Silica in Construction: Cal/OSHA’s Experience Patrick Corcoran MPH, CIH Senior Safety Engineer Cal/OSHA Consultation Service

§1530.1. Control of Employee Exposures from Dust-Generating Operations Conducted on Concrete or Masonry Materials. CA-only in 2008 Exceptions Stucco/plaster Downward drilling Incidental cutting/drilling Roofing Dust reduction system Training

§1530.1. Enforcement Issues Exceptions cover some very dusty tasks Dust reduction system maintenance – manual? PM? Could write it everyday Folks don’t want to/won’t let you sample Training did not need to be documented

§1532.3. Changes vs. §1530.1. Competent person Exceptions removed Lower Permissible Exposure Limit Written exposure control plan Table 1 (or effective alternative) Housekeeping Medical Surveillance Training Recordkeeping

§1532.3. Table 1 - excerpt

§1532.3. Table 1. Engineering and Work Practice Controls - Examples 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 Use saw equipped with commercially available dust collection system Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency Use drill equipped with commercially available shroud or cowling with dust collection system Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic pre-separator or filter-cleaning mechanism:

Potential Silica Dust Exposures Masonry Dry Wall Roof Tiles Structural Steel Insulation Plastering Sand Blasting Granite/Marble Concrete

Silica Exposure Control Silica dust exposure can be controlled by use of water or exhaust ventilation Using water to cut concrete and bricks Concrete sander with exhaust ventilation

Cal-OSHA’s Respiratory Protection Standard T8 CCR Section 5144 - Highlights

Organization of Standard (a) Permissible practice (b) Definitions (c) Respirator program (d) Selection of respirators (e) Medical evaluation (f) Fit testing (g) Use of respirators (h) Maintenance and care (i) Breathing air quality and use (j) Identification of filters, cartridges, and canisters (k) Training and information (l) Program evaluation (m) Recordkeeping (n) Dates (o) Appendices (mandatory) A: Fit Testing Procedures B-1: User Seal Checks B-2: Cleaning Procedures C: Medical Questionnaire D: Information for Employees Wearing Respirators When Not Required Under the Standard

(a) Permissible Practice The primary means to control occupational diseases caused by breathing contaminated air is through the use of feasible engineering controls, such as enclosures, confinement of operations, ventilation, or substitution of less toxic materials When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this standard

(c) Respirator Program Must develop a written program with worksite-specific procedures when respirators are necessary or required by the employer Must designate a program administrator who is qualified by appropriate training or experience to administer or oversee the program and conduct the required program evaluations Must provide respirators, training, and medical evaluations at no cost to the employee Note: OSHA has prepared a Small Entity Compliance Guide that contains criteria for selection of a program administrator and a sample program.

(c) Respirator Program Elements 1. Selection 2. Medical evaluation 3. Fit testing 4. Use 5. Maintenance and care 6. Breathing air quality and use 7. Training 8. Program evaluation

(d) Selection of Respirators Employer must select and provide an appropriate respirator based on the respiratory hazards to which the worker is exposed and workplace and user factors that affect respirator performance and reliability.

TABLE 1 – ASSIGNED PROTECTION FACTORS5 Respirator Type1, 2 Quarter Mask Half Mask Full Face Helmet/Hood Loose-Fitting Air Purifying 5 310 50 ----------------- PAPR -------------------- 1,000 425/1,000 25 SAR Demand Continuous Flow Pressure Demand/ other (+) pressure 10 --------------------- SCBA Pressure Demand/ other (+) pressure ------------------ 10,000 ----------------------------------------

(e) Medical Evaluation Procedures Must provide a medical evaluation to determine employee’s ability to use a respirator, before fit testing and use Must identify a PLHCP to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information Follow-up medical examination is required for an employee who gives a positive response to certain questions. Must obtain a written recommendation regarding the employee’s ability to use the respirator from the PLHCP.

(f) Fit Testing Before an employee uses any respirator with a negative or positive pressure tight-fitting facepiece, the employee must be fit tested with the same make, model, style, and size of respirator that will be used.

(g) Use of Respirators Facepiece Seal Protection Respirators with tight-fitting facepieces must not be worn by employees who have facial hair or any condition that interferes with the face-to-facepiece seal or valve function Corrective glasses or goggles or other PPE must be worn in a manner that does not interfere with the face-to-facepiece seal Employees wearing tight-fitting respirators must perform a user seal check each time they put on the respirator using the procedures in Appendix B-1 or equally effective manufacturer’s procedures

(g) Use of Respirators Continuing Respirator Effectiveness Maintain appropriate surveillance of work area conditions and degree of exposure or stress; Employees must leave the respirator use area: to wash their faces and respirator facepieces as necessary if they detect vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece to replace the respirator or filter, cartridge, or canister If employee detects vapor or gas breakthrough, changes in breathing resistance, or leakage of the facepiece, employer must replace or repair the respirator before allowing employee to return to the work area

(h) Maintenance and Care Provide each user with a respirator that is clean, sanitary and in good working order Use procedures in Appendix B-2 or equivalent manufacturer’s recommendations Clean and disinfect at the following intervals: as often as necessary when issued for exclusive use before being worn by different individuals when issued to more than one employee after each use for emergency respirators and those used in fit testing and training

(k) Training and Information Employees who are required to use respirators must be trained such that they can demonstrate knowledge of at least: why the respirator is necessary and how improper fit, use, or maintenance can compromise its protective effect limitations and capabilities of the respirator effective use in emergency situations how to inspect, put on and remove, use and check the seals maintenance and storage recognition of medical signs and symptoms that may limit or prevent effective use general requirements of this standard

Enforcement Issues: Respirators No written program No competent administrator Respirators Facial hair/hoodies No cartridge change-out schedule or estimate of exposure Medical evaluations/fit testing EE training Contaminant, change out, care and maintenance

Face-to-Facepiece Interference

Improper Respirator Use

Estimates of Exposure?

1532.3 A Brave New World Controls required for all silica-generating tasks when >AL Action level now much lower Burden of proof for some tasks shifts to ER Table 1 or assessment Maintenance of controls & training must be documented Manufacturers are creating controls to meet the demand: E.g. Bosch, Hilti, Milwaukee, DeWalt

Patrick Corcoran MPH, CIH Cal/OSHA Consultation pcorcoran@dir.ca.gov Questions? Patrick Corcoran MPH, CIH Cal/OSHA Consultation pcorcoran@dir.ca.gov