A presentation that I gave to the Chicago Roofing Contractors Assocation. Thanks to John Dimos for the corrections.

1. OSHA’s Crystalline Silica
Construction Regulation
29 CFR §1926.1153• Training
• Exposure Control
• Medical Surveillance
• Written Programs
Draft 2 3 2018

2. Training
• Silica training needs to be
done.
• The employer shall ensure that
each employee covered by this
section can demonstrate
knowledge and understanding
of at least the following:
• (A) The health hazards
associated with exposure to
respirable crystalline silica;
1926.1153(i)(2)(i)(A)

3. What is crystalline silica?
 Silica refers to the chemical
compound silicon dioxide
(SiO²).
 SiO2 is one of the most
common elements on Earth;
it is the main component of
sand.
 Quartz is commonly named
when referring to pure silica
or crystalline silica in SDSs.

4. Chronic Exposure
• Chronic exposure
refers to exposure
continued or repeated
for a prolonged
period, usually years.
For example, silicosis.

5. How does a hazard from crystalline silica occur?
• Hazard occurs when material
containing silica (quartz,
sand) is cut or ground usually
with powered equipment
such as grinders or saws with
diamond or abrasive blades
• “Respirable” or (RCS) means
breathable: The fine silica
particles (about 10 microns or
less in size) are tiny enough
to be inhaled and settle deep
in the lungs.

6. Levels
• OSHA level is 50
micrograms
• White cloud can be
over the silica levels in
one minute

7. Potential health effects
 Silicosis: the oldest known and most common occupational lung disease
marked by the formation of lumps and fibrous scar tissue in the lungs

8. Potential health effects
 Lung cancer: the leading cause of cancer deaths in the U.S.

9. Potential health effects
 Pulmonary tuberculosis: a contagious bacterial infection of the lungs

10. Potential health effects
 Chronic obstructive pulmonary disease (COPD)

11. Potential health effects
 Other diseases: More studies are needed on the cause and effect of RCS
on other diseases or illnesses, but some research indicates a higher
incidence of other cancers among workers exposed to silica, as well as a
higher incidence of
 kidney disease,
 immune system effects and
 enlargement of the right ventricle of the heart.

12. Whole Lung Lavage
 Positive results for early silicosis

13. Silica
• 150-200 deaths a year
(2009)
• 1150-1200 deaths a
year (1968)
• Yet….one company
had 3 silicosis and
10x+ severe
respiratory diseases
Gauley Bridge in 1920’s had
workers die in months.

14. Training
• Silica training needs to be
done.
• The employer shall ensure that
each employee covered by this
section can demonstrate
knowledge and understanding
of at least the following:
• Specific tasks in the workplace
that could result in exposure to
respirable crystalline silica
1926.1153(i)(2)(i)(C)

15. Tasks

16. Tasks

17. Tasks

18. Tasks

19. Tasks

20. Training
• Silica training needs to be
done.
• The employer shall ensure that
each employee covered by this
section can demonstrate
knowledge and understanding
of at least the following:
• Specific control measures
including engineering controls,
work practices, and respirators
to be used
1926.1153(i)(2)(i)(C)

21. OSHA sets out a hierarchy of
controls for silica

22. What is the hierarchy of
controls in silica exposure?
1. Engineering and work practice controls
(unless contractor shows NOT feasible)
a. Substitution
b. Isolation
c. Ventilation
d. Dust suppression
2. Respiratory protection

23. Controlling exposures
• Table 1 lists 18 construction tasks
• Contractor must fully and properly implement engineering
controls, work practices and respiratory protection listed for
the task in Table 1 UNLESS contractor assesses the worker
exposure to silica and limits it as the rule sets out
• Does it have silica?

25. Control Measures

26. Control Measures

27. Control Measures

28. Handheld and stand-
mounted drills
(including impact and
rotary hammer drills)
Use drill equipped with
commercially available
shroud or cowling with
HEPA dust collection
system
Operate and maintain
tool in accordance with
manufacturer's
instructions to
minimize dust
emissions
Use a HEPA-filtered
vacuum when cleaning
holes

29. Control Measures

31. Control Measures

33. Control Measures

34. Taping
• The primary ingredient is usually
calcite (limestone), but it may
contain gypsum, mica, talc,
perlite, clays such as kaolin,
gypsum, and in some cases silica
sand. With hand sanding, much
of the dust generated consists of
particles that are too big to inhale
into the lungs (particles larger
than 15 micrometers in diameter
make up about 50% of the
inhalable mass).
Festool Planex Drywall Sander

35. Training
• Silica training needs to be
done.
• The employer shall ensure that
each employee covered by this
section can demonstrate
knowledge and understanding
of at least the following:
• The contents of the OSHA Silica
Standard
1926.1153(i)(2)(i)(D)

36. Silica regulations
 Notice of proposed
rulemaking issued in
2013; rules targeted to
general industry
(manufacturing) and
construction
 Contains a more
protective permissible
exposure limit (PEL)
 Final rule in
construction effective
Sept. 23, 2017

37. Scope of rule
 Applies to all occupational
exposures in construction to
crystalline silica EXCEPT where
worker exposure will remain
below the action level of 25
micrograms per cubic meter of
air as an eight-hour time-
weighted average (TWA) under
any foreseeable conditions

38. Permissible Exposure Limit (PEL)
• Maximum amount or concentration of a chemical or physical
agent a worker may be exposed to under OSHA regulations.
• PEL is set at 50 micrograms per cubic meter of air as an eight-
hour TWA; a microgram is one-thousandth of a milligram or
one-millionth of a gram.

39. Training
• Silica training needs to be
done.
• The employer shall ensure that
each employee covered by this
section can demonstrate
knowledge and understanding
of at least the following:
• The identity of the competent
person designated by the
employer
1926.1153(i)(2)(i)(E)

40. Competent person
• The employer shall designate a
competent person to make
frequent and regular
inspections of job sites,
materials, and equipment to
implement the written
exposure control plan.
1926.1153(g)(4)
Per OSHA:

41. Written exposure control plan
• Following elements:
• A description of the tasks
• A description of the engineering
controls, work practices, and
respiratory protection for each task;
• A description of the housekeeping
measures
• A description of the procedures
used to restrict access to work areas
• Review annually and update it as
necessary.
1926.1153(g)(1)

42. Written exposure control plan
Operation: Hand-held power saw (any blade
diameter)
Engineering control: Water delivery system to
blade (water must be applied at flow rate that
minimizes release of visible dust)
Respirator required:
If four hours or less per day—none
If more than four hours per day—APF 10
respirator

43. Training
• Silica training needs to be
done.
• The employer shall ensure that
each employee covered by this
section can demonstrate
knowledge and understanding
of at least the following:
• The purpose and a description
of the medical surveillance
program.
1926.1153(i)(2)(i)(F)

44. Medical surveillance program.
Use of Table 1 triggers medical surveillance
requirements on the 30th work day
performing a task where respirator use is a
listed requirement.

45. Medical surveillance
Medical surveillance is needed for workers
required by the new rule to wear a respirator for
30 or more days per year.
The following medical exams should be
conducted by a physician or other licensed health
care professional:
• History and physical
• Chest X-rays by NIOSH-certified B Reader
• Pulmonary function test
• Latent TB test
An exam within 30 days after the worker’s
initial assignment must be done for
medical and work history, pulmonary
function, and other related issues.
1926.1153(h)

46. Notification
• Contractors must notify employees
of the results of an exposure
assessment within five days after
results are complete.
• If there is exposure above the PEL, a
description of the contractor’s
corrective action must be included

47. If tasks are not listed in Table 1
or the OSHA-mandated controls
are not fully implemented …
… contractor has to make sure no worker is
exposed to respirable silica in an amount
exceeding the PEL.

48. Exposure assessment
A contractor is required to assess the
exposure of any worker who is exposed, or
may reasonably be expected to be exposed,
to crystalline silica at or above the action
level of 25 micrograms per cubic meter of
air (half the PEL). This can be accomplished
by:
(1) The performance option, defined as any
combination of air monitoring (personal
breathing zone [PBZ] sampling) or use of
objective data.

49. (2) The scheduled monitoring option
 If below action level, monitoring can
be discontinued
 If at or above action level but at or
below PEL, periodic monitoring must
be done every six months; if above
PEL, monitoring must be done at
least every three months
 Reassess in the case of new
processes, practices or controls

50. Objective data
Objective data is defined by OSHA as
information, such as air-monitoring data
from industry-wide surveys or
calculations, that demonstrates worker
exposure to RCS associated with a
particular product or material or a specific
process, task or activity.
Such data must reflect workplace
conditions resembling current operations
or with a higher exposure potential than
current processes, materials, control
methods, work practices and
environmental conditions.

51. Asphalt shingle removal project
#1701
• Date: July 5, 2017
• Location: Munster, IN
• Structure type: Church
• Project description: Removal of 5,000 square feet of approximately 25 year old, three-
tab shingle removal using hand tools
• Lab analysis of removed material: 9.9% quartz
• Crew members sampled: 5.
Sample results for RCS in micrograms per cubic meter of air:
– 9.0 µg
– 9.2 µg
– 9.3 µg
– 9.4 µg
– 9.4 µg

52. Asphalt shingle installation
project #1702
• Date: July 6, 2017
• Location: Munster, IN
• Structure type: Church
• Project description: Installation of ice and water barrier and laminated asphalt shingles
on 5,000 square foot roof area
• Products installed: Carlisle WIP® 100 water and ice protection and Certainteed
Landmark® asphalt shingles
• Crew members sampled: 5.
Sample results for RCS in micrograms per cubic meter of air:
– 9.4 µg
– 9.5 µg
– 9.4 µg
– 9.4 µg
– 9.4 µg

53. Asphalt shingle removal project
#1703
• Date: September 6, 2017
• Location: Fairfield, OH
• Structure type: Residence
• Project description: 1,400 square feet of asphalt shingle and underlayment removal
using hand tools
• Lab analysis of removed material: 9.9% quartz
• Crew members sampled: 5.
Sample results for RCS in micrograms per cubic meter of air:
– 18.0 µg
– 17.0 µg
– 19.0 µg
– 18.0 µg
– 22.0 µg

54. Asphalt shingle installation
project #1704
• Date: September 6, 2017
• Location: Fairfield, OH
• Structure type: Residence
• Project description: Installation of synthetic underlayment, water barrier and laminated
asphalt shingles on 1,400 square foot roof area using pneumatic nail guns.
• Products installed: Atlas Summit® 60 Synthetic underlayment; Atlas Weathermaster®
granular self-adhesive ice and water barrier; Atlas StormMaster® shingles.
• Crew members sampled: 5.
Sample results for RCS in micrograms per cubic meter of air:
– 7.3 µg
– 8.6 µg
– 7.5 µg
– 7.7 µg
– 18.0 µg

55. Modified bitumen installation
project #1723
• Date: August 8, 2017
• Location: Madison, WI
• Structure type: School
• Project description: Installation of 4,000 square feet of torch-applied SBS modified
bitumen
• Product installed: Siplast Paradiene® 20 PR TG.
• Crew members sampled: 6
Sample results for RCS in micrograms per cubic meter of air:
– 4.6 µg
– 4.7 µg
– 4.8 µg
– 5.0 µg
– 4.6 µg
– 4.7 µg

56. Built-up roofing removal project
#1744
• Date: August 8, 2017
• Location: Clackamas, OR
• Structure type: School
• Project description: 1,500 square feet of built up roofing system removal (half day) using
powered roof cutter, shovels, brooms and wet/dry vacuum
• Crew members sampled: 3
Sample results for RCS in micrograms per cubic meter of air:
– 23 µg
– 10 µg
– 10 µg

57. Built-up roofing installation
project #1745
• Date: August 8, 2017
• Location: Clackamas, OR
• Structure type: School
• Project description: 1,000 square feet of built up roofing system installation (half day)
• Product installed: Johns Manville Dynabase®
• Crew members sampled: 3
Sample results for RCS in micrograms per cubic meter of air:
– 11 µg
– 11 µg
– 11 µg

58. Sheet metal and flashing installation project #1766
• Date: September 12, 2017
• Location: Chicago, IL
• Structure type: Apartment building
• Project description: Drilling and sawing into concrete and masonry to install 100’ of base
tie-in and 50’ aluminum termination bar; drilled for fasteners every 12 inches
(approximately 150 holes)
• Crew members sampled: 2
Sample results for RCS in micrograms per cubic meter of air:
– 5.8 µg
– 5.7 µg

59. Housekeeping
• Wet sweeping or HEPA
vacuuming of RCS dust is
preferred to dry sweeping or
brushing unless infeasible.
• Compressed air may not be
used to clean clothing or
surfaces if it could contribute
to worker exposure.

60. Safety Data Sheets (SDSs)
Under the GHS
format of SDSs,
Section 3 should
contain the
components of a
product as in these
examples.

61. SDSs
 SDSs may list quartz, sand or silica. Sometimes, none
will be listed in Section 3 as the regulation requires,
but you may find language elsewhere as the example
here indicates. The callout below is found in the
“Composition Notes” below the list of ingredients.
This highlights the importance of both the contractor
and workers being familiar with the contents of all
SDSs.

62. Product labeling under OSHA
HCS
 New products that
have silica, quartz or
sand listed as a
component or
ingredient in SDS
Section 3,
“Composition/informa
tion on ingredients,”
should also have
pictograms conveying
a hazard, such as: