1. Respirable Crystalline Silica
Strategies for an Effective Exposure Control Plan
Prepared by Abby Ferri, CSP

2. Learning Objectives
Describe the requirements of an RCS Exposure Control Plan.
Review & understand Table 1.
Understand your requirements for exposure assessment.
Identify resources for further study.

3. Quick background on new standard
Just in case…
Now let’s get into the actual standard.
Quick background on new standard

4. Effective Dates June 23, 2016: 1926.1153 is effective
Sept 23, 2017: All obligations, except for methods of sample analysis (Appx A)
June 23, 2018: Methods of sample analysis

5. Where to find the rule 606 pages, final rule + preamble
26 page regulatory text
The regulatory text will be officially published in the usual easy to read format at on June 23, 2016 – for now, you can access it via these links.

6. Exposure levels Expressed as 8-hour TWA PEL = 50 micrograms/m3
Action Level = 25 micrograms/m3
OSHA says exposure at this level is still significant, but is lowest level feasible
So if you remember from the last slide, exposures at the old PEL led workers to significant risk of health issues, and exposures at the new PEL also are said to be significant by OSHA. This language is why I personally think that any changes in the standard before or after promulgation in June of this year will not include a change in the PEL. I believe they will stick with the proposed 50 micrograms/m3 PEL.

7. Exclusions
If exposure stays below 25 micrograms/m3 as 8-hour TWA under “any foreseeable conditions”

8. Objective Data
If under 25 micrograms/m3 exception, no objective data required to support.
When done in isolation, do not generate significant exposures:
Mixing mortar
Pouring concrete footers, foundation
Removal of concrete formwork
“when these activities are done in isolation, OSHA found that they did not generate significant exposures”

9. OSHA’s Objective Data OSHA’s exposure monitoring found < AL
Drilling holes in concrete or masonry
Other tasks involving silica exposure done by carpenters, plumbers, and electricians
“occasional, brief exposures to” RCS
Their data was below the action level for these specific tasks.
Using RCS as an abbreviation for respirable crystalline silica or I’d be tripping over that term all day!

10. OSHA’s Objective Data
Dry drilling on a wall on lower level of a concrete parking garage with poor air circulation
300 micrograms/m3, 15 minutes
19 micrograms/m3 8-hour TWA
OSHA’s objective data that you can incorporate for your use…

11. OSHA - Drywall Finishing
Per the Preamble, not included in Table 1
<0.5% silica found in drywall compounds from retail stores tested by NIOSH
Use silica-free materials or engineering controls
OSHA tested “commercially available products” and found that they were labled silica free and had less than
.5% silica

12. Table 1 “Fully and properly implemented”
Not required to separately comply with PEL, exposure assessment, or methods
Fully and properly means just that!

13. (c)(1) Table 1
18 instances of equipment/task, engineering and work practice controls, and respiratory protection with APF
Water delivery systems, dust collection, and HEPA-filtered vacuums.
99% or greater efficiency or filter-cleaning mechanisms specified
Table 1 has 18 tasks…
Specifies such things as water delivery…

14. Table 1 – Suggested Approach
Identify tasks that could expose employees to RCS
Compare task list to Table 1
Implement Table 1 controls
Suggest using contract language to ensure subs responsible for following Table 1
Here’s my suggestion to approach the standard and the revised Table 1…

15. (c)(1) Table 1
Indoor or enclosed area tasks require means of exhaust to minimize accumulation of “visible airborne dust”
Work practice controls to limit entry to indoor/enclosed areas with RCS exposure
GC//Area ventilation? Business decision.
This could be a pain point for many of you when implementing the requirements of the final rule…

16. Emphasis on Engineering
Reliable, predictable, consistent
Can monitor continually and easily
Not susceptible to human error
Lowers exposure for others
Throughout the Preamble and standard, the focus is appropriately on engineering and work practice (administrative) controls FIRST, then PPE.

17. Wet/HEPA Methods Not safe and effective in all situations
Standard allows for dry sweeping, dry brushing, or compressed air for cleaning
OSHA expects this to be “extremely limited”
Must use ventilation + compressed air
OSHA received many comments that these methods are not…
We’ll talk about this later in best practices…

18. Alternative Exposure Control
When tasks are not listed on Table 1
When employer does not “fully and properly implement” Table 1 controls
These procedures should be followed when…

19. Alternative Exposure Control
Performance Option
Assess 8-hour TWA for each employee using air monitoring and/or objective data
Option one is the performance option, the other option is called the Scheduled Monitoring Option.
The difference is conducting exposure monitoring for EACH exposed EMPLOYEE or a representative or area sample.

20. Alternative Exposure Control
Scheduled Monitoring Option (part 1)
Initial 8-hour TWA for each employee, 1 or more breathing zone samples, each shift, each job, each work area
Representative samples may be done

21. Alternative Exposure Control
Scheduled Monitoring Option (part 2)
If initial monitoring < Action Level, discontinue monitoring.
If at or above AL, but at or below PEL, repeat within 6 months.
If above PEL, repeat monitoring w/in 3 months
This is a lot of monitoring and recordkeeping. This would most likely be outsourced to a third party IH vendor, as most of you probably do not have your own IH people or equipment capable of such monitoring in-house

22. Alternative Exposure Control
Scheduled Monitoring Option
Most recent, non-initial below AL, repeat within 6 months until 2 consecutive measurements, 7 or more days apart, are <AL
Monitoring can then be discontinued unless otherwise required.

23. Alternative Exposure Control
Scheduled Monitoring Option
Reassess when changes in production, process, controls, personnel, or work practices could result in new or + exposures or if exposures could have occurred.
Labs must follow Appendix A.

24. Employee Notification
Within five working days
In writing
Post results
Include corrective actions when over PEL
For either monitoring option, employees must be notified of the results.

25. Written exposure control plan
(g)
Written exposure control plan

26. Identification of Tasks
Tasks that involve RCS exposure
Use current scope, tasks, JHA/JSAs

27. Description of Controls
Refer to Table 1
For tasks not on Table 1, indicate controls that will be used and where/if engineering controls are not feasible

28. Controls Engineering and work practice controls unless not feasible
If controls do not reduce exposure to at or below PEL = respiratory protection

29. (Respiratory Protection)
Comply with when Table 1 requires respirators
Wear when Table 1 controls not fully and properly implemented
Wear when installing or implementing feasible engineering and work practice controls
When PEL is exceeded
Make sure your respiratory protection program is up to date and covers respiratory protection worn per Table 1 and other RCS related work.

30. (Respiratory Protection)
Employer is in compliance when respiratory protection is worn as prescribed in Table 1 and following
I’ve inserted some images that accompanied OSHA material for the RCS standard so you can see what’s out there…

31. Housekeeping Measures
Include any instances that compressed air, dry sweeping, or dry brushing will be used.

32. Procedures to Restrict Access
Multi-Employer Worksites
OSHA expects employers or competent person(s) to work with GC to avoid high exposures of employees working alongside others generating RCS.
OSHA suggestion: work scheduling to avoid exposure
Again, going back to engineering and work practice controls first before PPE

33. Review & Availability of Plan
Indicate how plan will be available for viewing, copying, etc by employees, designees, OSHA
Review as operations change…

34. Competent Person
Designate a CP who can implement the employer’s written exposure control plan regardless of size of employer
Smaller companies may need more people trained to competency level
Smaller companies may need more people trained to this competency level because they are often the sole representative for the employer on a site, thus, they must be able to implement the employer’s written exposure control plan.

35. Respirable Crystalline Silica
Summary

36. Exposure Control Program
Identify tasks with RCS
Compare the tasks to Table 1
Update Respiratory Protection Program if needed
Implement Alternative Controls
Conduct training
Evaluate & Adjust

37. Resources
Special Emphasis Program (1996), Silica eTool:
ASTM E Standard Practice for Controlling Occupational Exposure to RCS for Construction and Demolition Activities:

38. Resources
CPWR Create-A-Plan

39. Thank You