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Silica Rule Update / Silica Mitigation Equipment

Christine Reed, CHCM

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Silica Rule Update / Silica Mitigation Equipment

  1. 1. Silica Rule Update / Silica Mitigation Equipment Christine Reed, CHCM
  2. 2. Silica Rule Update  Few updates since the standards were implemented New Sample Training PowerPoint for Construction • Basic info – what is silica, where is it found, health hazards, protecting employees (Eng, A/WP, Resp, HK), competent person, medical) Video Protecting Workers from Silica Hazards in the Workplace, 5 minutes - basic overview for the new employee • Other videos for Table 1 Tasks (next slide) Table 1 Task Fact Sheets for Construction (next, next slide)
  3. 3. Controlling Silica Dust in Construction, Videos for Table 1 Tasks  Stationary Masonry Saws  Handheld Power Saws  Handheld and Stand-Mounted Drills  Jackhammers or Handheld Powered Chipping Tools  Handheld Grinders for Mortar Removal (Tuckpointing)  Handheld Grinders for Uses Other than Mortar Removal
  4. 4. Table 1 Tasks, Fact Sheets for Construction •Handheld Power Saws •Handheld Grinders for Tasks Other Than Mortar Removal •Handheld Power Saws Used to Cut Fiber-Cement Board •Jackhammers or Handheld Powered Chipping Tools •Handheld and Stand-Mounted Drills •Stationary Masonry Saws •Handheld Grinders for Mortar Removal (Tuckpointing) •Walk-Behind Saws •Drivable Saws •Rig-Mounted Core Saws or Drills •Dowel Drilling Rigs for Concrete •Vehicle-Mounted Drilling Rigs for Rock and Concrete •Walk-Behind Milling Machines and Floor Grinders •Small Drivable Milling Machines ( < Half Lane) •Large Drivable Milling Machines ( > Half Lane) •Crushing Machines •Heavy Equipment and Utility Vehicles Used During Demolition Activities •Heavy Equipment and Utility Vehicles Used for Grading and Excavating Tasks
  5. 5. Engineering Controls Only As Good As Maintained!
  6. 6. FAQs for the Construction Industry, August 2018  Scope  Definitions  Exposure Control Methods  Housekeeping  Written Exposure Control Plan  Medical Surveillance  Employee Information and Training  Recordkeeping
  7. 7. Citations / Penalties Construction (1926.1153) all industries  202 Inspections  556 citations  avg. 2.75 citation / inspection  $816,926 penalties  avg. $1,469.29 / citation General Industry (1910.1053) all industries  5 Inspections  12 citations  avg. 2.4 citations / inspection  $22,315 penalties  avg. $1,859.58 / citation October 2017 thru September 2018
  8. 8. Citations / Penalties  1926.1153(c)(1) the employer shall fully and properly implement engineering controls, work practices, and respiratory protection specified for tasks on Table 1, unless employer assesses and limits exposure to RCS, IAW para (d)
  9. 9. Citations / Penalties  1926.1153 (d)(2)(i) - assess exposure of each employee who is or may reasonably be expected to be exposed to RCS at or above the action level IAW either the performance option or the scheduled monitoring option
  10. 10. Citations / Penalties  Performance option - assess exposure for each employee on basis of any combination of air monitoring data or objective data sufficient to accurately characterize employee exposures to RCS
  11. 11. Citations / Penalties  Scheduled monitoring option ─ sample employees each shift, each job classification, each work area ─ exposures below the action level, discontinue monitoring ─ exposures at or above action level but at or below PEL, repeat monitoring within 6 months ─ exposures above the PEL, repeat monitoring within 3 months
  12. 12. Citations / Penalties *repeat monitoring is two samples taken seven or more days apart
  13. 13. Citations / Penalties  1926.1153(g)(1) Exposure Control Plan ─ description of the tasks in the workplace ─ description of engineering controls, work practices, respiratory protection ─ description of housekeeping measures ─ description of procedures used to restrict access to work areas
  14. 14. Citations / Penalties  1926.1153(I)(1) Communication of RCS hazards to employees - Hazard Communication  1910.1053(j)(1) Communication of RCS hazards to employees - Hazard Communication
  15. 15. Citations / Penalties  1910.1053(c) Permissible Exposure Limit ─ (d)(1) assess exposure ─ (e)(1) regulate areas ─ (f)(1) engineering controls, work practices ─ (f)(2)(i)(C) housekeeping measures ─ (l)(1)(i) failure to implement the standard
  16. 16. Citations / Penalties  1910.1053(g)(2) Respiratory Protection Program Where respiratory protection is required, employers must provide each employee with an appropriate respirator
  17. 17. Citations / Penalties  Virginia Department of Labor  Inspection date, for one company, 02202018 – 08062018  Fines assessed at $296,065.00  Specifically: 1. Communication of RCS hazards to employees 2. Not fully and properly implementing engineering controls, work practices and respiratory protection 3. Not assessing employee exposures to RCS 4. Not implementing respiratory protection
  18. 18. Respirator Use, 1910.1053  Respirators required  When PEL exceeded during periods to install/implement eng/work practice controls  When PEL exceeded during tasks, in which engineering and work practice controls are not feasible  When engineering/work practice controls are not sufficient to reduce exposures to or below the PEL  When in a regulated area • The employer must assess whether the observer already has the equipment, medical clearance, and training necessary to enter the area in question, including observers not employed by the employer
  19. 19. Respirator Use, 1926.1153  For tasks specified on table 1  For tasks not specified on table 1 in which exposures exceed the PEL  When engineering controls and work practices have not been fully and properly implemented
  20. 20. Respirator Use, 1926.1153 Fully and properly implemented means…  For tasks performed indoors or in enclosed areas, provide a means of exhaust as needed to minimize the accumulation of visible airborne dust  For tasks performed using wet methods, apply water at flow rates sufficient to minimize release of visible dust
  21. 21. Respirator Use, 1926.1153  For measures implemented that include an enclosed cab or booth, ensure that the enclosed cab or booth  Is maintained as free as practicable from settled dust  Has door seals and closing mechanisms that work properly  Has gaskets and seals that are in good condition and working properly  Is under positive pressure maintained through continuous delivery of fresh air  Has intake air that is filtered through a filter that is 95% efficient in the 0.3-10.0 μm range (e.g., *MERV-16 or better)  Has heating and cooling capabilities *minimum efficiency reporting value
  22. 22. Medical Surveillance  1910.1053(i)(1)(i)The employer shall make medical surveillance available at no cost to the employee, and at a reasonable time and place, for each employee who will be occupationally exposed to respirable crystalline silica at or above the action level for 30 or more days per year.  1926.1153(h)(1)(i)The employer shall make medical surveillance available at no cost to the employee, and at a reasonable time and place, for each employee who will be required under this section to use a respirator for 30 or more days per year.
  23. 23. Silica Mitigation Equipment  Exhaust Systems  Design for collection at the source, not for the area  Regular system inspections  Regular preventive maintenance
  24. 24. Silica Mitigation Equipment  Vacuums – w / HEPA filtration ─ Shop Vacs ─ Master Force ─ Nilfisk
  25. 25. Silica Mitigation Equipment Central Vac Systems ─ American Vacuum Company ─ Vac-U-Max
  26. 26. Silica Mitigation Equipment Sweepers ─ Tennant – S9 / S10 ─ Power Boss
  27. 27. Silica Mitigation Equipment  Sweeping Compounds  Delta Foremost  Tough Guy
  28. 28. Silica Mitigation Equipment  SonicAire – Blowers  Designed to create a barrier overhead to reduce dust accumulation  Creates downward draft  Size of facility determines # of blowers to install