1. Welcome Revised Silica Regulation Overview & Region III Focus Four Campaign Will begin at 10:30am To join Teleconference Call-in Number: Participant Pin: # Presented by: Dane Sprankle Pennsylvania OSHA Consultation Office Phone: or Web:

2. Revised Silica Regulation Overview & Region III Focus Four Campaign
Webinar General Info Recorded PowerPoint Presentation Q&A To join Teleconference Call-in Number: Participant Pin: # PA OSHA Consultation Program Website

3. Revised Silica Regulation Overview & Region III Focus Four Campaign
Questions Chat is open to submit questions Due to the technical nature of most questions requiring extensive responses, chat questions will not be answered live Answers will be posted on our website within seven days after the webinar  

4. WEBINAR OBJECTIVES
Provide an overview of OSHA’s revised silica regulations
Compliance dates
Key requirements
Not a comprehensive review
Provide a description of OSHA’s Region III Focus Four Campaign

5. Revised Silica Regulation Overview

6. Why Revisions? Better toxicology data Continuing health problems
Modern exposure control technology

7. Standards General Industry and Maritime – 29 CFR 1910.1053
Construction – 29 CFR

8. DATES Effective Date of Final Rule - 6/23/2016 Compliance dates:
General industry / Maritime
6/23/2018 – All obligations except medical surveillance
6/23/2020 – Medical surveillance

9. DATES Compliance Dates Cont’d:
Hydraulic Fracturing in oil/gas industry
6/23/2018 – All obligations except engineering controls and medical surveillance
6/23/2020 – Medical surveillance
6/23/2021 – Engineering controls

10. DATES Compliance Dates Cont’d: Construction
6/23/2017 – All obligations except methods of sample analysis
6/23/2018 – Methods of sample analysis

11. GENERAL INDUSTRY/MARITIME
29 CFR
Applies to all occupational exposures to respirable crystalline silica, except:
Construction work
Agricultural operations
Processing of sorptive clays
Objective data (if exp.< A.L)
In compliance with 29 CFR provided that:
Listed construction task, and
Non-routine

12. INDUSTRY EXAMPLES Glass manufacturing Pottery products
Concrete products
Foundries
Dental laboratories
Paintings and coatings
Jewelry production
Refractory products
Abrasive blasting in maritime, construction, and general industry
Oil and gas operations
Cut stone and stone products
Many more…

13. KEY PROVISIONS Exposure Limits
Current limit – “Respirable dust containing crystalline silica”
Variable
Permissible Exposure Limit (PEL) = mg/m3
% silica in sample + 2
Revised limits – Respirable crystalline silica
No variation
Action Level = 25 μg/m3
Permissible Exposure Limit (PEL) = 50 μg/m3

14. KEY PROVISIONS, Cont’d Exposure Assessment Performance Option
Any combination of objective data and air monitoring
Scheduled Monitoring Option
Initial monitoring
Repeat monitoring:
3 months if > PEL
6 months if > AL
Discontinuing monitoring

15. KEY PROVISIONS, Cont’d Regulated Area Exposure > PEL Demarcation
Signage
Access limited
Respiratory protection

16. REGULATED AREA - SIGNAGE
DANGER RESPIRABLE CRYSTALLINE SILICA MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS WEAR RESPIRATORY PROTECTION IN THIS AREA AUTHORIZED PERSONNEL ONLY

17. KEY PROVISIONS, Cont’d Methods of Compliance
Engineering and Work Practice Controls
Written Exposure Control Plan
Abrasive blasting

18. KEY PROVISIONS, Cont’d Engineering and Work Practice Controls
Best option
Feasible
Mandatory respirator if exp. > PEL
Examples:
Product substitution
Wet methods
Isolation (employee/process)
Local exhaust / capture systems
General ventilation

19. KEY PROVISIONS, Cont’d Written Exposure Control Plan Established
Updated annually
Describes:
Covered tasks
Exposure controls
Housekeeping measures

20. KEY PROVISIONS, Cont’d Abrasive Blasting – additional regulations
Application
Abrasive blasting agents containing crystalline silica
Substrates containing crystalline silica
Regulations
29 CFR (Ventilation)
29 CFR (Mechanical paint removers)
29 CFR 1915 Subpart I (Personal Protective Equipment

21. KEY PROVISIONS, Cont’d Respiratory protection
Meeting 29 CFR and 29 CFR
Required where:
Exposures > PEL
Installing or implementing engineering/work practice controls
Engineering/work practice controls not feasible
e.g. Certain maintenance tasks
Feasible engineering/work practice controls insufficient
Regulated areas

22. KEY PROVISIONS, Cont’d Housekeeping No dry sweeping/brushing unless:
Wet sweeping, HEPA-filtered vacuuming or other methods not feasible
No compressed air cleaning unless:
Used in conjunction with an effective ventilation system that captures the dust, or
No alternative method is feasible

23. KEY PROVISIONS, Cont’d Medical surveillance Application
Exposure > A.L. for 30 or more days per year
Examination schedule
Baseline within 30 days of initial assignment
At least every 3 years
Additional examinations (i.e. specialists) if recommended by PLHCP

24. KEY PROVISIONS, Cont’d Medical surveillance, cont’d
Examination content
Medical and work history
Physical examination
Chest X-Ray
Pulmonary function test
Tuberculosis test

25. KEY PROVISIONS, Cont’d Hazard communication
Include in hazard communication program
Ensure access to:
Safety Data Sheets
Labels
The following hazards must be addressed:
Cancer
Lung effects
Immune system effects
Kidney effects

26. KEY PROVISIONS, Cont’d Employee information and training
Specific training topics:
Health hazards
Covered tasks
Exposure controls
Contents of the standard, and
Medical surveillance

27. KEY PROVISIONS, Cont’d Record-keeping
In accordance with 29 CFR
Air monitoring data
Objective data (if applicable)
Medical surveillance

28. CONSTRUCTION
29 CFR
All exposures to respirable crystalline silica in construction work, except:
Objective data (if exp.< A.L)
"Construction work" means “work for construction, alteration, and/or repair, including painting and decorating”

29. Primary Differences from General Industry/Maritime Standard
Compliance dates
Written exposure control plan
Competent person
Specified exposure control methods
Medical surveillance trigger
Employee notification of monitoring results

30. COMPLIANCE DATES
6/23/2017 – All obligations except methods of sample analysis
6/23/2018 – Methods of sample analysis

31. WRITTEN EXPOSURE CONTROL PLAN
Similar to GI/Maritime with following additional requirements:
Describes procedures to:
Restrict access to work areas
Minimize number of employees exposed and exposure levels
Includes exposures generated by other employers
Designates a competent person to:
Inspect
Ensure implementation of plan

32. COMPETENT PERSON
“An individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them”

33. SPECIFIED EXPOSURE CONTROL METHODS
18 common tasks/equipment described
Controls and respirator requirements specified
Full implementation required
Tasks not listed or failure to implement fully:
Must assess and control exposures per paragraph (d)

34. TABLE 1 EXAMPLE TABLE 1: SPECIFIED EXPOSURE CONTROL METHODS
WHEN WORKING WITH MATERIALS CONTAINING CRYSTALLINE SILICA
Equipment/Task
Engineering and Work Practice
Control Methods
Required Respiratory Protection and Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift
> 4 hours/shift
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

35. ADDITIONAL REQUIREMENTS
When implementing control measures specified in Table 1:
Tasks performed indoors or in enclosed areas
Adequate ventilation to minimize visible airborne dust
Tasks using wet methods
Flow rates sufficient to minimize release of visible dust

36. ADDITIONAL REQUIREMENTS, Cont’d
Table 1 cont’d
Enclosed cab/booth requirements:
Free from settled dust
Door seals/closing mechanisms maintained
Gaskets/seals working properly
Positive pressure with continuous fresh air
Filtered intake air
Climate controlled

37. MEDICAL SURVEILLANCE TRIGGER
Respirator required 30/more days per year
GI based on action level

38. NOTIFICATION OF MONITORING RESULTS
General Industry / Maritime
Notify in writing within 15 working days after exposure assessment
Individually, or
Post where accessible to all affected employees
Construction
Notify in writing within 5 working days after exposure assessment

39. OSHA’s “FOCUS FOUR HAZARDS” CAMPAIGN

40. What is it?
Joint effort by OSHA and construction industry partners in Region III
Four month program started in February of this year
Focusing on the four leading hazards resulting in construction fatalities:
Falls
Electrocutions
Struck by object, and
Caught-in/between

41. “FOCUS FOUR HAZARDS” CAMPAIGN

42. “FOCUS FOUR HAZARDS” CAMPAIGN
How to participate
Conduct weekly toolbox talks (provided via )
Share the program with colleagues, trade groups, etc.
Provide feedback to local OSHA Area Office in care of their Compliance Assistance Specialist

43. PA OSHA Consultation

44. OSHA On-site Consultation Program
Designed specifically for small-and medium-size businesses
250 employees at a single site or 500 corporate wide
Priority assistance given to:
employers in high-hazard industries
involved in hazardous operations
Large business requests honored as well…but limited scope

45. No Citations, No Penalties
Different than OSHA enforcement
Citations for violations… are not issued
Penalties for violations… are not imposed
Employer Obligations
Employer must agree to correct any “serious or imminent danger” hazards identified
Must refer to OSHA Enforcement if employer refuses to correct hazards…very rare!

46. Costs and Savings Free of charge
Avoided OSHA penalty and litigation costs
Reduced workers compensation costs
Minimized equipment damage and product losses
One consultant identifies an average of 7 serious and other-than-serious hazards, SAVING the employer approximately $87,000 in OSHA fines per visit

47. Contact us Pennsylvania OSHA Consultation Office
57 South 9th Street Suite 305 Indiana, PA 15701
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48. Questions
Upcoming Webinar: Fall Protection in Construction May 9, 10:30am Pennsylvania OSHA Consultation Office Phone: or Website: