ISFA – Are You in Compliance with OSHA?
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Are You in Compliance with OSHA’s New Crystalline Silica Regulations?
By Shannon DeCamp
Most provisions of the Airborne Crystalline Silica standard became enforceable on June 23. During the first 30 days of enforcement, OSHA offered compliance assistance for employers who made good faith efforts to comply with the new standard. However, that window is now closed and it is time to make sure that you are in compliance. Crystalline silica is a common mineral found in both naturally-occurring and manmade materials, including concrete, stone and engineered stone/quartz surfacing.
Silica in Surface Fabrication Shops
OSHA has concluded that for many surface fabrication shops, the current methods commonly used to limit silica exposure do not adequately protect worker health. Fabricating, finishing and installing concrete, natural and engineered stone countertops can release hazardous levels of tiny crystalline silica dust particles into the air that workers breathe. Workers operating powered hand tools, such as saws, grinders and high-speed polishers, have some of the highest silica dust exposures. Workers involved in manufacturing stone or concrete countertops may also be exposed to silica dust when opening bags of ground quartz, moving or mixing bulk raw materials, cleaning and scraping mixers, cleaning dust collector bag houses or changing filter bags. Both the workers doing these tasks and anyone in the area where silica dust is present may be exposed and face lifelong health consequences.
Employers must ensure that employees’ exposures to respirable crystalline silica do not exceed the Permissible Exposure Limit (PEL), which is 50 µg/m³ calculated as an 8-hour TWA. This means that over the course of any 8-hour work shift, exposure can fluctuate, but the average exposure cannot exceed 50 µg/ m³. Employee exposure means the exposure to airborne, respirable crystalline silica that would occur if the employee were not wearing a respirator. The action level (25 µg/ m³ calculated as an 8-hour TWA) is the point at which employers must start to do exposure assessments and medical surveillance.
The employer can choose from two options for assessing exposures: the performance option; or the scheduled monitoring option. The performance option gives employers the flexibility to determine the 8-hour TWA exposure for each employee based on any combination of air monitoring data or objective data that can accurately characterize employee exposures to respirable crystalline silica.
Objective data is information that demonstrates employee exposure to respirable crystalline silica associated with a particular product, material, process, task or activity. The data must reflect workplace conditions that closely resemble, or could result in higher exposures than, the conditions in the employer’s current operations. Examples of objective data are information such as air monitoring data from industry-wide surveys, calculations based on the composition of a substance, and historical air monitoring data collected by the employer.
The scheduled monitoring option defines when and how often employers must perform monitoring to measure employee exposures. When following the scheduled monitoring options, employers must make sure that the results represent the employee’s TWA exposure to respirable crystalline silica over an 8-hour workday and that samples are collected from the employee’s breathing zone outside of respirators, so they represent the exposure that would occur without the use of a respirator. Employers using the scheduled monitoring option must conduct initial monitoring as soon as work begins so that they are aware of exposure levels and where control measures are needed. How often monitoring must be done depends on the results of initial monitoring.
■ If exposures are below the action level, no further monitoring is required.
■ If exposures are at or above the action level, but at or below the PEL, monitoring must be repeated within six months.
■ If exposures are above the PEL, the employer must repeat monitoring within three months.
■ When two non-initial monitoring results taken consecutively, at least seven days apart but within six months of each other, are below the action level, monitoring may be discontinued as long as no changes occur that could affect exposure levels.
■ If there is any change in process, materials, personnel, control equipment or work practices that could reasonably be expected to result in new or additional exposures at or above the action level, the employer must reassess. Employers must notify each affected employee of the results of the exposure assessment within 15 working days of completing it. Each employee must be notified in writing, or the results may be posted in a location that all affected employees can access. When an assessment reveals exposures above the PEL, the notification must also describe the corrective action the employer is taking to reduce employee exposures to or below the PEL.
Employers must establish regulated areas where airborne concentrations of respirable crystalline silica can be reasonably expected to exceed the PEL. These areas must be marked off from the rest of the workplace and a sign must be posted at each entrance. Employers must limit access to these areas only to authorized employees.
Engineering and Work Practice Controls
Employers must use engineering and work practice controls to reduce employee exposure to respirable crystalline silica at or below the PEL unless the employer can demonstrate that such controls are not feasible. If these engineering controls and work practices are not able to reduce employee exposures at or below the PEL, employers must still use feasible controls to reduce exposures to the lowest possible level and then use respiratory protection along with these controls.
The main engineering controls for silica are the use of wet methods and local exhaust ventilation. Wet methods apply water or foam at the point of dust generation to keep dust from getting into the air. Local exhaust ventilation removes dust by capturing it where it is created. Another engineering control separates employees from the dust source by containing the dust or isolating employees in a control booth.
Work practice controls involve doing a task in a way that reduces the likelihood or levels of exposure. Employees must know the appropriate work practices for maximizing the effectiveness of controls and minimizing exposures.
Engineering and work practice controls are the preferred methods for minimizing exposure as they actually reduce the level of crystalline silica in the air. When all feasible measures are still not enough, respirators must be used. If respirators are required, you will need a complete respiratory protection program that complies with OSHA’s Respiratory Protection standard (29 CFR 1910.134).
Written Exposure Control Plan
All employers covered by the standard must develop and implement a written exposure control plan. This plan must describe all workplace exposures and ways to reduce those exposures, such as engineering controls, work practices and housekeeping methods. This plan must be reviewed at least once a year and updated as necessary. Affected employees have the right to view or copy this plan.
All employers covered by the Respirable Crystalline Silica standard must avoid certain housekeeping practices. When cleaning up dust that could contribute to employee exposure, employers must prohibit dry brushing and sweeping, unless methods such as wet sweeping and HEPA-filtered vacuuming are not feasible. Employers must also prohibit cleaning surfaces or clothing with compressed air, unless it is used together with a ventilation system that effectively captures the dust cloud or no other cleaning method is feasible.
Medical surveillance is intended to:
■ Identify respirable crystalline silicarelated diseases so that employees with those diseases can take action to protect their health;
■ Determine if an employee has any condition, such as a lung disease, that might make him or her more sensitive to respirable crystalline silica exposure; and
■ Determine the employee’s fitness to use respirators.
The standard specifies which employees must be offered medical surveillance, when and how often the examinations must be offered, and the tests that make up medical examinations. The standard also specifies the information the employer must give to the physician or licensed healthcare professional (PLHCP) who conducts the examinations and the information that the employer must ensure the PLCHP provides to the employee and employer.
Employers must train and inform employees covered by the silica standard about respirable crystalline silica hazards and the method the employer uses to limit their exposures. The employer must ensure that employees trained under the silica standard can demonstrate knowledge and understanding of at least:
1. Health hazards associated with respirable crystalline silica exposure.
2. Specific workplace tasks that could expose employees to respirable crystalline silica.
3. Specific measures the employer is implementing to protect employees from respirable crystalline silica exposure, including engineering controls, work practices and respirators to be used. This should include recognizing signs that the controls may not be working effectively.
4. The contents of the Respirable Crystalline Silica standard, including the standard’s requirements.
5. The purpose and description of the medical surveillance program required by the standard.
Employees must be trained at the time they are assigned to a position involving exposure to respirable crystalline silica. Additional training must be provided as often as necessary to ensure that employees know and understand respirable crystalline silica hazards and the protections available in their workplace.
Employers must make and keep the following records:
■ An accurate record of all air monitoring performed to comply with the standard;
■ An accurate record of any objective data used to comply with the standard; and
■ An accurate record for each employee provided medical surveillance under the standard.
Installation and fabrication done at jobsites is covered under OSHA Construction standards. The new construction standard for silica provides a table of specified controls employers can follow. If employers follow these specifications, they can be sure that they are providing their workers with the required level of protection. Employers may provide alternative methods of protection as long as they can prove that their methods effectively reduce their workers’ exposure to silica dust.
It is important to keep in mind that, as with all new regulations, Silica will be a focus area for OSHA. It is best to get a head start on compliance immediately, not only to protect your business, but, most importantly, to protect your most important asset – your employees.
About the Author
Shannon DeCamp is Client Services Manager for TechneTrain, Inc. TechneTrain has a full line of safety training programs and reference manuals specifically designed for the surface fabrication industry, including a turnkey employee training program for the new airborne crystalline silica regulations. These products are available from ISFA at discounted prices. For further information regarding OSHA Compliance requirements for the surface fabrication industry, visit www.technetrain.net, or contact TechneTrain, Inc. at (800) 852-8314.