Welcome Revised Silica Regulation Overview & Region III Focus Four Campaign Will begin at 10:30am To join Teleconference Call-in Number: 571-392-7703 Participant Pin: 550 851 809 628 # Presented by: Dane Sprankle Pennsylvania OSHA Consultation Office Phone: 800-382-1241 or 724-357-4095 Web: www.iup.edu/pa-oshaconsultation

Revised Silica Regulation Overview & Region III Focus Four Campaign Webinar General Info Recorded PowerPoint Presentation Q&A To join Teleconference Call-in Number: 571-392-7703 Participant Pin: 550 851 809 628 # PA OSHA Consultation Program Website www.iup.edu/pa-oshaconsultation

Revised Silica Regulation Overview & Region III Focus Four Campaign Questions Chat is open to submit questions Due to the technical nature of most questions requiring extensive responses, chat questions will not be answered live Answers will be posted on our website within seven days after the webinar  

WEBINAR OBJECTIVES Provide an overview of OSHA’s revised silica regulations Compliance dates Key requirements Not a comprehensive review Provide a description of OSHA’s Region III Focus Four Campaign

Revised Silica Regulation Overview

Why Revisions? Better toxicology data Continuing health problems Modern exposure control technology

Standards General Industry and Maritime – 29 CFR 1910.1053 Construction – 29 CFR 1926.1153

DATES Effective Date of Final Rule - 6/23/2016 Compliance dates: General industry / Maritime 6/23/2018 – All obligations except medical surveillance 6/23/2020 – Medical surveillance

DATES Compliance Dates Cont’d: Hydraulic Fracturing in oil/gas industry 6/23/2018 – All obligations except engineering controls and medical surveillance 6/23/2020 – Medical surveillance 6/23/2021 – Engineering controls

DATES Compliance Dates Cont’d: Construction 6/23/2017 – All obligations except methods of sample analysis 6/23/2018 – Methods of sample analysis

GENERAL INDUSTRY/MARITIME 29 CFR 1910.1053 https://www.osha.gov/silica/SilicaGeneralIndustryRegText.pdf Applies to all occupational exposures to respirable crystalline silica, except: Construction work Agricultural operations Processing of sorptive clays Objective data (if exp.< A.L) In compliance with 29 CFR 1926.1153 provided that: Listed construction task, and Non-routine

INDUSTRY EXAMPLES Glass manufacturing Pottery products Concrete products Foundries Dental laboratories Paintings and coatings Jewelry production Refractory products Abrasive blasting in maritime, construction, and general industry Oil and gas operations Cut stone and stone products Many more…

KEY PROVISIONS Exposure Limits Current limit – “Respirable dust containing crystalline silica” Variable Permissible Exposure Limit (PEL) = 10 mg/m3 % silica in sample + 2 Revised limits – Respirable crystalline silica No variation Action Level = 25 μg/m3 Permissible Exposure Limit (PEL) = 50 μg/m3

KEY PROVISIONS, Cont’d Exposure Assessment Performance Option Any combination of objective data and air monitoring Scheduled Monitoring Option Initial monitoring Repeat monitoring: 3 months if > PEL 6 months if > AL Discontinuing monitoring

KEY PROVISIONS, Cont’d Regulated Area Exposure > PEL Demarcation Signage Access limited Respiratory protection

REGULATED AREA - SIGNAGE DANGER RESPIRABLE CRYSTALLINE SILICA MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS WEAR RESPIRATORY PROTECTION IN THIS AREA AUTHORIZED PERSONNEL ONLY

KEY PROVISIONS, Cont’d Methods of Compliance Engineering and Work Practice Controls Written Exposure Control Plan Abrasive blasting

KEY PROVISIONS, Cont’d Engineering and Work Practice Controls Best option Feasible Mandatory respirator if exp. > PEL Examples: Product substitution Wet methods Isolation (employee/process) Local exhaust / capture systems General ventilation

KEY PROVISIONS, Cont’d Written Exposure Control Plan Established Updated annually Describes: Covered tasks Exposure controls Housekeeping measures

KEY PROVISIONS, Cont’d Abrasive Blasting – additional regulations Application Abrasive blasting agents containing crystalline silica Substrates containing crystalline silica Regulations 29 CFR 1910.94 (Ventilation) 29 CFR 1915.34 (Mechanical paint removers) 29 CFR 1915 Subpart I (Personal Protective Equipment

KEY PROVISIONS, Cont’d Respiratory protection Meeting 29 CFR 1910.1053 and 29 CFR 1910.134 Required where: Exposures > PEL Installing or implementing engineering/work practice controls Engineering/work practice controls not feasible e.g. Certain maintenance tasks Feasible engineering/work practice controls insufficient Regulated areas

KEY PROVISIONS, Cont’d Housekeeping No dry sweeping/brushing unless: Wet sweeping, HEPA-filtered vacuuming or other methods not feasible No compressed air cleaning unless: Used in conjunction with an effective ventilation system that captures the dust, or No alternative method is feasible

KEY PROVISIONS, Cont’d Medical surveillance Application Exposure > A.L. for 30 or more days per year Examination schedule Baseline within 30 days of initial assignment At least every 3 years Additional examinations (i.e. specialists) if recommended by PLHCP

KEY PROVISIONS, Cont’d Medical surveillance, cont’d Examination content Medical and work history Physical examination Chest X-Ray Pulmonary function test Tuberculosis test

KEY PROVISIONS, Cont’d Hazard communication Include in hazard communication program Ensure access to: Safety Data Sheets Labels The following hazards must be addressed: Cancer Lung effects Immune system effects Kidney effects

KEY PROVISIONS, Cont’d Employee information and training Specific training topics: Health hazards Covered tasks Exposure controls Contents of the standard, and Medical surveillance

KEY PROVISIONS, Cont’d Record-keeping In accordance with 29 CFR 1910.1020 Air monitoring data Objective data (if applicable) Medical surveillance

CONSTRUCTION 29 CFR 1926.1153 https://www.osha.gov/silica/SilicaConstructionRegText.pdf All exposures to respirable crystalline silica in construction work, except: Objective data (if exp.< A.L) "Construction work" means “work for construction, alteration, and/or repair, including painting and decorating”

Primary Differences from General Industry/Maritime Standard Compliance dates Written exposure control plan Competent person Specified exposure control methods Medical surveillance trigger Employee notification of monitoring results

COMPLIANCE DATES 6/23/2017 – All obligations except methods of sample analysis 6/23/2018 – Methods of sample analysis

WRITTEN EXPOSURE CONTROL PLAN Similar to GI/Maritime with following additional requirements: Describes procedures to: Restrict access to work areas Minimize number of employees exposed and exposure levels Includes exposures generated by other employers Designates a competent person to: Inspect Ensure implementation of plan

COMPETENT PERSON “An individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them”

SPECIFIED EXPOSURE CONTROL METHODS 18 common tasks/equipment described Controls and respirator requirements specified Full implementation required Tasks not listed or failure to implement fully: Must assess and control exposures per paragraph (d)

TABLE 1 EXAMPLE TABLE 1: SPECIFIED EXPOSURE CONTROL METHODS WHEN WORKING WITH MATERIALS CONTAINING CRYSTALLINE SILICA Equipment/Task Engineering and Work Practice Control Methods Required Respiratory Protection and Minimum Assigned Protection Factor (APF) ≤ 4 hours /shift > 4 hours/shift 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. None

ADDITIONAL REQUIREMENTS When implementing control measures specified in Table 1: Tasks performed indoors or in enclosed areas Adequate ventilation to minimize visible airborne dust Tasks using wet methods Flow rates sufficient to minimize release of visible dust

ADDITIONAL REQUIREMENTS, Cont’d Table 1 cont’d Enclosed cab/booth requirements: Free from settled dust Door seals/closing mechanisms maintained Gaskets/seals working properly Positive pressure with continuous fresh air Filtered intake air Climate controlled

MEDICAL SURVEILLANCE TRIGGER Respirator required 30/more days per year GI based on action level

NOTIFICATION OF MONITORING RESULTS General Industry / Maritime Notify in writing within 15 working days after exposure assessment Individually, or Post where accessible to all affected employees Construction Notify in writing within 5 working days after exposure assessment

OSHA’s “FOCUS FOUR HAZARDS” CAMPAIGN

What is it? Joint effort by OSHA and construction industry partners in Region III Four month program started in February of this year Focusing on the four leading hazards resulting in construction fatalities: Falls Electrocutions Struck by object, and Caught-in/between

“FOCUS FOUR HAZARDS” CAMPAIGN

“FOCUS FOUR HAZARDS” CAMPAIGN How to participate Conduct weekly toolbox talks (provided via email) Share the program with colleagues, trade groups, etc. Provide feedback to local OSHA Area Office in care of their Compliance Assistance Specialist

PA OSHA Consultation www.iup.edu/pa-oshaconsultation

OSHA On-site Consultation Program Designed specifically for small-and medium-size businesses 250 employees at a single site or 500 corporate wide Priority assistance given to: employers in high-hazard industries involved in hazardous operations Large business requests honored as well…but limited scope www.iup.edu/pa-oshaconsultation

No Citations, No Penalties Different than OSHA enforcement Citations for violations… are not issued Penalties for violations… are not imposed Employer Obligations Employer must agree to correct any “serious or imminent danger” hazards identified Must refer to OSHA Enforcement if employer refuses to correct hazards…very rare! www.iup.edu/pa-oshaconsultation

Costs and Savings Free of charge Avoided OSHA penalty and litigation costs Reduced workers compensation costs Minimized equipment damage and product losses One consultant identifies an average of 7 serious and other-than-serious hazards, SAVING the employer approximately $87,000 in OSHA fines per visit www.iup.edu/pa-oshaconsultation

Contact us Pennsylvania OSHA Consultation Office 57 South 9th Street Suite 305 Indiana, PA 15701 Phone: 800-382-1241 Fax: 724-357-2385 Web: www.iup.edu/pa-oshaconsultation/ Facebook: https://www.facebook.com/Pennsylvania-OSHA-Consultation-Program-548810235234647/ Twitter: https://twitter.com/search?q=PA%20OSHA%20Consultation&src=savs

Questions Upcoming Webinar: Fall Protection in Construction May 9, 2017 @ 10:30am Pennsylvania OSHA Consultation Office Phone: 800-382-1241 or 724-357-4095 Website: www.iup.edu/pa-oshaconsultation