UNDERSTANDING OSHA’S SILICA STANDARD January, 2017 UNDERSTANDING OSHA’S SILICA STANDARD STEPHEN REYNOLDS, CSHM, CSSM

Safety First. Quality Always. Executive Summary Discuss Silica Sources and Construction Activities Review OSHA’s Standard Present Potential Impacts and Opportunities for Contractors Safety First. Quality Always.

Safety First. Quality Always. What is Silica? “Silica” - refers to silicon dioxide Exists in crystalline or amorphous form Crystalline silica - more hazardous - occurs as quartz, cristobalite or tridymite Safety First. Quality Always.

Safety First. Quality Always. Where is Silica Found? Naturally Occurring Quartz – 2nd most common mineral in earth’s crust Granite 20 - 70% quartz Shale 5 - 20% Beach sand >90% Manufactured products: Concrete products Bricks and blocks Abrasive blasting materials Safety First. Quality Always.

Silica Exposures in Construction Some construction tasks with exposure: Abrasive/sand blasting (High Risk) Rock drilling (High Risk) Stone, brick, and concrete block cutting, blasting, chipping, grinding, and sawing (DRY WALL) Cement/concrete mixing or cutting Demolition Jack hammer operations Safety First. Quality Always.

Silica Exposures in Drywall Sanding drywall joint compound: NIOSH Health Hazard Evaluation (HHE) found that drywall sanders were exposed to as much as 10 times the permissible exposure limit (PEL)  Vacuum Sanding Systems Containment/ Clean up when done for the day or project Safety First. Quality Always.

Silica Exposures in Construction Industries and Contractors Impacted: Building Construction Concrete & masonry contractors Demolition Earthwork and rock crushing/drilling Road construction and repair Abrasive blasting (sand blasting) Oil & Gas - fracking OSHA estimates 2.2 M workers exposed to silica – 1.8 M in Construction Safety First. Quality Always.

Silica as a Significant Health Hazard One of oldest known occupational diseases Earliest reports date back to ancient Egypt & Greece Recognized in 1930’s as a hazard The first silica standard was set in 1971 when OSHA was formed (does not adequately protect the worker) Safety First. Quality Always.

Silica as a Significant Health Hazard By 1930, silicosis was “the most serious occupational disease” 1930-1931 “Hawk’s Nest Tragedy” Near the Gauley Bridge in WV Union Carbide & local power company project Dug 3-mile tunnel thru silica-rich material Most workers poor, uneducated Of 3,000 workers 764 died and 1,500 developed silicosis Safety First. Quality Always.

Safety First. Quality Always. What is Silicosis? Symptoms Dry, non-productive cough Initial breathlessness during exercise, which progresses to shortness of breath during normal activity Progresses to lung scarring and failure Diagnosis Incurable Causes significant impairment or death Miner's lung with silicosis Safety First. Quality Always.

Safety First. Quality Always. Silicosis Acute silicosis (1-3 yrs.) Accelerated silicosis (3-10 yrs.) - 36-yr old, sandblasted for 36 months, died 11 yrs. after exposure - 30-yr old, sandblasted for 48 months, died 10 yrs. after exposure Chronic silicosis (7-25 yrs.) Healthy Lung Scarred Lung Silicosis is a single disease w/single cause – breathing crystalline silica dust Safety First. Quality Always.

Other Health Hazards of Silica Occupational Carcinogen IARC Group 1 for lung cancer Similar to benzene, asbestos and vinyl chloride Some evidence of “synergy” w/cigarette smoking Also linked with: Tuberculosis, emphysema, and pneumonia Stomach and other cancers Safety First. Quality Always.

Silica Effects to the Lungs Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard “Occupational Exposure to Respirable Crystalline Silica” standard (1926.1053) - published in FR 9/12/13 Why Needed According to OSHA? Current PELs outdated…adopted in 1971 and not protective of workers Since 1971 NTP, IARC, and NIOSH have identified silica as a carcinogen OSHA estimates that the proposed rule will save nearly 700 lives and prevent 1,600 new cases of silicosis/yr Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard Similar in approach to lead and hexavalent chromium standards Scope/Application Definitions PEL Exposure Assessment (w/AL) Regulated Areas/Access Control Methods of Compliance Respiratory Protection Medical Surveillance Communication of hazards to employees (training) Recordkeeping Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard c) PEL 8 hour TWA PEL = 50 micrograms of respirable crystalline silica per cubic meter of air (50 ug/m3) – Formerly “millions of particles per cubic foot, or mppcf” PEL represents = 50-80% reduction of privios PEL levels (to 50 ug/m3 from 250 ug/m3). FYI…since 2006, ACGIH TLV has been 25 µg/m3 Monitoring Cyclone Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard d) Exposure Assessment Assess exposures for employees who may “reasonable be expected” to be at or above TWA AL = 25 ug/m3 (or ½ PEL) Initial Assessment - IH monitoring or objective data <12 months - Not required if Table 1 followed - “Employer must ensure Lab…” - “Employee Notification in 5 days” Periodic Assessment - AL< Exposure <PEL, then every 6 mos. - Exposure >PEL, then every 3 mos. Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard e) Regulated Area OR Access Control Plan Regulated Area Required >PEL Demarcation from the rest of the workplace – “in any manner that alerts employees to boundaries AND minimizes the number of employees exposed”(?) Limit access to “persons authorized and required” to be present in the RA (?) Protective work clothing – “where there is the potential for clothing to become grossly contaminated w/finely divided material” (?) Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard e) Regulated Area OR Written Access Control Plan Written Access Control Plan Required >PEL Provisions for Competent Person to “identify the presence and location of any areas where silica exposures >PEL” Procedures for notifying employees For multi-employer workplaces, methods to notify other employers - e.g., Site Safety Plan Provisions for limiting access by other employees Reviewed annually Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard f) Methods of compliance Feasible Engineering/Work Practice Controls Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard f) Methods of compliance Feasible Engineering/Work Practice Controls Saw-cutting w/o water Saw-cutting w/water Safety First. Quality Always.

Safety First. Quality Always. OSHA Chat – 1/14/14 Q How will this regulation ensure that the hierarchy of controls is the basis of the entire program? A As with all OSHA Health Standards, the rule requires employers to implement engineering and work practice controls before requiring employees to wear PPE, such as respirators. Q Who decides when enough engineering controls have been implemented? A The proposed rule provides flexibility to employers in that the employer decides which engineering and work practice controls will be implemented to meet the PEL. Under the rule, the employer would be required to use feasible engineering and work practice controls to reduce employee exposures to, or below, the proposed PEL. Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard f) Methods of compliance 1st - Feasible Engineering/Work Practice Controls Table 1 for specific operations - Includes Engineering/Work Practice AND Respirator requirements - Most tasks still require ½ face APR even w/wet methods or LEV Table 1 requirements similar to OSHA 3362-05 (2009) Safety First. Quality Always.

Safety First. Quality Always. Table 1 (excerpt) NOTE: PAPR or Full face APR for all exposures NOTE: Most Task entries half-mask (10) respirator required >4 hrs. Safety First. Quality Always.

Safety First. Quality Always. Table 1 (excerpt) NOTE: PAPR or Full face APR for all exposures NOTE: Most Task entries half-mask (10) respirator required >4 hrs. Safety First. Quality Always.

Safety First. Quality Always. Table 1 (excerpt) NOTE: PAPR or Full face APR for all exposures NOTE: Most Task entries half-mask (10) respirator required >4 hrs. Safety First. Quality Always.

Safety First. Quality Always. Table 1 (excerpt) NOTE: PAPR or Full face APR for all exposures NOTE: Most Task entries half-mask (10) respirator required >4 hrs. Safety First. Quality Always.

Safety First. Quality Always. Table 1 (excerpt) NOTE: PAPR or Full face APR for all exposures NOTE: Most Task entries half-mask (10) respirator required >4 hrs. Safety First. Quality Always.

Safety First. Quality Always. Table 1 (excerpt) NOTE: PAPR or Full face APR for all exposures NOTE: Most Task entries half-mask (10) respirator required >4 hrs. Safety First. Quality Always.

Safety First. Quality Always. Table 1 (excerpt) NOTE: PAPR or Full face APR for all exposures NOTE: Most Task entries half-mask (10) respirator required >4 hrs. Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard g) Respiratory Protection Consistent w/1910.134 h) Medical Surveillance Required if exposure >PEL for 30 days/year Q - Should workers be pre-screened for silicosis? i) Communication of hazards to employees Under Hazard Communication “Each affected employee…” j) Recordkeeping Safety First. Quality Always.

Safety First. Quality Always. OSHA’s Standard Timeline First proposed change to the rule September 2013 Comment period extended until 1/27/14 Final Standard - (late June 2016, full implementation June 2017) Safety First. Quality Always.

Contractor Issues w/Proposal Cost burden for contractors potentially significant (training, eng./work practice controls, Regulated Areas/Control Access Plan, PPE, etc.) “The proposed rule is estimated to result in annual costs of about $1,242 for the average workplace covered by the rule. The annual cost to a firm with fewer than 20 employees would be less, averaging about $550.” Regulated Areas/Control Access burdensome For own employees AND for other contractor employees Safety First. Quality Always.

Silica is a known health hazard Summary Silica is a known health hazard Contractors could: Do nothing! – wait and see where this goes Do something! Evaluate silica-related tasks for impact Qualify/quantify potential exposures Consider opportunities to introduce engineering/work practice controls Consider cost implications (e.g., bids) Safety First. Quality Always.

Safety First. Quality Always. Questions? Sreynolds@harenlaughlin.com 913-228-7438 Safety First. Quality Always.