Ryan McAliney, Sr. Industrial Hygienist September 9, 2016

Ryan McAliney, Sr. Industrial Hygienist September 9, 2016
OSHA’s Final Rule on Occupational Exposure to Respirable Crystalline Silica: Focusing on Engineering Controls Photo courtesy of OSHA. Ryan McAliney, Sr. Industrial Hygienist September 9, 2016

Final Rule Published on March 25, 2016
The final rule was published on March 25, 2016, after an extensive process of stakeholder engagement. The proposed rule was posted on OSHA’s website in August, 2013 and published in the Federal Register in September, 2013. OSHA received more than 2000 written comments during a nearly year-long public comment period. Over 200 stakeholders, representing over 70 organizations, including public health groups, trade associations, and labor unions, presented testimony during public hearings on the proposed rule. OSHA considered all of this information in developing the final rule.

Purpose of the Final Rule
Employees exposed to respirable crystalline silica at the proceeding PELs are at increased risk to lung cancer mortality and silicosis mortality. Occupational exposures to respirable crystalline silica also result in increased risk of death from other nonmalignant respiratory diseases including COPD (chronic obstructive pulmonary disease) and kidney disease. As a result OSHA concluded that the new PEL of 50 ug/m3 is appropriate because it is the lowest feasible for all affected industries. Why did OSHA issue a new silica rule? OSHA adopted permissible exposure limits for respirable crystalline silica in construction, general industry, and shipyards in 1971, shortly after the Agency was created. Those PELs are outdated. The PELs for construction and shipyards are expressed in millions of particles per cubic foot, and are based on an obsolete sampling method that has not been used for many years. Anyone who uses modern sampling methods, including OSHA compliance staff, must apply a conversion factor to determine if sampling results are in compliance with the PEL. The PELs are also inconsistent. The construction and shipyard PELs allow workers in those sectors to be exposed to silica levels over twice as high as workers in general industry.

Scope of the New Standards
As proposed the new standards cover all occupational exposures to respirable silica with the exception of agricultural operations as defined by 29 CFR 1928. OSHA has made a final determination to exclude exposures in general industry and maritime where the employer has objective data demonstrating that employee exposure to respirable crystalline silica will remain below 25 ug/m3 as an 8-hour TWA under any foreseeable conditions. OSHA is also excluding exposures in construction where employee exposure to respirable crystalline silica will remain below 25 ug/m3 as an 8-hour TWA under any foreseeable conditions. In addition, OSHA is excluding exposures that result from the processing of sorptive clays from the scope of the rule.

Exposure Assessment Required if exposures are or may reasonably be expected to be at or above action level of 25 µg/m3 Exposures assessments can be done following: The performance option The scheduled monitoring option The standard requires employers to assess the exposure of any worker who may be exposed at or above the action level of 25 µg/m3 as an 8-hour time-weighted average. The standard allows for two different approaches to exposure assessment: The performance option, and the scheduled monitoring option.

Performance Option Exposures assessed using any combination of air monitoring data or objective data sufficient to accurately characterize employee exposure to respirable crystalline silica. The performance option provides flexibility for employers by allowing them to assess worker exposure based on any air monitoring data and/or objective data that is sufficient to accurately characterize worker exposure. For example, under this option an employer could determine that there is no meaningful difference between the exposure of an employee in a certain job classification who performs a task in a particular work area on one shift and the exposure of another employee in the same job classification who performs the same task in the same work area on a different shift. In that case, the employer could characterize the exposure of the second employee based on the characterization of the first employee’s exposure.

Objective Data Includes air monitoring data from industry-wide surveys or calculations based on the composition of a substance Demonstrates employee exposure associated with a particular product or material or a specific process, task, or activity Must reflect workplace conditions closely resembling or with a higher exposure potential than the processes, types of material, control methods, work practices, and environmental conditions in the employer's current operations Objective data can come from a variety of sources. Examples of objective data include: - Monitoring data obtained before the effective date of the standard; - Measurements of respirable dust by direct-reading instruments, along with information on the crystalline silica content of the material; and - Data from area sampling or area exposure profile mapping approaches. For example, an employer could assume that all respirable dust is respirable crystalline silica, and could then use measurements of respirable dust using direct-reading instruments to determine workers’ respirable crystalline silica exposures. The burden is on the employer to show that the exposure assessment is sufficient to accurately characterize employee exposures to respirable crystalline silica. Employers may rely on objective data for meeting their exposure assessment obligations, even where exposures may exceed the action level or PEL.

Scheduled Monitoring Option
Prescribes a schedule for performing initial and periodic personal monitoring If monitoring indicates: Initial below the AL: no additional monitoring Most recent at or above the AL: repeat within 6 months Most recent above the PEL: repeat within 3 months When two consecutive non-initial results, taken 7 or more days apart, are below the AL, monitoring can be discontinued Reassess if circumstances change The scheduled monitoring option provides a structured approach to assessing worker exposures. Any requirements for additional monitoring are determined based on the results of previous monitoring. The employer must reassess exposures whenever a change may reasonably be expected to result in new or additional exposures at or above the action level, or when the employer has any reason to believe that new or additional exposures at or above the action level have occurred.

General Industry/Maritime – Regulated Areas
Required where exposures can reasonably be expected to exceed the PEL Must be demarcated in any manner that limits workers in the area Must post warning signs at entrances Respirator use required Employers must establish a regulated area wherever worker exposures may exceed the PEL. The employer must demarcate the regulated area, and can use whatever means is appropriate for the workplaces (e.g., cones, stanchions). The standard specifies wording that must be included on signs to warn of hazards and required respirator use when in the area. Anyone in the regulated area must wear a respirator, even if their TWA exposure will not exceed the PEL. In response to commenters who argued that regulated areas are impractical in many situations in construction, regulated areas are not required under the construction standard. Employers must instead follow procedures for restricting access in the written exposure control plan (addressed later).

Methods of Compliance – Hierarchy of Controls
Employers can use any engineering or work practice controls to limit exposures to the PEL Respirators permitted where PEL cannot be achieved with engineering and work practice controls Employers must use engineering and work practice controls, to the extent feasible, to limit worker exposures to the PEL. Employers can choose any engineering controls and work practices that are effective in their workplace.

General Industry/Maritime – Written Exposure Control Plan
The plan must describe: Tasks involving exposure to respirable crystalline silica Engineering controls, work practices, and respiratory protection for each task Housekeeping measures used to limit exposure A written exposure control plan is intended help employers consistently control exposure by describing tasks resulting in exposure and controls for those exposures, as well as housekeeping measures. The plans must be reviewed annually and updated as needed, and must be made available to employees, their designated representatives, OSHA and NIOSH.

Respiratory Protection
Must comply with 29 CFR Respirators required for exposures above the PEL: While installing or implementing controls or work practices For tasks where controls or work practices are not feasible When feasible controls cannot reduce exposures to the PEL While in a regulated area (General Industry/Maritime) When respirator use is required, the employer must comply with OSHA’s respiratory protection standard and implement a respiratory protection program. Respiratory protection is required when engineering and work practice controls are not sufficient to limit worker exposures to the PEL.

Housekeeping When it can contribute to exposure, employers must not allow: Dry sweeping or brushing Use of compressed air for cleaning surfaces or clothing, unless it is used with ventilation to capture the dust Those methods can be used if no other methods like HEPA vacuums, wet sweeping, or use of ventilation with compressed air are feasible Certain cleaning methods, such as dry sweeping and use of compressed air, can contribute to worker exposure to respirable crystalline silica. The standard restricts use of these cleaning methods. Dry sweeping, dry brushing, and use of compressed air for cleaning are only allowed if other methods such as wet sweeping and HEPA-vacuuming are not feasible, or if a ventilation system is used to capture the dust cloud created by the compressed air.

General Industry/Maritime – Compliance Dates
Employers must comply with all requirements of the standard by June 23, 2018, except: Employers must comply with the action level trigger for medical surveillance by June 23, (The PEL is the trigger from June 23, 2018 through June 23, 2020.) Hydraulic fracturing operations in the oil and gas industry must implement engineering controls to limit exposures to the new PEL by June 23, 2021. Employers are required to comply with most provisions of the standard by June 23, 2018. Requirements for medical surveillance are phased in – workers exposed above the PEL for 30 or more days per year must be offered medical exams beginning on June 23, 2018; workers exposed at or above the action level for 30 or more days per year must be offered medical exams beginning on June 23, 2020. Hydraulic fracturing employers are given additional time to implement engineering controls to achieve the new PEL in order to take advantage of further development of emerging technologies in the industry.

Construction Standard
(a) Scope (b) Definitions (c) Specified exposure control methods OR (d) Alternative exposure control methods (1) PEL (2) Exposure Assessment (3) Methods of Compliance (e) Respiratory protection (f) Housekeeping (g) Written exposure control plan (h) Medical surveillance (i) Communication of silica hazards (j) Recordkeeping (k) Dates The construction standard follows a new approach to give construction employers more flexibility in addressing circumstances in their industry while offering workers protections that are as effective as those provided in general industry and maritime. Conditions in the construction industry warrant a standard that is somewhat different due to the transient nature of work, changing environmental conditions, common tasks where exposures to respirable crystalline silica are significant, and evidence on the effectiveness of controls needed to reduce exposures. The key difference is the specified exposure control methods approach—a flexible alternative to the traditional approach of assessing exposures and complying with the PEL using engineering and work practice controls to the extent feasible. Construction employers can follow either the specified exposure control methods or alternative exposure control methods. The specified exposure control methods approach involves following Table 1, which specifies effective controls, work practices, and respiratory protection for 18 construction tasks. Employers who fully and properly implement controls on Table 1 are not subject to the PEL and are not required to assess exposures for employees engaged in those tasks. If employers follow the alternative exposure control methods approach, they must comply with the PEL and provisions for exposure assessment. They must also follow the hierarchy of controls under methods of compliance. All construction employers, regardless of which approach they follow, are required to comply with all the other provisions of the standard including respiratory protection, housekeeping, written exposure control plan, medical surveillance, training, and recordkeeping. Other differences between general industry/maritime and construction include scope, written exposure control plan, medical surveillance and dates provisions.

Construction – Specified Exposure Control Methods
Table 1 in the construction standard matches 18 tasks with effective dust control methods and, in some cases, respirator requirements. Employers that fully and properly implement controls on Table 1 do not have to: Comply with the PEL Conduct exposure assessments for employees engaged in those tasks Table 1 in the construction standard lists common construction tasks known to generate high exposures to respirable crystalline silica, and identifies effective engineering controls, work practices, and respiratory protection for each task. When following this approach, employers must fully and properly implement the specifications listed on Table 1 for each employee engaged in the task. If they do this, they do not have to comply with the PEL or conduct exposure assessments. This approach simplifies compliance by avoiding the challenge of characterizing exposures and determining the effectiveness of controls in changing environments and conditions, while ensuring that employers are using controls that will adequately protect workers.

List of Table 1 Entries Stationary masonry saws Handheld power saws Handheld power saws for fiber cement board Walk-behind saws Drivable saws Rig-mounted core saws or drills Handheld and stand-mounted drills Dowel drilling rigs for concrete Vehicle-mounted drilling rigs for rock and concrete Jackhammers and handheld powered chipping tools Handheld grinders for mortar removal (tuckpointing) Handheld grinders for other than mortar removal Walk-behind milling machines and floor grinders Small drivable milling machines Large drivable milling machines Crushing machines Heavy equipment and utility vehicles to abrade or fracture silica materials Heavy equipment and utility vehicles for grading and excavating This slide shows the 18 entries on Table 1 The table covers the most common tasks in construction that involve exposure to respirable crystalline silica.

Construction – Written Exposure Control Plan
The plan must describe: Tasks involving exposure to respirable crystalline silica Engineering controls, work practices, and respiratory protection for each task Housekeeping measures used to limit exposure Procedures used to restrict access, when necessary to limit exposures In addition to the requirements for the Written Exposure Control Plan for general industry/maritime employers, the plan for construction also requires a description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed to respirable crystalline silica and their level of exposure, including exposures generated by other contractors. In construction, there is no requirement to establish regulated areas. This provision is intended to limit exposures to employees who might otherwise work adjacent to tasks that involve high exposures to respirable crystalline silica dust. Limiting access is necessary when workers are required to use respiratory protection for a task. Examples of how access can be restricting include moving employees upwind or scheduling high-exposure tasks when others are not around. Construction employers will not need to constantly update the plan for new locations, as long as the plan addresses the tasks, control measures, and procedures used to restrict access at the location.

Fully and Properly Implementing Controls Specified on Table 1
Presence of controls is not sufficient. Employers are required to ensure that: Controls are present and maintained Employees understand the proper use of those controls and use them accordingly Two critical components of this approach are: fully and properly implementing controls; and identifying employees engaged in the task. In order for an employer to be in compliance, the specified controls, work practices, and respiratory protection must be fully and properly implemented. Mere presence of controls is not sufficient—employers are required to ensure that controls are properly maintained and used. For example—for vacuum dust collection systems—the shroud must be intact and installed according to the manufacturer’s instructions; the hose connecting the tool to the vacuum must be intact or without kinks of tight bends that would prevent vacuum from providing sufficient air flow; the filter must be cleared or changed as frequently as necessary; and dust collection bags must be emptied as frequently as necessary. For water systems—an adequate water supply must be provided; spray nozzles must not be clogged; and water must be applied at the point of dust generation or other specified location. Resources for understanding full and proper implementation include manufacturer’s instructions; industry best practices; and the competent person.

Respiratory Protection Requirements on Table 1
Respirators required where exposures above the PEL are likely to persist despite full and proper implementation of the specified engineering and work practice controls Where respirators required, must be used by all employees engaged in the task for entire duration of the task Provisions specify how to determine when respirators are required for an employee engaged in more than one task In addition to specifying controls and work practices, Table 1 includes respiratory protection requirements for some equipment/tasks. If an employee is engaged in more than one Table 1 tasks and the duration of all tasks added together is more than 4 hours per shift, employers must follow the respiratory protection requirements in the greater then four hour column for each task.

Construction – Compliance Dates
Employers must comply with all requirements (except methods of sample analysis) by June 23, 2017 Compliance with methods of sample analysis required by June 23, 2018 Employers have until June 23, 2017 to comply with most provision of the construction standard. Controls for most construction tools are readily available and can be quickly adopted. Most construction employers are expected to use Table 1 and will not need to measure worker exposures to respirable crystalline silica. Employers who measure employee exposures have until June 23, 2018, to use laboratories that follow the procedures for sample analysis in Appendix A of the standard.

Engineering Controls/ Hazard Awareness
Grinding stone without engineering controls The next few slides show examples of engineering controls being used to limit worker exposure to respirable crystalline silica. The most common methods of limiting silica exposures are wet methods, where water is used to keep silica-containing dust from getting into the air, and vacuum dust collection systems, which capture dust at the point it is made. Photos obtained from OSHA PPT. Polishing stone using water to control the dust

Engineering Controls (cont.)/ Hazard Awareness
Grinding without engineering controls (Photos courtesy of the University of Washington). Grinding using a vacuum dust collector

Engineering Controls/ Hazard Awareness
Jackhammer use without engineering controls (Right Photo courtesy of NIOSH.) (Photo courtesy of Kenneth Linch.) Jackhammer use with water spray to control dust

High silica exposure can occur when stationary and hand held saws are operated without dust controls and wet methods. (Left Photo courtesy of the University of Washington. Right Photo courtesy of OSHA.)

When applying water to the blade, exposures of hand held saw operators to silica are considerably reduced. (Photo courtesy of OSHA.)

Grinders who perform tuck-pointing or hand held grinding without appropriate dust control mechanisms are exposed to high silica levels. (Photo courtesy of CPWR.)

Earth drilling rigs operated without dust controls are capable of producing high levels of respirable silica. (Photo courtesy of NIOSH, 1992.)

Table 1: Specified Exposure Control Methods (Respirable Silica)
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. No respiratory protection (RP) is required for this type of saw. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Handheld power saws (any blade diameter)-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. When used outdoors for less than 4 hours no respiratory protection (RPP) is required. When used greater than 4 hours RP with an APF 10 is required. When used indoors or in an enclosed area RP with an APF 10 is required. (Right Photo courtesy of NIOSH.) (Photo courtesy of Kenneth Linch.)

Handheld power saws for cutting fiber-cement boards with a diameter of 8 inches or less: (when used outdoors) Use saw equipped with commercially available dust collection system. Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions. Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency (HEPA). Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Walk-behind 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: When used outdoors no respiratory protection is required. When used indoors or in an enclosed area: respiratory protection is required with a minimum APF of 10. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Drivable Saws- (Engineering Controls are only required when used outdoors) Use a saw equipped with integral water delivery system that continuously feeds water to the blade. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Rig-mounted core saws or drills Use tool equipped with integrated water delivery system that supplies water cutting surface. Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions. No RP is required. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Handheld and stand-mounted drills (including impact and rotary hammer drills Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and filter cleaning mechanism. Use a HEPA-filtered vacuum when cleaning holes. No RP is needed. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Dowel drilling rigs for concrete (Tasks performed outdoors only): Use shroud around drill bit with a dust collection system. Dust collector must have a filter with 99% or greater effiency and filter cleaning mechanism. Use a HEPA-filtered vacuum when cleaning holes. Required respiratory protection with an APF 10 is required regardless of time during shift. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Vehicle-mounted drilling rigs for rock and concrete: Use dust collection system with close capture hood or shroud around drill bit with a low flow water spray to wet the dust at the discharge point from the dust collector OR Operate from within the enclosed cab and use water for dust suppression on drill bit. No respiratory protection is required. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Jackhammers and handheld powered chipping tools: Use tool with water delivery system that supplies continuous stream of spray of water at the point of impact. For outdoor use: Less than 4 hours- No RP required; Greater than 4 hours- APF 10 RP. Indoor use or in an enclosed area: RP APF 10 OR Use tool equipped with commercially available shroud and dust collection system. Operate and maintain in accordance with manufacturer’s instructions to minimize dust emissions. Dust collector must provide the air flow recommended by the tool manufacturer with a filter 99% or greater efficiency and filter cleaning mechanism. When used outdoors RP is only required when the shift is 4 hours or greater. When used indoors or in an enclosed area: RP must be APF 10 Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Jackhammers and handheld powered chipping tools: (Right Photo courtesy of NIOSH.) (Photo courtesy of Kenneth Linch.)

Handheld grinders for mortar removal (i.e. tuck-pointing) Use grinder equipped with commercially available shroud and dust collection systems. Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions. Dust collector must provide 25 cfm or greater of airflow per inch of wheel diameter and have a filter with 99% or greater capture efficiency. When the process is done for less than 4 hours: RP with an APF of 10 is required. When the process is greater than 4 hours: RP with an APF of 25 is required. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Handheld grinders for uses other than mortar removal (outdoor tasks only): Use grinder equipped with integrated water delivery system that continuously feeds water to the grinding surface. Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions. OR Use grinder equipped with commercially available shroud and dust collection system. Dust collector must provide 25 cfm or greater airflow per inch of wheel diameter and have a filter with 99% or greater efficiency. RP is required when used in an enclosed area for greater than 4 hours with an APF 10.

Handheld grinders for uses other than mortar removal (outdoor tasks only): Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Walk-behind milling machines and floor grinders: Use machine equipped with integrated water delivery system that continuously feeds water to the cutting surface. Operate and maintain tool in accordance with the manufacturer’s instructions to minimize dust emissions. OR Use machine equipped with dust collection system recommended by the manufacturer. Dust collector must provide the air flow recommended by the manufacturer or have a filter with a 99% or greater efficiency. When used indoors or in enclosed area use a HEPA vacuum to remove loose dust in between passes. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Small drivable milling machines (less than half-lane) : Use a machine equipped with supplemental water sprays designed to suppress dust. Water must be combined with a surfactant. Operate and maintain machine to minimize dust emissions. No RP is required. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Large drivable milling machines (half lane and larger) For cuts of any depth on asphalt only: Use machine equipped with exhaust ventilation on drum enclosure and supplemental water sprays designed to suppress dust. Operate and maintain machine to minimize dust emissions. For cuts of four inches in depth or less on any substrate: OR Use a machine equipped with supplemental water spray designed to suppress dust. Water must be combined with a surfactant.

Large drivable milling machines (half lane and larger) Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Crushing Machines: Use equipment designed to deliver water spray or mist for dust suppression at crusher and other points where dust is generated (e.g. hoppers, conveyors, sieves/sizing or vibrating components, and discharge points). Operate and maintain machine in accordance with manufacturer’s instructions to minimize dust emissions. Use a ventilated booth that provides fresh, climate-controlled air to the operator, or a remote control station. No RP required. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Heavy equipment and utility vehicles used to abrade or fracture silica- containing materials (e.g. hoe-ramming, rock ripping) or used during demolition activities involving silica-containing materials. Operate equipment from within an enclosed cab. When employees are outside of the cab are engaged in the task, apply water and or dust suppressants as necessary to minimize dust. No RP required. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Heavy equipment and utility vehicles for tasks such as grading and excavating but not including: demolishing, abrading, or fracturing silica-containing materials: Apply water and/or dust suppressants as necessary to minimize dust emissions. OR When equipment operator is the only employee engaged in the task, operate equipment from within an enclosed cab. Pictures are a Courtesy the Laborers’ Health and Safety Fund of North America

Ryan McAliney, Sr. Industrial Hygienist September 9, 2016

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Ryan McAliney, Sr. Industrial Hygienist September 9, 2016

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