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Silica 2018 construction

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John Newquist
John Newquist

A presentation that I gave to the Chicago Roofing Contractors Assocation. Thanks to John Dimos for the corrections.

1 of 65
OSHA’s Crystalline Silica Construction Regulation 29 CFR §1926.1153• Training • Exposure Control • Medical Surveillance • Written Programs Draft 2 3 2018
Training • Silica training needs to be done. • 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; 1926.1153(i)(2)(i)(A)
What is crystalline silica?  Silica refers to the chemical compound silicon dioxide (SiO²).  SiO2 is one of the most common elements on Earth; it is the main component of sand.  Quartz is commonly named when referring to pure silica or crystalline silica in SDSs.
Chronic Exposure • Chronic exposure refers to exposure continued or repeated for a prolonged period, usually years. For example, silicosis.
How does a hazard from crystalline silica occur? • Hazard occurs when material containing silica (quartz, sand) is cut or ground usually with powered equipment such as grinders or saws with diamond or abrasive blades • “Respirable” or (RCS) means breathable: The fine silica particles (about 10 microns or less in size) are tiny enough to be inhaled and settle deep in the lungs.
Levels • OSHA level is 50 micrograms • White cloud can be over the silica levels in one minute
Potential health effects  Silicosis: the oldest known and most common occupational lung disease marked by the formation of lumps and fibrous scar tissue in the lungs
Potential health effects  Lung cancer: the leading cause of cancer deaths in the U.S.
Potential health effects  Pulmonary tuberculosis: a contagious bacterial infection of the lungs
Potential health effects  Chronic obstructive pulmonary disease (COPD)
Potential health effects  Other diseases: More studies are needed on the cause and effect of RCS on other diseases or illnesses, but some research indicates a higher incidence of other cancers among workers exposed to silica, as well as a higher incidence of  kidney disease,  immune system effects and  enlargement of the right ventricle of the heart.
Whole Lung Lavage  Positive results for early silicosis
Silica • 150-200 deaths a year (2009) • 1150-1200 deaths a year (1968) • Yet….one company had 3 silicosis and 10x+ severe respiratory diseases Gauley Bridge in 1920’s had workers die in months.
Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • Specific tasks in the workplace that could result in exposure to respirable crystalline silica 1926.1153(i)(2)(i)(C)
Tasks
Tasks
Tasks
Tasks
Tasks
Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • Specific control measures including engineering controls, work practices, and respirators to be used 1926.1153(i)(2)(i)(C)
OSHA sets out a hierarchy of controls for silica
What is the hierarchy of controls in silica exposure? 1. Engineering and work practice controls (unless contractor shows NOT feasible) a. Substitution b. Isolation c. Ventilation d. Dust suppression 2. Respiratory protection
Controlling exposures • Table 1 lists 18 construction tasks • Contractor must fully and properly implement engineering controls, work practices and respiratory protection listed for the task in Table 1 UNLESS contractor assesses the worker exposure to silica and limits it as the rule sets out • Does it have silica?
Silica 2018 construction
Control Measures
Control Measures
Control Measures
Handheld and stand- mounted drills (including impact and rotary hammer drills) Use drill equipped with commercially available shroud or cowling with HEPA dust collection system Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions Use a HEPA-filtered vacuum when cleaning holes
Control Measures
Silica 2018 construction
Control Measures
Silica 2018 construction
Control Measures
Taping • The primary ingredient is usually calcite (limestone), but it may contain gypsum, mica, talc, perlite, clays such as kaolin, gypsum, and in some cases silica sand. With hand sanding, much of the dust generated consists of particles that are too big to inhale into the lungs (particles larger than 15 micrometers in diameter make up about 50% of the inhalable mass). Festool Planex Drywall Sander
Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • The contents of the OSHA Silica Standard 1926.1153(i)(2)(i)(D)
Silica regulations  Notice of proposed rulemaking issued in 2013; rules targeted to general industry (manufacturing) and construction  Contains a more protective permissible exposure limit (PEL)  Final rule in construction effective Sept. 23, 2017
Scope of rule  Applies to all occupational exposures in construction to crystalline silica EXCEPT where worker exposure will remain below the action level of 25 micrograms per cubic meter of air as an eight-hour time- weighted average (TWA) under any foreseeable conditions
Permissible Exposure Limit (PEL) • Maximum amount or concentration of a chemical or physical agent a worker may be exposed to under OSHA regulations. • PEL is set at 50 micrograms per cubic meter of air as an eight- hour TWA; a microgram is one-thousandth of a milligram or one-millionth of a gram.
Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • The identity of the competent person designated by the employer 1926.1153(i)(2)(i)(E)
Competent person • The employer shall designate a competent person to make frequent and regular inspections of job sites, materials, and equipment to implement the written exposure control plan. 1926.1153(g)(4) Per OSHA:
Written exposure control plan • Following elements: • A description of the tasks • A description of the engineering controls, work practices, and respiratory protection for each task; • A description of the housekeeping measures • A description of the procedures used to restrict access to work areas • Review annually and update it as necessary. 1926.1153(g)(1)
Written exposure control plan Operation: Hand-held power saw (any blade diameter) Engineering control: Water delivery system to blade (water must be applied at flow rate that minimizes release of visible dust) Respirator required: If four hours or less per day—none If more than four hours per day—APF 10 respirator
Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • The purpose and a description of the medical surveillance program. 1926.1153(i)(2)(i)(F)
Medical surveillance program. Use of Table 1 triggers medical surveillance requirements on the 30th work day performing a task where respirator use is a listed requirement.
Medical surveillance Medical surveillance is needed for workers required by the new rule to wear a respirator for 30 or more days per year. The following medical exams should be conducted by a physician or other licensed health care professional: • History and physical • Chest X-rays by NIOSH-certified B Reader • Pulmonary function test • Latent TB test An exam within 30 days after the worker’s initial assignment must be done for medical and work history, pulmonary function, and other related issues. 1926.1153(h)
Notification • Contractors must notify employees of the results of an exposure assessment within five days after results are complete. • If there is exposure above the PEL, a description of the contractor’s corrective action must be included
If tasks are not listed in Table 1 or the OSHA-mandated controls are not fully implemented … … contractor has to make sure no worker is exposed to respirable silica in an amount exceeding the PEL.
Exposure assessment A contractor is required to assess the exposure of any worker who is exposed, or may reasonably be expected to be exposed, to crystalline silica at or above the action level of 25 micrograms per cubic meter of air (half the PEL). This can be accomplished by: (1) The performance option, defined as any combination of air monitoring (personal breathing zone [PBZ] sampling) or use of objective data.
(2) The scheduled monitoring option  If below action level, monitoring can be discontinued  If at or above action level but at or below PEL, periodic monitoring must be done every six months; if above PEL, monitoring must be done at least every three months  Reassess in the case of new processes, practices or controls
Objective data Objective data is defined by OSHA as information, such as air-monitoring data from industry-wide surveys or calculations, that demonstrates worker exposure to RCS associated with a particular product or material or a specific process, task or activity. Such data must reflect workplace conditions resembling current operations or with a higher exposure potential than current processes, materials, control methods, work practices and environmental conditions.
Asphalt shingle removal project #1701 • Date: July 5, 2017 • Location: Munster, IN • Structure type: Church • Project description: Removal of 5,000 square feet of approximately 25 year old, three- tab shingle removal using hand tools • Lab analysis of removed material: 9.9% quartz • Crew members sampled: 5. Sample results for RCS in micrograms per cubic meter of air: – 9.0 µg – 9.2 µg – 9.3 µg – 9.4 µg – 9.4 µg
Asphalt shingle installation project #1702 • Date: July 6, 2017 • Location: Munster, IN • Structure type: Church • Project description: Installation of ice and water barrier and laminated asphalt shingles on 5,000 square foot roof area • Products installed: Carlisle WIP® 100 water and ice protection and Certainteed Landmark® asphalt shingles • Crew members sampled: 5. Sample results for RCS in micrograms per cubic meter of air: – 9.4 µg – 9.5 µg – 9.4 µg – 9.4 µg – 9.4 µg
Asphalt shingle removal project #1703 • Date: September 6, 2017 • Location: Fairfield, OH • Structure type: Residence • Project description: 1,400 square feet of asphalt shingle and underlayment removal using hand tools • Lab analysis of removed material: 9.9% quartz • Crew members sampled: 5. Sample results for RCS in micrograms per cubic meter of air: – 18.0 µg – 17.0 µg – 19.0 µg – 18.0 µg – 22.0 µg
Asphalt shingle installation project #1704 • Date: September 6, 2017 • Location: Fairfield, OH • Structure type: Residence • Project description: Installation of synthetic underlayment, water barrier and laminated asphalt shingles on 1,400 square foot roof area using pneumatic nail guns. • Products installed: Atlas Summit® 60 Synthetic underlayment; Atlas Weathermaster® granular self-adhesive ice and water barrier; Atlas StormMaster® shingles. • Crew members sampled: 5. Sample results for RCS in micrograms per cubic meter of air: – 7.3 µg – 8.6 µg – 7.5 µg – 7.7 µg – 18.0 µg
Modified bitumen installation project #1723 • Date: August 8, 2017 • Location: Madison, WI • Structure type: School • Project description: Installation of 4,000 square feet of torch-applied SBS modified bitumen • Product installed: Siplast Paradiene® 20 PR TG. • Crew members sampled: 6 Sample results for RCS in micrograms per cubic meter of air: – 4.6 µg – 4.7 µg – 4.8 µg – 5.0 µg – 4.6 µg – 4.7 µg
Built-up roofing removal project #1744 • Date: August 8, 2017 • Location: Clackamas, OR • Structure type: School • Project description: 1,500 square feet of built up roofing system removal (half day) using powered roof cutter, shovels, brooms and wet/dry vacuum • Crew members sampled: 3 Sample results for RCS in micrograms per cubic meter of air: – 23 µg – 10 µg – 10 µg
Built-up roofing installation project #1745 • Date: August 8, 2017 • Location: Clackamas, OR • Structure type: School • Project description: 1,000 square feet of built up roofing system installation (half day) • Product installed: Johns Manville Dynabase® • Crew members sampled: 3 Sample results for RCS in micrograms per cubic meter of air: – 11 µg – 11 µg – 11 µg
Sheet metal and flashing installation project #1766 • Date: September 12, 2017 • Location: Chicago, IL • Structure type: Apartment building • Project description: Drilling and sawing into concrete and masonry to install 100’ of base tie-in and 50’ aluminum termination bar; drilled for fasteners every 12 inches (approximately 150 holes) • Crew members sampled: 2 Sample results for RCS in micrograms per cubic meter of air: – 5.8 µg – 5.7 µg
Housekeeping • Wet sweeping or HEPA vacuuming of RCS dust is preferred to dry sweeping or brushing unless infeasible. • Compressed air may not be used to clean clothing or surfaces if it could contribute to worker exposure.
Safety Data Sheets (SDSs) Under the GHS format of SDSs, Section 3 should contain the components of a product as in these examples.
SDSs  SDSs may list quartz, sand or silica. Sometimes, none will be listed in Section 3 as the regulation requires, but you may find language elsewhere as the example here indicates. The callout below is found in the “Composition Notes” below the list of ingredients. This highlights the importance of both the contractor and workers being familiar with the contents of all SDSs.
Product labeling under OSHA HCS  New products that have silica, quartz or sand listed as a component or ingredient in SDS Section 3, “Composition/informa tion on ingredients,” should also have pictograms conveying a hazard, such as:
Silica 2018 construction
Silica 2018 construction
Silica 2018 construction

More Related Content

Silica 2018 construction

  • 1. OSHA’s Crystalline Silica Construction Regulation 29 CFR §1926.1153• Training • Exposure Control • Medical Surveillance • Written Programs Draft 2 3 2018
  • 2. Training • Silica training needs to be done. • 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; 1926.1153(i)(2)(i)(A)
  • 3. What is crystalline silica?  Silica refers to the chemical compound silicon dioxide (SiO²).  SiO2 is one of the most common elements on Earth; it is the main component of sand.  Quartz is commonly named when referring to pure silica or crystalline silica in SDSs.
  • 4. Chronic Exposure • Chronic exposure refers to exposure continued or repeated for a prolonged period, usually years. For example, silicosis.
  • 5. How does a hazard from crystalline silica occur? • Hazard occurs when material containing silica (quartz, sand) is cut or ground usually with powered equipment such as grinders or saws with diamond or abrasive blades • “Respirable” or (RCS) means breathable: The fine silica particles (about 10 microns or less in size) are tiny enough to be inhaled and settle deep in the lungs.
  • 6. Levels • OSHA level is 50 micrograms • White cloud can be over the silica levels in one minute
  • 7. Potential health effects  Silicosis: the oldest known and most common occupational lung disease marked by the formation of lumps and fibrous scar tissue in the lungs
  • 8. Potential health effects  Lung cancer: the leading cause of cancer deaths in the U.S.
  • 9. Potential health effects  Pulmonary tuberculosis: a contagious bacterial infection of the lungs
  • 10. Potential health effects  Chronic obstructive pulmonary disease (COPD)
  • 11. Potential health effects  Other diseases: More studies are needed on the cause and effect of RCS on other diseases or illnesses, but some research indicates a higher incidence of other cancers among workers exposed to silica, as well as a higher incidence of  kidney disease,  immune system effects and  enlargement of the right ventricle of the heart.
  • 12. Whole Lung Lavage  Positive results for early silicosis
  • 13. Silica • 150-200 deaths a year (2009) • 1150-1200 deaths a year (1968) • Yet….one company had 3 silicosis and 10x+ severe respiratory diseases Gauley Bridge in 1920’s had workers die in months.
  • 14. Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • Specific tasks in the workplace that could result in exposure to respirable crystalline silica 1926.1153(i)(2)(i)(C)
  • 15. Tasks
  • 16. Tasks
  • 17. Tasks
  • 18. Tasks
  • 19. Tasks
  • 20. Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • Specific control measures including engineering controls, work practices, and respirators to be used 1926.1153(i)(2)(i)(C)
  • 21. OSHA sets out a hierarchy of controls for silica
  • 22. What is the hierarchy of controls in silica exposure? 1. Engineering and work practice controls (unless contractor shows NOT feasible) a. Substitution b. Isolation c. Ventilation d. Dust suppression 2. Respiratory protection
  • 23. Controlling exposures • Table 1 lists 18 construction tasks • Contractor must fully and properly implement engineering controls, work practices and respiratory protection listed for the task in Table 1 UNLESS contractor assesses the worker exposure to silica and limits it as the rule sets out • Does it have silica?
  • 28. Handheld and stand- mounted drills (including impact and rotary hammer drills) Use drill equipped with commercially available shroud or cowling with HEPA dust collection system Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions Use a HEPA-filtered vacuum when cleaning holes
  • 34. Taping • The primary ingredient is usually calcite (limestone), but it may contain gypsum, mica, talc, perlite, clays such as kaolin, gypsum, and in some cases silica sand. With hand sanding, much of the dust generated consists of particles that are too big to inhale into the lungs (particles larger than 15 micrometers in diameter make up about 50% of the inhalable mass). Festool Planex Drywall Sander
  • 35. Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • The contents of the OSHA Silica Standard 1926.1153(i)(2)(i)(D)
  • 36. Silica regulations  Notice of proposed rulemaking issued in 2013; rules targeted to general industry (manufacturing) and construction  Contains a more protective permissible exposure limit (PEL)  Final rule in construction effective Sept. 23, 2017
  • 37. Scope of rule  Applies to all occupational exposures in construction to crystalline silica EXCEPT where worker exposure will remain below the action level of 25 micrograms per cubic meter of air as an eight-hour time- weighted average (TWA) under any foreseeable conditions
  • 38. Permissible Exposure Limit (PEL) • Maximum amount or concentration of a chemical or physical agent a worker may be exposed to under OSHA regulations. • PEL is set at 50 micrograms per cubic meter of air as an eight- hour TWA; a microgram is one-thousandth of a milligram or one-millionth of a gram.
  • 39. Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • The identity of the competent person designated by the employer 1926.1153(i)(2)(i)(E)
  • 40. Competent person • The employer shall designate a competent person to make frequent and regular inspections of job sites, materials, and equipment to implement the written exposure control plan. 1926.1153(g)(4) Per OSHA:
  • 41. Written exposure control plan • Following elements: • A description of the tasks • A description of the engineering controls, work practices, and respiratory protection for each task; • A description of the housekeeping measures • A description of the procedures used to restrict access to work areas • Review annually and update it as necessary. 1926.1153(g)(1)
  • 42. Written exposure control plan Operation: Hand-held power saw (any blade diameter) Engineering control: Water delivery system to blade (water must be applied at flow rate that minimizes release of visible dust) Respirator required: If four hours or less per day—none If more than four hours per day—APF 10 respirator
  • 43. Training • Silica training needs to be done. • The employer shall ensure that each employee covered by this section can demonstrate knowledge and understanding of at least the following: • The purpose and a description of the medical surveillance program. 1926.1153(i)(2)(i)(F)
  • 44. Medical surveillance program. Use of Table 1 triggers medical surveillance requirements on the 30th work day performing a task where respirator use is a listed requirement.
  • 45. Medical surveillance Medical surveillance is needed for workers required by the new rule to wear a respirator for 30 or more days per year. The following medical exams should be conducted by a physician or other licensed health care professional: • History and physical • Chest X-rays by NIOSH-certified B Reader • Pulmonary function test • Latent TB test An exam within 30 days after the worker’s initial assignment must be done for medical and work history, pulmonary function, and other related issues. 1926.1153(h)
  • 46. Notification • Contractors must notify employees of the results of an exposure assessment within five days after results are complete. • If there is exposure above the PEL, a description of the contractor’s corrective action must be included
  • 47. If tasks are not listed in Table 1 or the OSHA-mandated controls are not fully implemented … … contractor has to make sure no worker is exposed to respirable silica in an amount exceeding the PEL.
  • 48. Exposure assessment A contractor is required to assess the exposure of any worker who is exposed, or may reasonably be expected to be exposed, to crystalline silica at or above the action level of 25 micrograms per cubic meter of air (half the PEL). This can be accomplished by: (1) The performance option, defined as any combination of air monitoring (personal breathing zone [PBZ] sampling) or use of objective data.
  • 49. (2) The scheduled monitoring option  If below action level, monitoring can be discontinued  If at or above action level but at or below PEL, periodic monitoring must be done every six months; if above PEL, monitoring must be done at least every three months  Reassess in the case of new processes, practices or controls
  • 50. Objective data Objective data is defined by OSHA as information, such as air-monitoring data from industry-wide surveys or calculations, that demonstrates worker exposure to RCS associated with a particular product or material or a specific process, task or activity. Such data must reflect workplace conditions resembling current operations or with a higher exposure potential than current processes, materials, control methods, work practices and environmental conditions.
  • 51. Asphalt shingle removal project #1701 • Date: July 5, 2017 • Location: Munster, IN • Structure type: Church • Project description: Removal of 5,000 square feet of approximately 25 year old, three- tab shingle removal using hand tools • Lab analysis of removed material: 9.9% quartz • Crew members sampled: 5. Sample results for RCS in micrograms per cubic meter of air: – 9.0 µg – 9.2 µg – 9.3 µg – 9.4 µg – 9.4 µg
  • 52. Asphalt shingle installation project #1702 • Date: July 6, 2017 • Location: Munster, IN • Structure type: Church • Project description: Installation of ice and water barrier and laminated asphalt shingles on 5,000 square foot roof area • Products installed: Carlisle WIP® 100 water and ice protection and Certainteed Landmark® asphalt shingles • Crew members sampled: 5. Sample results for RCS in micrograms per cubic meter of air: – 9.4 µg – 9.5 µg – 9.4 µg – 9.4 µg – 9.4 µg
  • 53. Asphalt shingle removal project #1703 • Date: September 6, 2017 • Location: Fairfield, OH • Structure type: Residence • Project description: 1,400 square feet of asphalt shingle and underlayment removal using hand tools • Lab analysis of removed material: 9.9% quartz • Crew members sampled: 5. Sample results for RCS in micrograms per cubic meter of air: – 18.0 µg – 17.0 µg – 19.0 µg – 18.0 µg – 22.0 µg
  • 54. Asphalt shingle installation project #1704 • Date: September 6, 2017 • Location: Fairfield, OH • Structure type: Residence • Project description: Installation of synthetic underlayment, water barrier and laminated asphalt shingles on 1,400 square foot roof area using pneumatic nail guns. • Products installed: Atlas Summit® 60 Synthetic underlayment; Atlas Weathermaster® granular self-adhesive ice and water barrier; Atlas StormMaster® shingles. • Crew members sampled: 5. Sample results for RCS in micrograms per cubic meter of air: – 7.3 µg – 8.6 µg – 7.5 µg – 7.7 µg – 18.0 µg
  • 55. Modified bitumen installation project #1723 • Date: August 8, 2017 • Location: Madison, WI • Structure type: School • Project description: Installation of 4,000 square feet of torch-applied SBS modified bitumen • Product installed: Siplast Paradiene® 20 PR TG. • Crew members sampled: 6 Sample results for RCS in micrograms per cubic meter of air: – 4.6 µg – 4.7 µg – 4.8 µg – 5.0 µg – 4.6 µg – 4.7 µg
  • 56. Built-up roofing removal project #1744 • Date: August 8, 2017 • Location: Clackamas, OR • Structure type: School • Project description: 1,500 square feet of built up roofing system removal (half day) using powered roof cutter, shovels, brooms and wet/dry vacuum • Crew members sampled: 3 Sample results for RCS in micrograms per cubic meter of air: – 23 µg – 10 µg – 10 µg
  • 57. Built-up roofing installation project #1745 • Date: August 8, 2017 • Location: Clackamas, OR • Structure type: School • Project description: 1,000 square feet of built up roofing system installation (half day) • Product installed: Johns Manville Dynabase® • Crew members sampled: 3 Sample results for RCS in micrograms per cubic meter of air: – 11 µg – 11 µg – 11 µg
  • 58. Sheet metal and flashing installation project #1766 • Date: September 12, 2017 • Location: Chicago, IL • Structure type: Apartment building • Project description: Drilling and sawing into concrete and masonry to install 100’ of base tie-in and 50’ aluminum termination bar; drilled for fasteners every 12 inches (approximately 150 holes) • Crew members sampled: 2 Sample results for RCS in micrograms per cubic meter of air: – 5.8 µg – 5.7 µg
  • 59. Housekeeping • Wet sweeping or HEPA vacuuming of RCS dust is preferred to dry sweeping or brushing unless infeasible. • Compressed air may not be used to clean clothing or surfaces if it could contribute to worker exposure.
  • 60. Safety Data Sheets (SDSs) Under the GHS format of SDSs, Section 3 should contain the components of a product as in these examples.
  • 61. SDSs  SDSs may list quartz, sand or silica. Sometimes, none will be listed in Section 3 as the regulation requires, but you may find language elsewhere as the example here indicates. The callout below is found in the “Composition Notes” below the list of ingredients. This highlights the importance of both the contractor and workers being familiar with the contents of all SDSs.
  • 62. Product labeling under OSHA HCS  New products that have silica, quartz or sand listed as a component or ingredient in SDS Section 3, “Composition/informa tion on ingredients,” should also have pictograms conveying a hazard, such as: