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

1. Safety First. Quality Always.
Executive Summary
Discuss Silica Sources and Construction Activities
Review OSHA’s Standard
Present Potential Impacts and Opportunities for Contractors
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2. 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
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3. Safety First. Quality Always.
Where is Silica Found?
Naturally Occurring
Quartz – 2nd most common mineral in earth’s crust
Granite % quartz
Shale %
Beach sand >90%
Manufactured products:
Concrete products
Bricks and blocks
Abrasive blasting materials
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4. 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.

5. 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
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6. 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
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7. 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)
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8. Silica as a Significant Health Hazard
By 1930, silicosis was “the most serious occupational disease”
“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
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9. 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
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10. 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
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11. 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
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12. Silica Effects to the Lungs
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13. Safety First. Quality Always.
OSHA’s Standard
“Occupational Exposure to Respirable Crystalline Silica” standard ( ) - published in FR 9/12/13
Why Needed According to OSHA?
Current PELs outdated…adopted in 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
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14. 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
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15. 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
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16. 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.
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17. 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” (?)
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18. 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
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19. Safety First. Quality Always.
OSHA’s Standard
f) Methods of compliance
Feasible Engineering/Work Practice Controls
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20. 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
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21. 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.
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22. 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 (2009)
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23. 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.
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24. 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.

25. 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.

26. 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.

27. 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.

28. 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.

29. 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.

30. Safety First. Quality Always.
OSHA’s Standard
g) Respiratory Protection
Consistent w/
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
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31. 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)
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32. 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
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33. 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.

34. Safety First. Quality Always.
Questions?
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