheld grinders for mortar removal (tuckpointing)

More…

Page 45: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Water Delivery Systems

Flow rates

Nozzles

Additional work practices for cold temperatures

Insulating drums

Wrapping drums with gutter heat tape

Adding environmentally-friendly antifreeze

Page 46: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Commercially Available

No on-site improvisations of equipment by the employer

Page 47: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Not Listed on Table 1

Reciprocating cutting tools

Concrete chain saws

Wire saws

Abrasive blasting

Tunnel boring

Page 48: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Alternative Exposure Control Methods:

(Construction)

Alternative Exposure Control Methods. Use them when

Task is not listed in Table 1, or

The employer does not fully implement the engineering controls, work practices

and respiratory protection in Table 1

Have to ensure employees are not exposed in excess of the PEL

Assess the exposure by using

Performance option or

Scheduled monitoring option

Page 49: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Performance Option

Assess the 8 hour TWA

Can use any combination of air monitoring data or objective data

Must accurately characterize employee exposures

Page 50: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Scheduled Monitoring Option

Perform initial monitoring

Breathing zone air samples

Must reflect exposures on each shift, for each job classification,

in each work area

If employees do same task, may take a representative fraction

Sample worst case exposure

Page 51: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Scheduled Monitoring Option

Results:

If below action level (25 ug/m3, discontinue monitoring)

If between action level and below permissible exposure level, repeat

within six months

If results are above the PEL, repeat within three months of the most

recent

When recent results are below action level, repeat within six months

until two consecutive measurements (taken 7 or more days apart)

are below the action level, discontinue monitoring

Page 52: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Reassessment of Exposures

When there is a change in:

Production

Process

Control equipment

Personnel

Work practices….

That may reasonably be expected to result in exposures above the AL

If the change is likely to reduce the exposure, no reassessment is needed

Page 53: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Notification of Assessment Results

Within 5 working days after completing an exposure

assessment

In writing or

Post the results

If results are above the PEL,

Describe corrective actions being taken

Employees or designated representatives may observe the

monitoring

If employees enter into an area where the use of protective

clothing is required

Provide protective clothing and equipment

Page 54: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Methods of Compliance

Engineering and work practice controls will be the

primary means to reduce exposure to the PEL or to

the lowest feasible level above the PEL

Supplement the controls with respiratory protection

Page 55: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Methods of Compliance: The Hierarchy

of Controls

Page 56: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Methods of Compliance: Engineering

Controls

Elimination/Substitution

Isolation

Ventilation

Dust Suppression

Page 57: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Engineering Controls:

Elimination/Substitution

Elimination: change process so task that creates silica dust is not necessary

Substitution: the replacement of a toxic material with another material that reduces or eliminates the harmful exposure

Auto-body work: silica free body fillers

Abrasive blasting

High pressure water-jetting techniques (elimination)

Coal and copper slag

Steel grit, Nickel slag, Baking soda

Evaluate the toxicity of the replacement

Evaluate alternatives

Many are not feasible or safer

Different health risks

5(a)1

Page 58: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Engineering Controls

Isolation:

Separate the worker from the source of the

contaminant

A physical barrier surrounding the source

Contains the toxic substance

Protective of workers who are in the vicinity

Enclosed cabs in heavy equipment

Page 59: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Engineering Controls: Ventilation

Dilution Ventilation: circulates the contaminant but dilutes

it with a large quantity of air

Local Exhaust Ventilation

Captures the contaminant at the source before it spreads

LEV can be adapted to fit tools

Tool mounted shrouds

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Engineering Controls: Dust Suppression

Used in

Grinding operations

Cutting operations

Abrasive blasting

Operating heavy equipment

Three types:

Wet dust suppression

A liquid or foam is applied to the surface of the dust-generating material

Airborne capture

Water dispensed in a dust clout, dust drops out

Stabilization

Holds down particles by chemical means

Calcium chloride, magnesium chloride

Page 63: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Engineering Controls: Dust Suppression

Water

Inexpensive

Readily available

Disadvantages?

Page 64: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Engineering Controls

Engineering Controls

Control contaminant at the source

Reliable, predictable, offer a consistent level of protection

Can be monitored continually

Not susceptible to human error

Don’t have to rely on the actions of individual employees

Protects others and the public (nearby laborers)

Have to decrease levels of silica as much as you can…even if you don’t reach

the PEL…why could this be an advantage?

Page 65: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Methods of Compliance: Work Practice

Controls

Modify how the workers perform their jobs

Adjusts the way the work is performed

Stand away from the dust cloud

Always use dust suppressant when sweeping

Usually includes the use of engineering controls

Use saw with water reservoir

Enhances and compliments the effectiveness of engineering controls

Expectation to use the local exhaust ventilation

Page 66: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Methods of Compliance: Administrative

Controls

Less effective because they need to be managed

Job rotation

Restricting time of exposure

Doing job when few people are in the area

Stand upwind

Page 67: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Methods of Compliance: Personal

Protective Equipment The last line of defense

Respirators

Page 68: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Advantages of Engineering and Work

Practice Controls

Easier to monitor and maintain

Engineering controls limit exposure to RCS at its source

Protects nearby workers, and the public

Can eliminate the hazard from the whole site, not just the worker wearing

the respirator

Reliable, predictable, consistent levels of protection

Not susceptible to human error as PPE

Doesn’t rely on the actions of individual employees

Page 69: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Respiratory Protection

OSHA’s Respiratory Protection Standard Applies

Respirators required when exposures exceed the PEL while

Installing engineering and work practice controls

During tasks where engineering and wp controls are not feasible

Engineering and wp controls have been implemented, but not enough

When in a regulated area

Page 70: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Respirators

Why the last line of defense?

Rely on the individual to use it properly

Must be individually selected

Must be fitted, refitted

Employee must be medically cleared

Must be worn properly

Must have regular maintenance

Must be replaced when necessary

Page 71: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Respirators

Burdens

The weight of the respirator

Breathing resistance

Auditory, olfactory impaired

Level of work affects body response: heat, high humidity

Increased heart rate puts additional burden on those with underlying disease

Vision impairment

Communication impairment: annoyance, fatiguing

Movement of the jaw can cause leakage

Skin irritation

Isolation from others and the work

Claustrophobia

Page 72: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Respirators

Use engineering and work practice controls to decrease the level of exposures

Then a lighter respirator with a decreased APF can be worn

You will have a wider range of options as exposures decrease

The requirement to use Table 1 is tied to expected or recorded exposures.

The PEL is expected to be exceeded.

Financial burdens to small businesses:

Maintaining a comprehensive respiratory protection program is burdensome

If any of the elements are missing, the respirators won’t be effective anyway

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Respiratory Protection

There is no requirement that employers must provide respirators to

employees on request

Not prohibited

Respirators are not allowed as an alternative to engineering and work

practice controls

Some maintenance and repair activities, some engineering and work practice

controls are not feasible

then respiratory protection is required

Page 74: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Respiratory Protection Program

Program must include

Procedures for selecting

Medical evaluation

Fit testing for tight fitting respirators

Procedures for proper use

Schedules for respirator maintenance

Quality breathing air

Training in hazards

Training in proper use

Procedures for evaluating the effectiveness of the program

Page 75: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Respiratory Protection

If using Table 1, employers are considered to be in compliance .134

Employers must allow employees to select from a sufficient number of

respirator models and sizes

Under fit testing protocols require that an employee has an opportunity to

reject respirator facepieces that the employee considers unacceptable

Page 76: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Employee Rotation

Employee rotation not generally accepted to avoid implementation of

engineering controls or administrative controls

May be reasonable to rotate employees to avoid exceeding the four-hour

threshold that would trigger a requirement for respirator use

Not to be used to achieve compliance with the PEL

May be acceptable to limit the need for respiratory protection

May allow employees to continue to work

If unable to pass medical evaluation but can otherwise do the work

Page 77: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Respiratory Protection

Employers following Table 1 must still comply with the provisions of the

Respiratory Protection Standard

Page 78: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Housekeeping

No dry sweeping or dry brushing

Where it can contribute to employee exposure

Use wet sweeping or HEPA filtered vacuuming or other means

No cleaning clothing or surfaces

Where it could contribute to employee exposure

Ok if used with a ventilation system that captures the dust

Ok if no alternative method is feasible

When wet methods and/or HEPA vacuuming creates additional

hazards

Page 79: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Housekeeping

Employer has the burden of showing that wet methods are not

feasible in a particular situation

OSHA does not require employers to clean up dust

But it limits employee exposures

Provide for clean up in the exposure control plan

Page 80: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Written Exposure Plan

Construction: Review Annually

Evaluate effectiveness

Designate a Competent Person to

Make inspections of job sites, materials and equipment to implement the plan

Page 81: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Written Exposure Control Plan

Required for both GI and Construction

Will improve employee protections

Written exposure control plans

A tool for

Ensuring performance of maintenance checks

Maintaining Table 1 conditions

Identifying operations that will result in exposures

Identifying specific control measures

Procedures for determining if controls are being properly used and maintained

Communicating protections to employees

Communicating to others (other trades, etc.)

Page 82: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Written Exposure Control Plan

Not just for exposures above or reasonable expected to be above the PEL

Not limited to scenarios where the PEL is exceeded

A written plan for each job or worksite?

If same tasks using the same equipment and materials at various worksites, then no.

If using Table 1: types of equipment used, types of protections standardized

Plan must address all materials, tasks and conditions that are relevant to the work performed

ECP does not have to be limited by materials, tasks and conditions for a particular job site and can include all materials, tasks and conditions typically encountered

Won’t have to modify the plan just because the location has changed

Page 83: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Written Exposure Control Plan Elements

Tasks that involve exposure to RCS

Description of:

Engineering controls

How to verify controls are working

Settings, flow rates, proper usage

Work practices

How to clean clothing

Respiratory protection used to limit exposure for each task

Housekeeping measures used to limit exposure

Cleaning methods to be used

Page 84: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Written Exposure Control Plan Elements

Respiratory protection used to limit exposure for each task

Housekeeping measures used to limit exposure

Cleaning methods

How to restrict access to work areas (administrative controls)

Minimize number of employees and others exposed

How?

Stay out of the area

Safe distance

Stay away from dust clouds

Perform work when others are away

GI and Maritime require “Regulated Areas”

Demarcated

Warning signs at entrance

Page 85: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Written Exposure Control Plan

Communicating hazards is part of the HCS

Providing respirators to designated person covered by

the respiratory protection plan

Make the plan readily available

Useful way to communicate protections to employees

Page 86: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Competent Person: Construction

Standard Only

Duties

Evaluates workplace exposures and effectiveness

Has authorization to take prompt corrective measures to eliminate or

minimize them

Has knowledge and ability necessary to identify existing and foreseeable RCS

hazards

Makes frequent and regular inspections of

Job sites

Materials and equipment

Implements the exposure control plan

Employer designates the CP

Page 87: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Competent Person

Designate the CP, inform workers of his/her identity

Must be trained to identify and correct RCS hazards

Is authorized to take immediate corrective actions

Observes conditions indicating controls are not functioning

Makes frequent and regular inspections of the worksite

Implements the ECP

Page 88: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Medical Surveillance

GI: if employees are exposed or are reasonably expected to be exposed to

levels of silica at or above the action level for 30 or more days per year.

Construction: if employees wear or are reasonably expected to wear a

respirator for 30 or more days per year.

Performed by a PLHCP

Page 89: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Medical Surveillance

Purpose

Early detection of disease related to RCS

To let employees know they have a condition

Enables employees to make informed decisions about their work and medical care

Assess fitness to wear a respirator

Page 90: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Medical Examination: Initial

Within 30 days after initial assignment

Unless a medical examination has been received

within the last three years

Requirements

Medical and work history

Past, present and anticipated exposure

History of respiratory system dysfunction

Signs, symptoms of respiratory disease

Shortness of breath, cough, wheezing

History of tuberculosis

Smoking status

Page 91: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Medical Examination: Initial

Chest X-ray

Pulmonary Function Test

Forced vital capacity (FVC) and forced

expiratory volume (FEV1) and FEV/FVC

ration

Test for tuberculosis

Other tests

Every 3 years

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Medical Examination: Periodic

Exam to be repeated every three years

Not the requirement for testing for latent

tuberculosis

Page 93: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Information for the PLHCP

Provide the PLHCP with

A copy of the standard

A description of employee’s former, current and anticipated duties (as pertains to

RCS)

The employee’s former, current and anticipated levels of occupational exposure to

RCS

Description of PPE used or to be used by the employee

How long, when used

Information from medical exams, if available

Page 94: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

PLHCP Report for the Employee

PLHCP to explain the results of the medical exam

Give the employee a written medical report within 30

days

Report to include

Results of the exam

Medical conditions placing the employee at increased risk

from exposure to RCS

Recommended limitations on the employee’s use of

respirators

If X ray is classified as 1/0 or higher, a statement the

employee should see a specialist

Or if PLHCP deems appropriate

Page 95: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

PLHCP Medical Opinion for the Employer

Within 30 days of the examination.

Include

Date

Statement the exam has met the requirements

Recommended limitations on the employee’s use of respirators

If the employee authorizes in writing

Recommended limitations on the employee’s exposure to RCS

Statement the employee should be examined by a specialist

Employer to ensure employee receives a copy within 30 days of the exam

Page 96: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Medical

Additional examinations

If PlHCP determines the employee should be examined by a specialist, the

employer shall make the examination available within 30 days after receiving the

opinion

Give same information to the specialist

Specialist must explain results to the employee and provide employee with a

written report

Employer must obtain a written opinion from the specialist within 30 days of the

exam

Page 97: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

General Industry

Formerly PEL was different for quartz, cristobalite and tridymite

Now, one PEL for all forms of silica

Page 98: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Communication of RCS Hazards to

Employees

Include RCS into the hazard communication (HCS) standard requirements

Access to SDS, labels

Trained in hazards of exposure to RCS

Ensure these hazards are addressed:

Cancer

Lung effects

Immune system effects

Kidney effects

Page 99: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Communication of RCS Hazards to

Employees

Include RCS into the hazard communication (HCS) standard requirements

Access to SDS, labels

Trained in hazards of exposure to RCS

Demonstrate knowledge and understanding of

Health hazards

Specific tasks that could result in exposure

Measures employer has implemented for employee protection

Contents of the standard

Purpose and a description of the medical surveillance program

Make the standard readily available to the employee

Page 100: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Communication of RCS Hazards

Specific tasks in the workplace that could result in exposure to RCS

Specific measures the employer has implemented to protect employees from

exposure

Engineering controls

Work practices

Respiratory protection to be used

This standard

Identity of the Competent person

Purpose and description of the medical surveillance program

Make this standard readily available

Page 101: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Recordkeeping

Air Monitoring Data

Exposure measurements to assess employee exposure to RCS

Name, SSN, job classification of employees represented by the monitoring

Objective data

All objective data relied upon to comply with requirements

Include

Crystalline silica-containing material

Source of the data

Testing protocol and results of testing

Description of the process, task, activity

Medical Surveillance requirements

Page 102: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Regulated Areas: GI

Establish when levels expected to be >PEL

Demarcate from the rest of the workplace

To minimize the number of employees exposed

Post signs at all entrances

Limit access to regulated areas

Persons authorized

Observers

OSHA reps

Provide respirators to employees and designated representatives

Page 103: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Regulated Areas: General Industry

Whenever an employee’s exposure to airborne concentrations of RCS is or can reasonably be expected to be, in excess of the PEL

Demarcation

Minimize the number of employees exposed

Post signs

Limit access

Only authorized persons

A designated representative of the employee (observe monitoring)

Provide respirators

Authorized person (worker)

Designated representative of the employee

Page 104: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Regulated Area Signage: GI

Signs at entrances to regulated areas:

Danger

Respirable Crystalline Silica

May Cause Cancer

Causes Damage to Lungs

Wear Respiratory Protection in This Area

Authorized Personnel Only

Page 105: Explanation of the Standards - MWUAmwua.org/.../03/Session-25-Explanation...standards.pdf · Dates Beginning on June 23, 2018, employers must offer medical surveillance to general

Exposure Assessment: General Industry

GI: the employer shall assess the exposure of each employee who is or may

reasonably be expected to be exposed to RCS at or above the action level.

How? Use either

Performance option

Use air monitoring data or objective data or both to characterize employee exposures

Scheduled monitoring option

Perform initial monitoring to find 8 hour TWA

Use results to determine schedule

Reassess as necessary

Notify employees

If above PEL, include corrective actions taken