OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica....

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OSHA Respirable Crystalline Silica Standard

Transcript of OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica....

Page 1: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

OSHA Respirable Crystalline Silica Standard

Page 2: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Introduction

• OSHA has issued a standard to regulate the exposures to Respirable Crystalline Silica. The effective date is 6-23-2016.

• Standards have been issued for General Industry, Maritime and Construction.

• The implementation period for Construction is 1 year; General Industry has 2 years.

Page 3: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Introduction

• The main items that are addressed in the new standards include:- The Permissible Exposure Limit (PEL) has been changed, an Action

Level (AL) has also been established.- An exposure assessment is required where an employee can be

reasonably exposed above the AL.- Written exposure control plans are required. - Regulated areas are required for General Industry work.- Specified exposure control methods with required respiratory

protection for 18 tasks using certain equipment (Table 1).

Page 4: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Introduction

- Medical surveillance when employee is exposed 30 or more days per year. Threshold varies between standards.

- Acceptable housekeeping practices are specified. - Specific information and training requirements, including Hazard

Communication.- Recordkeeping requirements for monitoring, objective data used and

medical surveillance.

• There were several changes made from the proposed standard.

Page 5: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

General Industry vs. Construction Work

• "Construction work" means work for construction, alteration, and/or repair, including painting and decorating.

• “General Industry" to refer to all industries not included in agriculture, construction or maritime.

• Usually, if the job involves “improving”, it falls under Construction, if it involves keeping the equipment in its existing state, it will fall under General Industry.

Page 6: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

General Industry vs. Construction Work

• For EEI member companies, silica exposures in General Industry work would include (but not limited to):

- Maintenance work (including instrumentation and control work) where equipment is kept in its existing state- Operations work - Coal yard activities- Baghouse work- Routine cleaning activities

Page 7: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

General Industry vs. Construction Work• Construction activities would include (but not limited to):- Any concrete/rock/masonry disturbance where dusts would be generated. The activities would include drilling, sawing, chipping or jackhammering (possibly others) of any of these materials- Outage or other maintenance work where improvements are made- Cleaning activities in preparation for outages or other improvements - Excavation or soil disturbance- Ceramic insulation work- Abrasive blasting where silica blasting agents are used or substrate contains silica (other standards may apply)

Page 8: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Exposure Limits

• For both General Industry and Construction work, the new Permissible Exposure Limit (PEL) is 0.05 mg/m3 (50ug/m3) as an eight hour Time Weighted Average (TWA8)

• The Action Level (AL) is 0.025 mg/m3 (25ug/m3) as an eight hour Time Weighted Average (TWA8)

• The respirable dust PEL – 15mg/m3 (TWA8)

Page 9: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Exposure Limits

• The PEL for Crystalline Silica covers all types of Crystalline Silica.

• There is no minimum amount of silica concentration required for a material to fall under the standard.

• When monitoring, continue to request both Crystalline Silica and respirable dust.

Page 10: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Personal Monitoring

• Sampling for Crystalline Silica must be done using a nylon or aluminum cyclone with a 5.0um PVC filter. Respirable dust should also be sampled, therefore a pre-weighed cassette should be used.

• Follow the manufacturer’s requirements for flow rate. – Cyclone in breathing zone of worker, air inlet pointing forward, suspended

from collar

Page 11: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Personal Monitoring

• Use NIOSH Method 7602 for analyzing Crystalline Silica and NIOSH Method 0600 for Respirable Dust.

• There are other analytical methods that are acceptable.

• The new PEL is not required to be calculated in the same manner as the old PEL. The results are not depended upon the respirable dust concentration.

Page 12: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Medical Surveillance

• Requirements vary slightly between General Industry and Construction. For both, surveillance is required when the threshold is exceeded for 30 days or more per year.

• For General Industry, in 2018, the threshold is the PEL. In 2020, it drops to the AL.

• For Construction, it is required when the employee is required to wear a respirator under the standard for 30 or more days per year.

Page 13: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Medical Surveillance

• Both General Industry and Construction require an initial exam within 30 days of initial assignment and periodic exams at least every 3 years. The exam includes:

- Medical & work history- Physical exam with special emphasis on the respiratory system- Chest X-ray- Pulmonary function- Test for latent TB infection- Other tests as deemed appropriate

Page 14: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Exposure Assessments

• Both standards require exposure assessments when workers can reasonably be expected to be exposed at or above the AL. The standard permits the use of objective data if it is sufficient to accurately characterize employee exposures.

• Tasks that involve low exposures (below AL under foreseeable conditions) can be excluded if the employer has objective data that determines exposures are below the AL. There are no time restrictions for using past data.

Page 15: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Exposure Assessments

• EEI has a database of Crystalline Silica personal samples, most are from Generation. There is little data for work involving Distribution and Transmission activities. We need to consider how we can leverage this information as objective date.

• There are scheduled monitoring options if objective data is not available or the employer chooses this option. This option is similar to the metals standards in that additional monitoring is required if the levels exceed the AL or the PEL.

Page 16: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Regulated Areas• The General Industry standard requires that the employer establish a

regulated area wherever an employee’s exposure to airborne concentrations of crystalline silica is, or can reasonably be expected to be, in excess of the PEL. Each entrance to the regulated area must be posted with the following signage:

DANGERRESPIRABLE CRYSTALLINE SILICA

MAY CAUSE CANCERCAUSES DAMAGE TO LUNGS

WEAR RESPIRATORY PROTECTION IN THIS AREAAUTHORIZED PERSONNEL ONLY

Page 17: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Regulated Areas

• The Construction standard does not have a provision for establishing regulated areas, but includes a requirement that the written exposure control plan includes procedures to restrict access to work areas.

Page 18: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Written Exposure Control Plan

• Written exposure control plans will be required by both standards (except where exposures will remain below the AL under any foreseeable conditions). The plan needs to include a description of:

- the task that involves exposures to Crystalline Silica- engineering controls used- work practices and PPE, including respiratory protection used- housekeeping measures to limit exposures

Page 19: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Written Exposure Control Plan

• The Construction standard also requires procedures to restrict access work areas (not regulated areas as with General Industry).

• The Construction standard also requires a designated competent person to implement the exposure control plan.

• An annual review of the plan is required under both standards.

Page 20: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Engineering and Work Practice Controls

• If engineering and work practice controls are insufficient to reduce the silica levels to below the PEL, they still must be used in conjunction with respiratory protection.

• Ventilation, HEPA filtered equipment and wet methods are the primary means to reduce silica exposures.

• OSHA does not prohibit employee rotation as a means to keep exposures below the PEL.

Page 21: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Personal Protective Equipment

• There are no requirements for protective clothing.

• Respirator use will be required if engineering and/or administrative controls are not effective or feasible in keeping Crystalline Silica levels below the PEL.

• A P-100 is the proper filter for protection against Crystalline Silica exposures.

Page 22: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Table 1

• Paragraph (c) of the Construction standard contains Table 1 –Specified Control Methods When Working With Materials Containing Crystalline Silica. For 18 tasks, it lists:

- Equipment/task

- Engineering and work practice control methods

- Required respiratory protection and minimum assigned protection factors (APF)

Page 23: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Table 1

• For these 18 tasks, if all of the engineering, work practices and respiratory protection requirements are met, the other requirements of the standard do not apply.

• In the table, the required respiratory protection is listed as both if the task is 4 hours or less, and if the task lasts longer than 4 hours.

• This does not permit using a respirator only after 4 hours for a task that lasts longer than 4 hours. A respirator is required for the entire job.

Page 24: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Table 1

• Table 1 is designed for Construction activities. For General Industry activities, it is permitted to use Table 1 if the task is not performed frequently and is the same as the task listed in Table 1.

• Tasks that are not addressed by Table 1 must be performed under the requirements of the standard.

Page 25: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Housekeeping

• Dry sweeping and/or dry brushing is permitted only if other methods (i.e., wet methods, HEPA vacuuming, etc.) are not feasible.

• Compressed air cleaning is not permitted unless it is used in conjunction with a ventilation system or no alternative method is feasible.

Page 26: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Recordkeeping

• The recordkeeping requirements are the same as other standards, with the exception that the employee’s social security number is required on the documentation.

• Affected employees must be notified of monitoring results within 15 working days for General Industry.

• Construction notification is required within 5 working days.

Page 27: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Training

• Employee information and training must include:- Health hazards associated with Crystalline Silica exposures- Specific tasks that could result in exposures- Protective measures, including respiratory protection- Contents of the standard(s) and how to obtain a copy- Purpose and description of the medical surveillance program - Competent person for Construction• No frequency for training is specified by either standard.

Page 28: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Going Forward

• We will need to define which jobs are “low exposure” jobs and which will fall under the regulations.

• We will need develop exposure assessments. We have some data on coal and ash. Concrete/rock/masonry work will need to evaluated further.

• We will need to work with contractors to assure that they comply with the standard.

Page 29: OSHA Crystalline Silica Standard - The Source s/2016Spring/ih/hatcherSilica.pdfCrystalline Silica. The effective date is 6-23-2016. • Standards have been issued for General Industry,

Going Forward

• We will need to determine which employees will require medical surveillance.

• The implementation period gives us time to get the specifics resolved to assure that we are in compliance by the implementation dates.

• QUESTIONS????