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

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.

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

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

Where to find the rule 606 pages, final rule + preamble https://www.federalregister.gov/articles/2016/03/25/2016-04800/occupational-exposure-to-respirable-crystalline-silica 26 page regulatory text https://www.osha.gov/silica/SilicaConstructionRegText.pdf The regulatory text will be officially published in the usual easy to read format at www.osha.gov on June 23, 2016 – for now, you can access it via these links.

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.

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

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”

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!

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…

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

Table 1 “Fully and properly implemented” Not required to separately comply with PEL, exposure assessment, or methods https://theferrigroup.co/resources/ Fully and properly means just that!

1926.1153(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…

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…

1926.1153(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…

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.

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…

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…

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.

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

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

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.

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.

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.

Written exposure control plan 1926.1153(g) Written exposure control plan

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

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

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

(Respiratory Protection) Comply with 1910.134 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.

(Respiratory Protection) Employer is in compliance when respiratory protection is worn as prescribed in Table 1 and following 1910.134 I’ve inserted some images that accompanied OSHA material for the RCS standard so you can see what’s out there…

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

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

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

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.

Respirable Crystalline Silica Summary

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

Resources Special Emphasis Program (1996), Silica eTool: https://www.osha.gov/dsg/etools/silica/spec_emph_prog/spec_emph_prog.html ASTM E2625-09 Standard Practice for Controlling Occupational Exposure to RCS for Construction and Demolition Activities: http://www.astm.org/Standards/E2625.htm

Resources CPWR Create-A-Plan http://plan.silica-safe.org/

Thank You