Steps for Compliance with Silica Standard.
Before we do the steps, let’s review the rule. It was passed, quite a long time ago, but enforcement has been extended for many months, and then again, for several months, from this summer to this fall. (Sept. 23, 2017). Then OSHA has said they will ‘not cite with fines’, if the employer is doing something with the rules, besides hoping it won’t happen. So, start now if you haven’t already! This post is for me to give everyone a quick primer on what you need to be doing right now, to get a plan in place.
Remember there are two other rules that are still in force and which we have been living under for 45 years or more. The silica standard was part of the original safety standards from OSHA, and has always required knowledge of how much silica workers are being exposed to. The respirator protection standard has always required that if any exposure exceeds allowable amount, then respirator protection shall be used. The old standard had a much higher amount of micrograms per cubic meter than the new standard does.
The new standard allows for you to have a plan that is not special measurements and monitoring done all the time, like lead or asbestos. Rather, it allows us to find out and get data to “KNOW” in advance what an exposure for a certain task may be, and then base our protection on that data. Unfortunately, OSHA only supplied a scant amount of data to let us “KNOW”, but over time we will all be able to find data for circumstances that will let us KNOW, and using that data we can act on the plan we put together to protect the employees.
The obvious, and ideal situation, would be that we KNOW that how we do the work will never raise enough silica to trigger the rest of the standards (respirators, medical checks, etc.). That would be my goal, if I was any contractor – including a concrete or asphalt or demolition contractor. The other “best scenario” would be to KNOW that all the methods chosen and used by my company would ONLY require a “paper” filtering facepiece respirator – or better (like a rubber half mask with cartridges). Then we could proceed much like today, with only minimal effort to eliminate risk and potential OSHA fines and health problems.
There are protests going on against this standard. To think it will succeed is foolish, since this new standard is likely to help across the board, even though there is little silica illness found in USA today.
So, here are some first steps to getting ready for the new standard:
- List all your functions that you have in your company (EVER!) that could create silica dust. That is any mechanical breaking or wearing the surface of any silica containing material.
- Next to each item put your plan for protecting your workers. For NOW, you must put in filtering facepiece respirator, or half mask rubber facepiece respirator. If you use rubber half masks or full masks, the other respiratory standard is triggered, and you must provide training and fit testing and cleaning facilities for those kinds of face masks. For filtering facepiece respirators, only training on the hazard, when and where to use them, how to put them on, and when to throw them away.
- Leave a blank now for the amount of silica found to be the exposure with dry actions.
- Leave a blank now for the amount of silica found to be the exposure with wet actions.
- Leave a blank now for the amount of time allowed to work under 4 total hours, or over 4 total hours.
- List whether the type of mask is mandatory or voluntary – for now make them all mandatory.
- Buy P-100 filtering facepiece respirators for each job and have a training class on when to wear them (see above) whenever using or doing anything that is on the list, at all times that any silica dust can be seen.
- Buy vacuums for each job that will do this kind of work. Buy HEPA filters for these vacuums. Include in training when to use these vacuums.
- Buy a weed sprayer (compressed pump type tank and spray nozzle), and some Palmolive or other liquid dish washing soap, for each job that will do this kind of work. NOT DETERGENT.
- Have someone write or you write a safety plan that follows the basic format of the OSHA standard (it is essentially a policy to do what the law says, determine what is listed here and determine what you are going to do about it – see above)
After this baseline is done, you must
- Keep your listing (1. above) up, and
- try to find better techniques that work for you, and
- determine through official channels the actual exposure that’s been measured.
In the alternative, get a test done during a one hour period your workers are doing the work, the way you have chosen to do it, and then have an expert calculate your 4 hour exposure, and your 8 hour exposures, and your 8 hour time weighted average (8TWA).
If your style of work and the tools and materials and techniques you use are found to be less than 25 micrograms per meter/average over a 8 hour day, (8TWA) then, you can amend your listing (1. above) to show that the measurements are less than the lowest amount, and that you are NO LONGER requiring the wearing of the respirators.
Note, any one of the items you list, you may, if you have the information documented, use that information and fill in the requirements for protection of the workers accordingly.
Note, that the data we collect is modeled after the asbestos standard – which is that we must collect a data set of the worst case, or the case that will always be worse than what we are going to actually do. For instance, if you check worst case for drilling holes in concrete with a hammer drill, to be without water, and it comes up 38 micrograms per cubic meter, then you say, “we will ‘always’ use water in the drill holes, and always suck up the debris with our HEPA vacuum,” then you’ll have defensible standing with OSHA. However, if you were to do your testing for data on guy drilling on the floor, and then try to have that data serve as your work for drilling overhead, it would clearly be different situations. That is why the setup of the types of work you will be doing must be thorough when you list them in the part discussed in 1. above.
It is not the easiest standard to understand, but compliance might be, in the long run, easiest once we get our baselines established.
That baseline, starts with a complete list of what kind of work, what tools, and what methods of doing the work are established. That can be an exhausting list to create. Once done, the rest will be less complicated, since most of the methods and the protections are the same.
Note that silica exists in anything that is manufactured with glass, or sand, or many rocks, or clays, or other mineral/rock formations. For instance, granite, marble, gneiss, quartz, and others all have silica. Ceramics, tiles, blocks, concrete, asphalt, cement fiber boards, siding, bricks, mortar, and other common materials can put out microscopic silica particles when they are blasted, broken repeatedly (like jack-hammers do), chipped, crushed, hammered, drilled, cored, run over, pulverized, dropped from heights, ground, sanded, hammered, sawed, chiseled, or almost any abrasive, aggressive, mechanical changes are done to the solid objects made of this material. It is almost impossible to create enough dust if the mechanical means are wetted thoroughly. It isn’t at all likely that you can get overexposed handling the solid objects unless there are lots of broken bits, and residue that is made airborne.
Note too, that your operations may be an alarming thing to someone nearby, especially if they were trained to avoid all silica. You may have to deal with job site complaints and being able to tell anyone on the outside of the work area that you KNOW what the output is and this will help you deal with such claims.