How Will Silica Exposure Considerations Change the Concrete Product Industry? NCMA Annual Convention and MCPX Anaheim, CA February 23, 2006 Kevin Campbell, CIH, CSP, CEM CIH Service, LLC – Nashville, TN

copyright © 2006 CIH Service, LLC Efforts are currently underway to establish an OSHA standard for Crystalline Silica

copyright © 2006 CIH Service, LLC Current Respirable Silica Permissible Exposure Limit  Based upon formula: = 10 milligrams/meter 3 (% Silica + 2)  Controls silica to ~ 0.1 mg/m 3 (when respirable dust is 100% silica)

copyright © 2006 CIH Service, LLC History of Current Standard  1970 – PEL formula adopted by OSHA from 1969 ACGIH TLV  OSHA established a “fixed” PEL at 0.1 mg/m 3 for respirable quartz  Fixed PEL was vacated

copyright © 2006 CIH Service, LLC Silica Control History  August 1996 – OSHA Special Emphasis Program (SEP) started  October 1996 – International Agency for Research on Cancer (IARC) listed silica as “Carcinogenic to Humans”  present. Silica standard on OSHA Unified Agenda  SBREFA report completed

copyright © 2006 CIH Service, LLC Current Status of Silica Rulemaking Process  Pre-Rule Stage  Next Target Date = April 2006 Complete Peer Review of Health Effects and Risk Assessment due

copyright © 2006 CIH Service, LLC Future Actions Still Needed  Advanced Notice of Proposed Rulemaking (ANPR) must occur  Notice of Proposed Rulemaking  Public Comment period  Public Hearing  Post-Hearing Comment period  Final Rule must be published in the Federal Register  Phase-in period for Compliance

copyright © 2006 CIH Service, LLC Other Crystalline Silica Exposure Standards  NIOSH REL = 0.05 mg/m 3  ACGIH TLV = mg/m 3  NIOSH and ACGIH do NOT consider economic impact on business community to meet the standards recommended

copyright © 2006 CIH Service, LLC Draft Proposed Crystalline Silica PEL  0.1 mg/m 3 with 0.05 mg/m 3 medical Action Level  mg/m 3 with 0.04 mg/m 3 medical Action Level  0.05 mg/m 3 with no medical Action Level

copyright © 2006 CIH Service, LLC Monitoring  Initially (Exception for abrasive blasters in type CE abrasive blasting respirators or employers with objective data)  Quarterly if greater than PEL  Every 6-months if greater than Action Level  Observation of Monitoring and Employee Notifications

copyright © 2006 CIH Service, LLC Regulated Areas  Required for areas that exceed or are reasonably expected to exceed the PEL  Established by “Competent Person”  Demarcated with signs, barriers or negative pressure enclosures

copyright © 2006 CIH Service, LLC Competent Person  Definition – one who has the knowledge to identify and evaluate existing and predictable crystalline silica hazards in the workplace and who has authorization to take corrective measures to control employee exposure to crystalline silica  Designated for each worksite

copyright © 2006 CIH Service, LLC Competent Person Responsibilities  Evaluate exposures and existing controls  Implement corrective measures, including temporary work stoppage  Define, demarcate and check Regulated areas  Inspect Abrasive Blasting activities  Communicate with other employers at the worksite to inform of regulated area boundaries around abrasive blasting operations

copyright © 2006 CIH Service, LLC Prohibited Practices  Job rotation  Use of compressed air, brushing or dry sweeping for cleaning  Eat, drink or use tobacco in regulated areas  Remove dust from clothing by blowing or shaking  Abrasive Blasting using Silica in enclosed areas

copyright © 2006 CIH Service, LLC Abrasive Blasting  Only in Regulated areas  Type CE, continuous flow respirator (hood or helmet)  Blasting areas cleaned using:  HEPA vacuums  Wet Methods  Dust suppressants  If dry blasting with sand in an open area, alternative blast medias must be evaluated

copyright © 2006 CIH Service, LLC Personal Protective Equipment  Respirators required for employees exposed above the PEL  Or for those who request it

copyright © 2006 CIH Service, LLC Protective Work Clothing  New disposable clothing provided each day  Non-disposable clothing such as coveralls or full bodied clothing

copyright © 2006 CIH Service, LLC Hygiene Facilities  Change rooms  Only authorized employees allowed to remove non-disposable clothing for laundering, maintenance or disposal  Contaminated clothing placed and stored in closed containers labeled with Silica hazard warning labels  Laundry service must be informed of potential silica contamination including harmful effects  Contaminated clothing transported in sealed impermeable bags with hazard label

copyright © 2006 CIH Service, LLC Shower Facilities  Considered as an option for those exposed above the PEL  May require employer to ensure employees shower at the end of each work shift

copyright © 2006 CIH Service, LLC Lunchrooms  Must be below the PEL  May require temperature controlled, positive pressure, filtered air supply for lunchrooms  May require HEPA filtered vacuums for cleaning clothes before entering lunchrooms, change rooms or shower rooms

copyright © 2006 CIH Service, LLC Housekeeping  HEPA vacuum Silica accumulations  Prevent accumulation of silica- contaminated water that could dry and result in residue that could contribute significantly to airborne exposures

copyright © 2006 CIH Service, LLC Health Screening  Offered initially and annually for all exposed above the Action Level (or PEL if 0.05 mg/m 3 )  Before assignment to tasks above Action Level  Whenever employee reports silica related symptoms  Within 30 days of termination

copyright © 2006 CIH Service, LLC Health Screening Content  Occupational and health history with emphasis on silica exposures and other respiratory agents  Physical exam with emphasis on respiratory system  Chest X-Ray  Pulmonary Function Test (PFT)  Any other tests deemed necessary by the HCP  Annual review of history and physical exam with emphasis on respiratory system

copyright © 2006 CIH Service, LLC Health Screening Info Employer Provides to HCP  Description of employee’s job as it relates to silica  A copy of paragraph (k), Employee Health Screening section of the standard  Results from employee exposure monitoring  Results of previous health screening  A description of PPE

copyright © 2006 CIH Service, LLC HCP Written Opinion  Shared with employee within 15 days  Must include: Employee Health condition related to silica. Non-silica findings must remain confidential from the employer  A statement whether employee should be referred to a pulmonary specialist. A list of three reasonably accessible pulmonary specialists must be provided if referred for additional testing  A statement HCP has informed employee of silica screening results

copyright © 2006 CIH Service, LLC Pulmonary Specialists  Employer must make one choice available from the list provided by the HCP  Written opinion must be obtained within 30-days of examination  Copy of results to employee within 15-days

copyright © 2006 CIH Service, LLC Pulmonary Specialists (continued)  Specialists written opinion must include:  Employee health condition related to silica  Recommended work limitations, such as restrictions or removal with probable durations  Statement results were shared with employee  Employer must report all cases of silica-related disease identified by the pulmonary specialist to NIOSH

copyright © 2006 CIH Service, LLC Hazard Communication  All employees potentially exposed are informed and trained initially, prior to assignment  Must be informed on the requirements of the silica standard and how to access or obtain a copy

copyright © 2006 CIH Service, LLC Recordkeeping  Historical or objective data  Exposure Measurements–30 years  Health Screening Records–Employment+30 years  Respirator Fit Test Records-most current  All records may be kept in any form  Available upon request to Asst. Secretary, subject employee or qualified representative  Provision for transfer of records upon sale or close of business

copyright © 2006 CIH Service, LLC Some Items that Were NOT Included  Written Control Plan  Medical Removal Provisions  Consideration for Non-standard work shifts (greater than 8-hours)

copyright © 2006 CIH Service, LLC Potential Impacts  At PEL of 0.1 mg/m 3 :  Estimated ~⅓ may have overexposure areas or tasks Dry sanding, sawing, abrasive blasting and mixer cleaning tasks produce most overexposures  Most can be controlled through improved housekeeping, work practices and ventilation

copyright © 2006 CIH Service, LLC At PEL of mg/m 3  Estimated ~½ of workplaces may have tasks or areas with overexposures  In addition to tasks that exceeded 0.1 mg/m 3, other tasks such as additive mixing, material loading/unloading may produce overexposures, especially in open cab mobile equipment

copyright © 2006 CIH Service, LLC At a PEL of 0.05 mg/m 3  MIOSHA 2004 Annual Report on Silicosis - 60% of workplaces sampled in excess of NIOSH REL or PEL at 0.05 mg/m 3 (Note- Data summarized for all inspected business!)  Regulated areas now extend into more areas  Control options include automation, control rooms, enclosures, isolation, closed cabs on mobile equipment, wet methods for cleaning, part-time work shifts (4-6 hours duration)…  Respirators!

copyright © 2006 CIH Service, LLC Example of Compliance Costs with PEL at 0.1 mg/m 3 Plant employs 20 laborers with 1/3 Above PEL and 1/3 Above Action Level = 12 employees Analytical costs for quarterly and Semi- Annual monitoring = $3,360 Signs for Regulated areas = $14 minimum for 2 signs 85 boxes/yr of 3M 8210 N95 disposable dust masks = $1,154

copyright © 2006 CIH Service, LLC Compliance Costs (continued) Baseline Health Screening = $2,160 ($180 per employee for 12 employees) –$35 Physical –$65 PFT –$80 Chest X-Ray Year1 and Year2 = $1200 (Physical and PFT only…Chest X-ray every 3 rd Year) Estimate does not include time away from work!

copyright © 2006 CIH Service, LLC Compliance Costs (continued) Annual Fit Tests and Training = $120 (~$20 per employee) Disposable Protective Clothing = $5,595 ($3.73 per employee per day) HAZ-COM Training = $160 Recordkeeping = $60 Minimum Annual Total ~ $12,000 per facility

copyright © 2006 CIH Service, LLC Other Costs Lunchroom facilities Lunchroom HVAC Lunchroom HEPA vacuums Shower Facilities Uniforms Laundry Service, or Washer/Dryer eqt. Utility Costs Dust Collectors or other Local Exhaust HEPA Vacuum for Work Areas Rent or buy sampling equipment Quarterly Survey by Consultant Miscellaneous costs (laundry bags and labels, S&H samples, communications, etc.)

copyright © 2006 CIH Service, LLC Compliance Costs Per Facility Minimum ~$12,000/year Costs go up significantly if Facility Changes are needed for Lunchrooms, Shower facilities and Exhaust Ventilation (add~ $10K-$500K)

copyright © 2006 CIH Service, LLC Recommendations for Action!  Evaluate your workplace!  Formulate a silica exposure control plan!  Communicate with your NCMA representatives on how this would impact your business!  Communicate with your elected officials to educate them on silica issues!

copyright © 2006 CIH Service, LLC Summary  A specific OSHA silica standard may cause significant changes in Concrete Products industry  As the PEL is reduced, more areas would require actions and additional expense

copyright © 2006 CIH Service, LLC