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Explanation of the Standards
Silica
Silicon dioxide
Amorphous
Semiconductors
Used in electronics
Crystalline
Quartz
Found in masonry
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
Effects of Silica
Kidney disease
Immunological effects
Activation of latent tuberculosis
A Group 1 carcinogen: carcinogenic to humans
by IARC
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
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
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
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
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.
(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
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
GI and Construction
Both cover quartz, cristobalite and tridymite
The GI standard has a different limit for cristobalite and tridymite than for quartz
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
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
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
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
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
One more Definition
“Any Foreseeable Conditions”
Situations that can reasonably be anticipated
Malfunction or failure of engineering controls
Equipment fails sometimes
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
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
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
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
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
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
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
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
Construction: Specified Exposure
Control Methods
Whose responsibility is it to see that the controls have been fully and properly
implemented?
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.
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)
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?
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
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?
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.
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
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)
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.
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?
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
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.
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
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
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
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
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…
Water Delivery Systems
Flow rates
Nozzles
Additional work practices for cold temperatures
Insulating drums
Wrapping drums with gutter heat tape
Adding environmentally-friendly antifreeze
Commercially Available
No on-site improvisations of equipment by the employer
Not Listed on Table 1
Reciprocating cutting tools
Concrete chain saws
Wire saws
Abrasive blasting
Tunnel boring
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
Performance Option
Assess the 8 hour TWA
Can use any combination of air monitoring data or objective data
Must accurately characterize employee exposures
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
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
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
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
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
Methods of Compliance: The Hierarchy
of Controls
Methods of Compliance: Engineering
Controls
Elimination/Substitution
Isolation
Ventilation
Dust Suppression
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
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
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
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
Engineering Controls: Dust Suppression
Water
Inexpensive
Readily available
Disadvantages?
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?
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
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
Methods of Compliance: Personal
Protective Equipment The last line of defense
Respirators
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
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
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
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
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
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
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
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
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
Respiratory Protection
Employers following Table 1 must still comply with the provisions of the
Respiratory Protection Standard
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
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
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
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.)
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
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
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
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
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
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
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
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
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
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
Medical Examination: Periodic
Exam to be repeated every three years
Not the requirement for testing for latent
tuberculosis
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
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
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
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
General Industry
Formerly PEL was different for quartz, cristobalite and tridymite
Now, one PEL for all forms of silica
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
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
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
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
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
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
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
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