Protecting Workers Exposed to Respirable Crystalline Silica Annette Iannucci and David O’Connor OSHA Alliance Program Construction Roundtable September 12, 2013

OSHA’s Proposed Crystalline Silica Rule  Published in Federal Register today  Will improve protections for 2.2 million workers  Will save nearly 700 lives and prevent over 1,600 cases of silicosis annually once full effects are realized

Reasons for the Proposed Rule  Current Permissible Exposure Limits (PELs) are formulas that many find hard to understand  Construction/shipyard PELs are obsolete particle count limits  General industry formula PEL is about equal to 100 µg/m 3 ; construction/shipyard formulas are about 250 µg/m 3

Exposure and Health Risks  Current PELs do not adequately protect workers  Exposure to respirable crystalline silica has been linked to: –Silicosis; –Lung cancer; –Chronic obstructive pulmonary disease; and –Kidney and immune system disease Healthy Lung Lung with Silicosis

Construction Activities that Generate Airborne Respirable Particles  Chipping  Cutting (Sawing)  Drilling  Abrasive blasting  Grinding  Sanding  Polishing  Crushing  Tuckpointing

OSHA’s Proposed Rule  Two proposed standards: –One for General Industry and Maritime –One for Construction  Offers common sense, flexible approaches for employers  Similar to other OSHA health standards, ASTM consensus standards, industry guidelines

OSHA’s Proposed Rule (cont.)  Establishes new PEL of 50 μg/m 3  Includes provisions for: –Measuring worker exposures to silica; –Limiting access to areas where workers could be exposed above the PEL; –Use of dust controls; –Use of respirators when necessary; –Medical exams for highly exposed workers; –Worker training; and –Recordkeeping.

Flexibility for Exposure Measurements  Initial exposure measurement  Periodic assessment by: - Fixed schedule option - Performance option – assess asnecessary to adequately characterize exposures  Exposure monitoring not required for construction employers who choose to implement dust controls listed in Table 1

Measuring Silica Exposures  Allows for use of OSHA, NIOSH, or MSHA methods for sampling and analysis  Flexibility in using dust samplers – any that are designed to conform to ISO-CEN  Use of accredited labs that follow certain quality assurance procedures to ensure reliable measurements

Flexibility for Dust Controls  Employers can use any dust or work practice controls to limit exposures to the PEL  Respirators permitted where PEL cannot be achieved with engineering and work practice controls

Additional Flexibility for Construction Employers  Table 1 in the construction standard matches tasks with effective dust control methods and respirators.  If employers choose to follow Table 1: –They would not have to determine worker exposures to silica –They would have to offer medical exams to workers doing tasks that require respirators for more than 30 days a year

Table 1 Example Table 1. Exposure Control Methods for Selected Construction Operations Operation Engineering and Work Practice Control Methods Required Air- Purifying Respirator (Minimum Assigned Protection Factor) ≤ 4 hr/day > 4 hr/day Using Stationary Masonry Saws Use saw equipped with integrated water delivery system. (Plus additional specifications) None Half- Mask (10)

Operations Included in Table 1  Using stationary masonry saws  Using hand-operated grinders  Tuckpointing  Using jackhammers and other impact drillers  Using rotary hammers or drills  Operating vehicle- mounted drilling rigs  Milling  Using handheld masonry saws  Using walk-behind or drivable masonry saws  Rock crushing  Drywall finishing  Use of heavy equipment during earthmoving

Medical Surveillance  Covers workers exposed above PEL for 30 or more days per year  Initial exam followed by periodic exam every 3 years  Exam includes medical and work history, physical exam, chest X-ray, and pulmonary function test (TB test on initial exam only)

Consistency with Consensus Standards  Voluntary consensus standards have been adopted for general industry (ASTM E 1132 – 06) and construction (ASTM E 2626 – 09).  These voluntary standards include provisions for exposure measurement, use of dust controls, respiratory protection, medical surveillance, and training.  Medical surveillance provisions also largely consistent with NISA recommendations

Estimates of Those Affected by Proposed Rule  2.2 million workers −1.85 million in construction; −320,000 in general industry and maritime  534,000 establishments −477,000 in construction −57,000 in general industry and maritime

Health Benefits of Rule Nearly 700 fatalities avoided annually (560 in construction) - Lung cancer:165 - Silicosis and other non-cancer lung diseases:381 - End-stage kidney disease:153 Over 1,600 silicosis cases avoided annually (over 1,080 in construction)

Costs per Workplace  Costs per establishment are relatively modest  Average annual costs per workplace: −Average workplace: $1,242 −Average workplace with less than 20 employees: $550

Public Participation  OSHA welcomes public input on the proposed silica rule. –Written comments –Public hearings –Post-hearing comments  Comments and testimony are carefully considered  OSHA’s final rules are based on evidence in the record as a whole

Additional Information Additional information on the proposed rule is available on OSHA’s Silica Rulemaking webpage at

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