Session 28 - Silica the Next Steps - WMC

3/26/2017

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Environmen

tal

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WSC Safety & Health Conference

April 11, 2017

Brian J. Harms, P.E.(WI), CIH

Session #28

Silica – The Next Steps

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At the end of this session, you should be able to:

Have an understanding of OSHA’s new Silica Rule

Understand the next steps for your facility

Have some tools utilizing real‐time instruments for performing root cause analysis of the exposure sources

Course Objectives

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1. Review and Understand the New Silica Rule

2. Conduct Initial Ventilation Assessment and Monitoring

3. Document Initial Monitoring Results in Your Silica Exposure Control Plan

4. Target Problem Areas For Root Cause Analysis

5. Document Results of the Root Cause Analysis and Identify Action Items

6. Fix the “Low Hanging Fruit” – Engineering Controls/Work Practices

7. Document Those Fixes in Your Silica Exposure Control Plan

8. Re‐Monitor and Document Results

9. ($$) For Areas Still Above the New PEL: Outline Requirements (i.e. Medical Evaluations, PPE, Monitoring Schedules, Notifications, etc.)

10. ($$$)Prepare an Engineering Study for Processes Still Above the New PEL and Document an Approach in your Silica Exposure Control Plan

Complying With the New Silica Rule

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Background

From OSHA….

“Respirable crystalline* silica – very small particles at least 100 times smaller than ordinary sand you might encounter on beaches and playgrounds – is created during work operations involving stone, rock, concrete, brick, block, mortar, and industrial sand. Exposures to respirable crystalline silica can occur when cutting, sawing, grinding, drilling, and crushing these materials.”

*Note: Amorphous or fused silica is not part of this standard

Photo courtesy of AFS Silica Control Manual

Photo courtesy of OSHA.gov

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Background

DIRECTIVE NUMBER: CPL 03‐00‐007 EFFECTIVE DATE: 1/23/08

Silica can be crystalline or amorphous. Crystalline silica is significantly more hazardous to employees than amorphous silica. In addition to causing the disabling and irreversible lung disease silicosis , crystalline silica has been classified as a Group I carcinogen ‐ Carcinogenic to Humans by the International Agency for Research on Cancer (IARC ) [IARC, 1997]. The term "silica" as it is used in this directive refers specifically to crystalline silica. Crystalline silica is an important industrial material, and occupational exposure occurs in a variety of workplace settings, including mining, manufacturing, construction, maritime, and agriculture. Processes associated historically with high rates

of silicosis include sandblasting, sand‐casting foundry operations, mining, tunneling, cement cutting and demolition, masonry work, and granite cutting.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=3790

Photo courtesy of sessler.cm.utexas.edu

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Background

August 2013: Proposed Rule Released

March 2014: Public Hearings Begin on Silica Proposal

December 2015: Rule Sent for Final Review

March 25, 2016: Final Rule Published in Federal Register

June 23, 2016: Rule Becomes Effective (Starts the Clock)

June 23, 2017: Requirements Effective for Construction

June 23, 2018: Requirements Effective for General Industry (Including Engineering Controls)

June 23, 2018: Medical surveillance required for employees above the PEL for 30 or more days

June 23, 2020: Medical surveillance required for employee above the Action Level for 30 or more days

June 23, 2021: Engineering controls to be in place (Applies to Fracking Industry Only)

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Existing OSHA PEL until June 23, 2018 (1910.1000 Table Z‐3)

Resp. PM PEL = 10 / (% Quartz + 2) [MSHA still to use this]

Cut in half for Cristobalite and Tridymite

– Example Results: 0.80 mg/m3 respirable PM; 18% Quartzor 0.14 mg/m3 of Quartz

– PEL Calculation = Resp. PM PEL = 10 / (18 + 2) = 0.5 mg/m3

– Result of 0.80 mg/m3 is greater than 0.5 mg/m3 and is over the existing PEL for Respirable PM containing silica.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9994

Understanding the Silica Rule

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New Rule 29 CFR 1910.1053 Industry


New Rule 29 CFR 1926.1153 Construction


Removes formula, new PEL would be 0.050 mg/m3; action level would be 0.025 mg/m3 as Silica, not Respirable PM

Understanding the Silica Rule

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Small Entity Guide for Compliance with the Respirable Crystalline Silica Standard – Construction

https://www.osha.gov/Publications/OSHA3902.pdf

An employer has two options for limiting employee exposure to respirable crystalline silica:

Specified exposure control methods; or

Alternative exposure control methods.

Construction Specific

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Specified Approach

Employers who choose the specified exposure controls option must fully and properly implement protections for the tasks or equipment listed in Table 1 of the standard. Employers who fully and properly implement the controls in Table 1 do not have to assess employees’ silica exposure levels or keep employee exposures at or below the permissible exposure limit (PEL). However, still need to do the other provisions such as housekeeping, medical surveillance, training, and written exposure control plans.

Alternative Approach

Employers who follow alternative exposure control methods must conduct initial monitoring and employ alternative engineering controls or work practices as well as housekeeping, medical surveillance, training, and written exposure control plans.

Construction Specific

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Construction Table 1

(i) Stationary masonry saws

(ii) Handheld power saws (any blade diameter)

(iii) Handheld power saws for cutting fiber-cement board (withblade diameter of 8 inches or less)

(iv) Walk-behind saws

(v) Drivable saws

(vi) Rig-mounted core saws or drills

(viii) Dowel drilling rigs for concrete

(ix) Vehicle-mounted drilling rigs for rock and concrete

(x) Jackhammers and handheld powered chipping tools

(xi) Handheld grinders for mortar removal (i.e., tuckpointing)

(xii) Handheld grinders for uses other than mortar removal

Photo courtesy of www.lhsfna.org

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Construction Table 1 (Continued)

(xiii) Small drivable milling machines

(xiv) Walk‐behind milling machines and floor grinders

(xv) Large drivable milling machines

(half‐lane and larger)

(xvi) Crushing machines

(xvii) Heavy equipment and utility vehicles used to

abrade or fracture silica‐containing materials

(e.g., hoe‐ramming, rock ripping) or used

during demolition activities involving

silica‐containing materials

(xviii) Heavy equipment and utility vehicles for tasks such as grading

and excavating but not including:

Demolishing, abrading,

or fracturing silica‐containing materials.

Photo courtesy of iqpowertools.com

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Initial Monitoring


Review Ventilation & Existing Conditions (Is everything working?)

Full Shift Sampling Root Cause Analysis

Engineering and/or Work Practice Controls

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Initial exposure assessment either through Air Monitoring or anew Performance Option

– Identify activities that have potential silica exposure (Crystalline Silica – Quartz, Cristobalite, Tridymite) Amorphous Silica is notpart of this rule.

– Conduct 8‐hour employee exposure sampling to determine if any positions are above the new PEL or Action Level

– Performance Option – Can be tricky, can look at historical data and process configurations to make assessment. OSHA may sample anyway.

Conduct Initial Monitoring

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Amorphous Silica Not Part of the Rule, however for those that use Ceramics such as Lost Foam or Lost Wax or Refractories with Amorphous Silica please be aware of possible transformation to cristobalite:

“The formation of cristobalite at 900 0C from amorphous silicic acid and silica gel adds credence to this proposal. The absence of tridymite when the different SiO2 materials are heated is noteworthy. More than forty different heating trials were made during the course of our study and not once was any indication of the presence or formation of any tridymite observed. . . . The absence of the tridymite “phase” is not unusual in studies of the one component SiO2 system; in fact, this modification has never been synthesized in the laboratory without the use of “mineralizers” which introduce foreign ions into the system and thereby result in “complex stuffed” derivatives.” The American Mineralogist, Vol. 46, January‐

February, 1961 – Phase Transformations in Silica as Examined by Continuous X‐Ray Diffraction. F.M. Wahl, R.E. Grim, and R.B. Graf, University of Illinois, Urbana, Illinois

Amorphous Silica Note

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1968 ACGIH Criteria cut point of ~3.5 µm

New ISO/CEN Definition cut point of ~4.0 µm

“particle size collection criteria are also often described by their 50‐percent respirable ‘‘cut size’’ or ‘‘cut point.’’ This is the aerodynamic diameter at which 50 percent of the particle mass is collected, i.e., the particle size that the sampler can collect with 50‐percent efficiency. Particles with a diameter smaller than the 50‐percent cut point are collected with an efficiency greater than 50 percent, while larger‐diameter particles are collected with an efficiency less than 50 percent. The cut point for the 1968 ACGIH specification is 3.5 µm and for the ISO/CEN convention is 4.0 µm”

pg. 16438 Federal Register / Vol. 81, No. 58 / Friday, March 25, 2016 / Rules and Regulations

Notes on Sampling

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Existing rule (and OSHA) typically use Dorr‐Oliver nylon cyclones, new rule opens it up for other cyclone usage as well.

SKC Cyclone ~4 um cut point at 2.5 LPM

Dorr Oliver Cyclone ~3.5 um cut point at 1.7 LPM

Cyclone Sampling Discussion

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If positions are found to be below the Action Level,those positions drop out of the standard.

1910.1053(a)(2) Respirable Crystalline Silica

“This section does not apply where the employer has objective data demonstrating that employee exposure to respirable crystalline silica will remain below 25 micrograms per cubic meter of air (25 μg/m3) as an 8‐hour time‐weighted average (TWA) under any foreseeable conditions.”

Document These Results in Your Silica Control Plan

Initial Monitoring Rule Applicability

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1910.1053(d)(6) Employee Notification of Assessment Results

– 1910.1053(d)(6)(i) Within 15 working days after completing an exposure assessment in accordance with paragraph (d) of this section, the employer shall individually notify each affected employee in writing of the results of that assessment or post the results in an appropriate location accessible to all affected employees.

– 1910.1053(d)(6)(ii) Whenever an exposure assessment indicates that employee exposure is above the PEL, the employer shall describe in the written notification the corrective action being taken to reduce employee exposure to or below the PEL.

Employee Notification of Monitoring Results

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Now We Know What Areas to Target


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Define your exposures [Know the Source]

– Compliance Monitoring

– Real‐Time Task Assessment

Minimize Regulated Areas

– Map areas

Define Feasible Engineering Controls

– Get in front of this, the ACGIH Ventilation Manual is a valuable resource

AFS Study Grant to Publish Methods

Root Cause Exposure Analysis


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Case Studies Using Real‐Time Instruments

– Case Study #1: Mapping

– Case Study #2: Work Practices

– Case Study #3: Recirculation Issue

Root Cause Exposure Analysis

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Case Study #1 ‐ Mapping

Total Particulate Matter (mg/m3)

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More Information Needed Before Moving Forward –Employees in Blast Booth Area Exceeding OSHA PEL

– Original Theories Is the background air causing exceedance?

What is the impact of material on the castings?

Shot leaking from areas of blast booth, is that causing the exceedance?

– Real‐Time Method Used DataRAM synchronized with video tape.

Case Study #2 – Work Practices

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Conclusions

– Background concentrations low.

– Blast booth shot leak negligible affects.

– Material on castings main source.

– Approximately 90% of shift activities within acceptable limits. Remaining shift cleanup activities (i.e., sweeping, shoveling, etc.) high enough to cause overexposures.

– Video useful in illustrating cause and effect to management decision makers.


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Case Study #3 – Recirculation Issue

ShakeoutOsborne Mold-

Making WheelabratorSand Muller

8/16/2006

11/16/2006

12/18/2007

0.000

0.010

0.020

0.030

0.040

0.050

0.060

0.070

0.080

0.090

Res

pir

able

Qu

artz

(m

g/m

3 )

Employee Location

Date

Figure 3

Historical Silica as Quartz Results Comparison (mg/m3)

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Conclusions

– pDR‐1200 illustrated lack of general ventilation.

– pDR‐1200 graph also illustrated similar dust levels during shakeout and melting. Why? Led to bar graph.

– Bar graph of historical results indicated better capture at shakeout, however recirculation back inside providing mixing and silica exposure to other employees. Implicating the baghouse.

– Baghouse was opened up and found to be plugged. Guilty.

Case Study #3 – Recirculation Issue

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1910.1053(f)(2) [Make this tell your story]

Employers Must Implement a Written Exposure Control Plan and Review Annually for all tasks that involve potential exposure to crystalline silica. Plans require:

– (i) A description of the tasks in the workplace that involve exposure to respirable crystalline silica;

– (ii) a description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task; [Use Your Root Cause Analysis Discussion]

– (iii) a description of the housekeeping measures used to limit employee exposure to respirable crystalline silica;

– (iv) for construction, a description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed to respirable crystalline silica and their level of exposure, including exposures generated by other employers or sole proprietors.

Written Silica Exposure Control Plans

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Make the Written Exposure Plan Work for You ‐ Similar Issue When Hex Chrome Became a Standard.

Hex Chrome Story Time

Photo courtesy of Galson Labs

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Fix the Low Hanging Fruit

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Respirab

le Particulate M

atter (m

g/m3)

Time

Chart 11End of Shift Sweeping Powders Room ‐ No Sweeping Compound

March 8, 2017

Broom Sweeping

Sweeper /Vacuum Truck Enters the Area toCollect Swept up Piles

Employee Leaves Area and Takes Samples to the LabReturns to the Area Sweeper Truck StillRunning

MAX: 7.01 mg/m3AVG: 1.55 mg/m3

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Fix the Low Hanging Fruit

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Respirab

le Particulate M

atter (m

g/m3)

Time

Chart 3Sweeping with Sweeping Compound & Auto Sweeper

March 7, 2017

Broom sweeping with compound (Max of 34.8 mg/m3)

Driving Sweeper w/No Compound

Hand Tossing

MAX 34.8 mg/m3AVG: 0.44 mg/m3

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Conduct Full Shift Sampling Again


Review Ventilation & Existing Conditions (Is everything working?)

Full Shift Sampling Root Cause Analysis

Engineering and/or Work Practice Controls

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Respiratory Protection

Periodic Monitoring

Regulated Areas

Housekeeping

Medical Surveillance

Training

Engineering & Work Practice Controls

Still Above the PEL – Full Rule Required

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Required every 3 months for exposures above the PEL; every 6 months for exposures above the actionlevel, but below the PEL (Requirement Starts June 23, 2017 for Construction and June 23, 2018 for

Industry)

Need two consecutive sampling rounds with passing results, at least 7 days apart to modify schedule

Periodic Monitoring

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Areas Above the PEL to be Demarcated– Signage at Entrances

– All who enter required to have respirators on

DANGER

RESPIRABLE CRYSTALLINE SILICA

MAY CAUSE CANCER

CAUSES DAMAGE TO LUNGS

WEAR RESPIRATORY PROTECTION IN

THIS AREA

AUTHORIZED PERSONNEL ONLY

Regulated Areas

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Housekeeping provisions in the rule to apply to situations where dry sweeping, dry brushing or use of compressed air could contribute to employee exposure to respirable crystalline silica. (Regardless of Being Over the PEL or Not)– (i) The employer shall not allow dry sweeping or dry brushing where such

activity could contribute to employee exposure to respirable crystalline silica unless wet sweeping, HEPA‐filtered vacuuming or other methods that minimize the likelihood of exposure are not feasible.

– (ii) The employer shall not allow compressed air to be used to clean clothing or surfaces where such activity could contribute to employee exposure to respirable crystalline silica unless:

(a) The compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air; or

(b) No alternative method is feasible

Photo Courtesy of www.mysafetysign.com

Housekeeping

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Compressed Air On Clothing

0

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10

15

20

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13:24:58 13:26:24 13:27:50 13:29:17 13:30:43 13:32:10 13:33:36 13:35:02

Total D

ust m

g/m3

Time

Figure 9Kiln Attendant ‐ Clothing Blowoff

Clothing Blowoff Time

Walking Outside Back to Lunch

Average: 1.40 mg/m3

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Required for each employee who will be occupationally exposed to respirable crystalline silica at or above the action level for 30 or more days per year.

– Due June 30, 2018 for those above the PEL& Every 3 Years

(Make Sure Your Medical Provider is ready for this)

– Due June 30, 2020 for those above the Action Level and below the PEL

– New employees or new assignments; baseline examination due within the first 30 days of Initial Assignment


Photo courtesy of www.eurosil.eu

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The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following:

– (A) The health hazards associated with exposure to respirable crystalline silica;

– (B) Specific tasks in the workplace that could result in exposure to respirable crystalline silica;

– (C) Specific measures the employer has implemented to protect employees from exposure to respirable crystalline silica, including engineering controls, work practices, and respirators to be used;

– (D) The contents of this section; and

– (E) The purpose and a description of the medical surveillance program.

The employer shall make a copy of this section readily availablewithout cost to each employee covered by this section.

Training

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Training

1910.1053(j)(1)

Hazard communication. The employer shall include respirable crystalline silicain the program established to comply with the hazard communication standard(HCS) (29 CFR 1910.1200). The employer shall ensure that each employeehas access to labels on containers of crystalline silica and safety data sheets, and is trained in accordance with the provisions of HCS and paragraph (j)(3)of this section. The employer shall ensure that at least the following hazardsare addressed: Cancer, lung effects, immune system effects, and kidney effects.

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The employer shall use engineering and work practice controls to reduce and maintain employee exposure to respirable crystalline silica to or below the PEL, unless the employer can demonstrate that such controls are not feasible.– Due June 23, 2017 for Construction Activities

– Due June 23, 2018 for Industry

– Due June 23, 2021 for Fracking Industry

Ventilation Recirculation Scrutinized (See OSHA’s Dust ControlHandbook – Chapter 7)

https://www.osha.gov/dsg/topics/silicacrystalline/dust/dust_control_handbook.html

*Allow time for any necessary air permitting with EPA or DNR agencies

Engineering & Work Practice Controls

Questions?Brian J. Harms, P.E., CIHP: 262.901.2129 | E: [email protected]

Session 28 - Silica the Next Steps - WMC

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Transcript of Session 28 - Silica the Next Steps - WMC