Friday, March 09, 2018

OSHA's Silica Standard - What's All The Fuss About? Part Two

In our previous post, we discussed that as long as you were performing tasks that were listed in Table 1 of the Occupational Safety and Health Administration (OSHA) Respirable Crystalline Silica 1926.1153 standard we didn't see what all the fuss was about.  Even if some tasks required a respirator some of those tasks would allow you to use an administrative control (have the worker do the task for 4 hours or less) to eliminate the respirator requirement.  The fuss is all about those tasks that do not eliminate respirator usage (i.e, Task (x) Jackhammers and handheld powered chipping tools with a water delivery system at the point of impact, used indoors or in an enclosed area) in Table 1 or a task not listed in Table 1.  We already discussed the requirements, if Table 1 requires a respirator in Part One of this blog.  So the question is what is required if your task is not listed in Table 1 or you can't fully & properly implement the engineering controls, work practices, and respiratory protection described in Table 1?  Well that's a long story and that's what all the fuss is all about!

Mr. Peter Delucia's Silica Presentation at the PACNY Conference
Before we get into this long story, we would like to thank Mr. Peter Delucia, of AAC Contracting, for his assistance in helping us write this blog post.  Mr. Delucia's presentation at the Professional Abatement Contractors of New York (PACNY) 22nd Annual Environmental Conference was jam packed with examples, references, and information out in the internet to assist employers wanting to comply with this standard.  Much of that information helped us write this post.

If you can't use Table 1 (the above video would be a Table 1 activity), then you have to use an alternative exposure control method (d).  Which first requires that no employee be exposed to an airborne concentration of respirable crystalline silica ( silica) in excess of 50 micrograms per cubic meter (ug/m3), calculated as an 8-hour Time Weighted Average (TWA).  Second employers must perform an exposure assessment (d)(2)(i) for each employee who is or may reasonably be expected to be exposed to silica at or above the action level (25 ug/m3).  Here you have two choices either the performance option (d)(2)(ii) or scheduled monitoring option (d)(2)(iii).  The performance option allows combination of air monitoring or objective data that is sufficient to accurately characterize employee exposures to silica. The performance option can be almost like Table 1 in that the employer can use objective data that is created by others to determine employee exposures to silica.  Some manufacturers are creating objective data for their tools (i.e., Milwaukee Tool, which has some objective data information for some of their tools and shrouds).  You can use these by just following the instructions on the objective data and making sure you meet the conditions listed in objective data.  The second choice is to perform initial monitoring (scheduled monitoring) to assess the 8-hour TWA exposures for each employee on the basis of one or more personal breathing zone air samples that reflect the exposures of employees on each shift, for each job classification, in each work area.  Which means you need to have the personal air sampling equipment and a laboratory for analysis of your air samples.  This is a little complicated and because most people are unfamiliar with how to do personal air sampling, this can be quite intimidating!

However, with the proper training (we do a respirable crystalline silica competent person course) and a good laboratory to support your efforts the competent person could perform the sampling necessary to meet the OSHA requirements.  There is some basic equipment that is needed to do sampling (as you can see from the video above).  One of the most important pieces is the personal air sampling pump.  These pumps are portable and are usually worn on the waist of the person you want to determine their exposure.  There are quite a few manufacturers of these pumps (Sensidyne, maker of Gillian sample pumps & SKC, maker of Universal sample pumps, etc.).  You want these pumps to be durable and be able to handle a drop here and there.  Purchasing these pumps is not a bad idea but before you consider doing that we need to remind you that these pumps need to be calibrated against a primary standard at least every three months.  Primary standards are not cheap (Buck Calibrator & Gilibrator, etc).  So unfortunately, its not that easy to buy the pumps and use them.  If you don't intend on using these pumps regularly a better choice would be to rent the pumps from a laboratory.  Then have the laboratory maintain and calibrate the pumps when they send them to you.  This also allows for billing the equipment to specific projects.  There are quite a few labs that can help you in that way (SGS Galson & EMSL, etc.).  This way you can tell them what you are sampling and they will send you the equipment and sampling media you need for doing the sampling and incorporate the analysis price for the whole exposure assessment.  They will also send you instructions on using the equipment properly, sample & chain of custody forms for doing the sampling, as needed. The samplers for silica are pictured below and you will want to use either one of these samplers.  The standard then goes into how often you will need to do scheduled monitoring based on the results, employee notification of results, and observation of monitoring results.

Personal Pump with PPI sampler for silica
Breathing zone sampling with aluminum cyclone sampler for silica

Once you have determined which method you are using (Exposure Assessments, or Scheduled monitoring), the employer must have a written exposure control plan.  The plan must cover the tasks in the workplace; a description of engineering controls, work practices, and respiratory protection used to limit exposure; housekeeping measures used to limit exposure; and procedures to restrict access.  The employer must update the plan at least annually and designate a competent person to make frequent and regular inspections of job sites, materials, & equipment to implement the plan.   The final step is to train the workers and the competent person on the exposure control plan so everyone understands and knows what is required under the plan.  Again, we have added a number of courses to our schedule or contact us here if you need us to work with you in developing your exposure control plan or exposure monitoring plan to help you keep your employees safe!

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