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

2. § 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

3. §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

4. §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

5. § Table 1 - excerpt

6. §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:

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

8. 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

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

10. 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

11. (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

12. (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.

13. (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

14. (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.

15. 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

16. (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.

17. (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.

18. (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

19. (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

20. (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

21. (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

22. 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

23. Face-to-Facepiece Interference

24. Improper Respirator Use

25. Estimates of Exposure?

26. 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

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