TAMMY K Y K. C CLAR ARK - Aggregate Technology Specialist, State of MI, MDOT - Density Technology Specialist, State of MI, MDOT - Bituminous Level 1 Technology Specialist, State of MI, MDOT SAFETY & HEALTH CONSULTANT, CONSTRUCTION INDUSTRY
Respirable Crystalline Silica - PART 690 (MI), 1926.1153 CONSTRUCTION
The R e Reason W Why Current Estimate of exposure: Approximately 2.3 million workers are exposed to respirable crystalline silica each year; the majority of these workers (2 million) are in the construction industry. OSHA estimates that the new rule will: Save over 600 lives annually. Prevent over 900 new cases of silicosis each year. Provide a net benefit to industry $7.7 billion annually. Annual costs per year of $1,524 for the average work place.
The e Rea eason on W Why
Respirable Silica Dust (<10 microns)
What is is Silic ilica? - Na Naturally ly occurrin ing m mineral. al. - 70% o of Earth’ h’s c crus ust - Beac each; s silic ica san and - Particles 10 100x sm smaller than sa sand.
The New Silica Standard… Straightforward in delivery. Complicated in application.
Respir irable le C Crystalli lline Si Silic ica - Microf ofume Du Dust Where can it be found: ◦ Concrete ◦ Masonry ◦ Sandstone ◦ Rock ◦ Paint ◦ Abrasives ◦ Mortar ◦ Plaster ◦ Shingles
Heal ealth E Effec ects ts – Silic ilica ◦ Early stages of the disease may go unnoticed. X-RAY. ◦ Silicosis – disabling, non-reversible & fatal lung disease. ◦ Other non-malignant respiratory diseases, such as chronic bronchitis. ◦ Lung Cancer ◦ Kidney disease – including nephritis & end-stage renal disease (kidneys). ◦ May be associated with auto-immune disorders & cardiovascular disease.
Heal ealth E Effec ects ts – Silic ilica ◦ Symptoms include : ◦ Shortness of breath ◦ Severe cough ◦ Chest pains ◦ Weakness ◦ Fatigue ◦ Respiratory Failure
Heal ealth E Effec ects ts – Silic ilica ◦ Symptoms : ◦ Rarely develop in less than 5 years. ◦ - Exception – massive exposures. ◦ Typically 10 – 20 years – disabling, death. ◦ Many only in their 30’s. ◦ Some as young as 20’s.
War arning! Silicosis IS NOT CURABLE , but it IS PREVENTABLE . Don’t be like THAT guy!
Scope & Application Part 690, 1926.1153 – Construction This section applies to all occupational exposures to respirable crystalline silica in construction work, except where employee exposure will remain below 25 micrograms per cubic meter of air (25 µg/m³) as an 8-hour time-weighted average (TWA) under any foreseeable conditions. ◦ This section means this respirable crystalline silica std. 29 CFR 1926.1153.
De Definitions Action Level (AL) = 25 µg/m³ (0.025 mg/m³) Permissible exposure limit (PEL) = 50 µg/m³ (0.050 mg/m³) Employee exposure = Means the exposure to airborne respirable crystalline silica that would occur if the employee were not using a respirator .
De Definitions High-efficiency particulate air [HEPA] filter = Means a filter that is at least 99.97 percent efficient in removing mono-dispersed (a uniform collection of size) particles of 0.3 micrometers in diameter. Objective data = means information (air monitoring data) from industry wide surveys/calculations based on the composition of a substance, demonstrating employee exposure to respirable crystalline silica associated with a particular product/material/task/activity. Data must reflect workplace conditions closely resembling or with a higher exposure potential than the processes, types of material, control methods, work practices, and environmental conditions in the employer’s current operations.
Obje ject ctive D Data o USE EXTREME CAUTION! o Industry tests – conditions must be very similar: o Tested in lab/field? Outside vs. inside? o Silica percentage comparison? Similarity of materials? o Tools used? Saw blades same size? o Wind speed
De Definitions Competent person (construction) = means an individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has the authorization to take prompt corrective measures to eliminate or minimize them. The competent person must have knowledge and ability necessary to fulfill the responsibilities set forth in paragraph (g) of this section. By way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them. - There are currently no specific standards regarding competent person requirements.
De Definitions Physician or other licensed health care professional [PLHCP] = means an individual whose legally permitted scope of practice (i.e., license, registration, or certification) allows him or her to independently provide or be delegated the responsibility to provide some or all of the particular health care services required by paragraph (h) of this section. Regulated area (GI) = means an area, demarcated by the employer, where an employee’s exposure to airborne concentrations of respirable crystalline silica exceeds, or can reasonably be expected to exceed, the PEL. Respirable crystalline silica = means quartz, cristobalite, and/or tridymite contained in airborne particles that are determined to be respirable by a sampling device designed to meet the characteristics for respirable-particle-size-selective samplers specified in the international Organization for Standardization (ISO) 7708:1995: Air Quality – Particle Size Fraction Definitions for Health-Related Sampling.
Employer R r Requirements 1. Determine if the silica standard applies to your employees. Could employees be exposed to respirable crystalline silica at or above 25 µg/m 3 as an 8- hour TWA under any foreseeable conditions, including the failure of engineering controls, while performing construction activities? NO: No further action is required under the standard. YES: Choose to comply with the standard using either the: • Specified exposure control in Table 1, or • The alternative methods of compliance
Speci ecified ied E Expos osure C Contr trol M Meth thod ods Construction For each employee engaged in a task identified on Table 1, the employer shall fully and properly implement the engineering controls, work practices, and respiratory protection specified for the task on Table 1, unless the employer assesses and limits the exposure of the employee to respirable crystalline silica in accordance with paragraph (d) of this section (Alternate exposure control methods).
Eng ngineering Co Controls Wet Methods Equipment utilizing water deliver methods Vacuum Dust collection equipment capable of pulling 25 cubic feet of air per minute Ventilation When working in enclosed spaces exhaust ventilation may be required
Table 1 1: Specified Exposure C Contr trol M Meth thods When W Working With M Materials C Containing Crystalline Silica - Construction REQUIRED RESPIRATORY PROTECTION & EQUIPMENT/TASK/CONTROL METHODS MINIMUM ASSIGNED PROTECTION FACTOR (APF) ≤ 4 hours/shift ≥ 4 hours/shift Stationary Masonry Saws None None ◦ Continuous water feed to blade Handheld power saws (any blade diameter) ◦ Continuous water feed to blade ◦ Outdoors None APF 10 ◦ Indoors/enclosed area APF 10 APF 10 Handheld power saws for cutting fiber cement board (blade diameter ≤ 8 inches) ◦ Outdoor use only None None ◦ Dust collection system (commercial) ◦ Proper tool airflow & HEPA filters (≥99%)
Table 1 1: Specified Exposure C Contr trol M Meth thods When W Working With M Materials C Containing Crystalline Silica REQUIRED RESPIRATORY PROTECTION & EQUIPMENT/TASK/CONTROL METHODS MINIMUM ASSIGNED PROTECTION FACTOR (APF) ≤ 4 hours/shift ≥ 4 hours/shift ◦ Walk-behind saws ◦ Continuous water feed to blade None None ◦ Outdoors ◦ Indoors/enclosed area APF 10 APF 10 ◦ Drivable saws ◦ Outdoors only None None ◦ Continuous water feed to blade ◦ Rig-mounted core saws/drills None None ◦ Continuous water feed to blade
No comments on the use of a vacuum exhaust system from OSHA/MIOSHA. This means you are on your own! Get air monitoring data!
Table 1 1: Specified Exposure C Contr trol M Meth thods When W Working With M Materials C Containing Crystalline Silica REQUIRED RESPIRATORY PROTECTION & EQUIPMENT/TASK/CONTROL METHODS MINIMUM ASSIGNED PROTECTION FACTOR (APF) ≤ 4 hours/shift ≥ 4 hours/shift Handheld & Stand-mounted drills (include impact/rotary hammer drills) None None ◦ Shroud/cowling equipped drill ◦ Dust collection ≥99% w/ filter cleaning mechanism ◦ HEPA filtered vac for cleaning holes Dowel drilling rigs for concrete APF 10 APF 10 ◦ Outdoors only ◦ Shroud/cowling around drill bit ◦ Dust collection ≥99% w/ filter cleaning mechanism
NOTE: Dowel drilling rigs are typically done dry = excessive dust emissions. Changes are coming! They will now need shrouds for each bit and local exhaust ventilation, lots of ventilation. With this new standard coming, mfg’s are designing new dust control systems everyday. There are no comments on the use of a water flood system here so again you must develop your own air monitoring data for a wet system that you will use.
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