SILICA DUST: EVERYTHING YOU NEED TO KNOW.

CAN YOU (AND YOUR TEAM) ANSWER ALL OF THESE QUESTIONS?

• What is Silica Dust?
• What is respirable silica dust?
• What activities create respirable silica dust?
• How does respirable silica dust effect my health?
• How do we control exposure to respirable silica dust?
• Who is the employer’s respirable silica dust competent person?
• What is the purpose and process of the medical surveillance program?
• What are the OSHA standard requirements of the new respirable silica dust standard?
• Has all the above been covered and properly documented in the respirable silica dust exposure control plan?

Can you answer all the questions? If you cannot thoroughly answer these questions then you have not fulfilled the training requirements outlined in the new respirable silica dust OSHA standard.

We are not going to cover all the questions, as the length of the article would be substantial. However, we are going to focus on the main points of the new standard, centered around controlling silica dust exposure. If you want the answer to all the above questions, or to fulfill the osha training requirements, or gain a vast knowledge on silica dust exposure and control, and receive template documents to start your company in the right direction… JLN currently offers an open enrollment respirable silica dust course found on our website.
JLN can also bundle our training course with an easy three step process to get your crew medically evaluated and fit tested all through the JLN Fit Testing Program.
Feel free to call anytime with questions, we are here to help ensure your crew is safe and in compliance.

Compliance Dates & Technical Information:

OSHA has tightened up the safety requirements concerning operations that create silica dust in construction.

The original compliance enforcement date was June 23^rd, 2017. After public comment and various reasoning, OSHA delayed the date to September 23^rd, 2017 allowing more time for the industry to make the changes necessary.
Other industries are going to see later compliance dates:

• General Industry & Maritime – June 23^rd, 2018
• Hydraulic Fracturing – June 23^rd, 2021

Respirable Silica Dust Overview:
Silica dust comes from the chemical compound Silicon

Dioxide; a colorless chemical compound. It is the most plentiful compound on the earth’s surface.

Silicon Dioxide is commonly found in materials containing quartz. Quartz can be found in a variety of different materials used around your home and on the job.

For example, some everyday items found on the job can include: Rocks, sand, dirt, concrete mixing products, brick, block, tile, stone, asphalt, etc.
These products in their stagnant condition may not present a health hazard. However, when these products are released into the air in very fine particles, the health hazard drastically changes.

Remember the title of the OSHA standard reads “1926.1153 – Respirable Crystalline Silica Dust”

The health hazard is the respirable silica dust:
Respirable dust containing silicon dioxide particulate created by a method of destructive reduction or impact.

The difference between silica dust and respirable silica dust is the particle size.

• Inhalable (silica) dust is generally around 100 micrograms
• Respirable (silica) dust is 10 micrograms or less.

Respirable (silica) dust is so small in particle size that the body’s respiratory system does not have the ability to stop these particles from entering the lungs. Once respirable silica dust enters the lungs the body internally attempts to fight the particles with cells called macrophages. However, these cells cannot decompose the particle. Macrophages attempt to recover in the walls of the lung and, in-turn, bring the respirable silica dust particle into the wall of the lung. The macrophage cell then dies and creates scar tissue. Once scar tissue has formed in the lung, it can no longer take oxygen into the blood. E

ach area of scar tissue compromises a section of the overall lung capacity; permanently.

Controls to avoid over exposure are extremely important.
The new OSHA PEL for respirable silica dust is 50 micrograms per cubic meter of air (previously 100 micrograms per cubic meter of air). 
While a 50% decrease is significant, this is not the “highlight” of the new standard. The highlight is found in the control methodology being utilized.

OSHA has essentially outlined two control method options:

• Option 1: Follow the provided “Table 1” control procedures for the associated job activities and you do not have to comply with the air monitoring requirement section of the standard.
• Option 2: Do not follow “Table 1” and perform air sampling for all necessary job activities to prove your job specific control practice with factual documentation.

To further breakdown these options, below are the pros and cons for a realistic working construction environment:

Option 1 (Table 1):

• Pros:
  • Best available practice for exposure control.
  • OSHA compliance without the need for air sampling documentation.
  • The activity and control is listed for you, no need to perform “guess and check” implementation of a control to see if it works.
• Cons
  • Unrealistic in an ever-changing construction environment.
  • If an OSHA inspector found you out of “Table 1” compliance you would be in violation of numerous applicable air monitoring standards.
  • “Cookie cutter” job activities listed. Any variation may put you out of compliance with “Table 1” in the eyes of an OSHA inspection.

Option 2:

• Pros:
  • Full lab documentation to directly prove the reasoning behind your procedure and associated control method.
  • Full job activity and control method customization if the OSHA PEL and standard is satisfied.
• Cons
  • Costly & time-consuming air sampling and lab analysis.
  • Any variation will need to be sampled do have the documentation to prove exposure is controlled.

In the end the best control methodology would be to utilize option 1 (Table 1) as a starting point or best practice and follow up with option 2 as seen necessary. Air sampling should be performed for every “variation” or non-Table 1 listed job activity and control method out in the field. This way, If your job activity or control method diverges from “Table 1”, you have the documentation necessary to prove to an OSHA inspector that you are in compliance.

The other large change in control methodology, is the standard integration of the hierarchy of controls.

Engineering controls   ▶   Administrative controls   ▶  Personal Protective Equipment
Controlling respirable silica dust exposure will have to be done in this order.
For example, to use a cut-off saw to cut block in half, the operator would have to use water during the cutting operation before being able to use a respirator.

 

To further break this down this example:
Step one to controlling exposure (engineering control) – Water hook-up to the wet saw. This prevents the dust from becoming airborne.
Step two to controlling exposure (administrative control) – Employee hazard training specific to the material, tools, and controls. This includes worker changeover. Worker changeover prevents one worker from cutting all the block and receiving a potentially higher exposure.
Step three to controlling exposure (personal protective equipment control) – Respirator with respirable particulate cartridges will be used. This prevents particulate from entering the lungs (if properly used and in good working condition).

These approaches to controlling exposure would have to be used in that order. Even if the “higher control” does not bring the worker exposure below the OSHA PEL, it will have to be used in addition to the “lower control”. If the controls are not used in that order or the superintendent/foreman/worker deems an engineering control not feasible, they will have to justify “why” to an OSHA inspector. In this case, “there is no water source” or “the pump on my saw is broken” will not be reasonable excuses to not use engineering controls. This would correspondingly create a willful fine scenario; as the person(s) knew the control they needed to implement and instead purposely used a different (less satisfactory) control. In this case, the common excuse of “I didn’t know” would merely indicate that you have not had your respirable silica dust training required by the standard, resulting in a potentially higher fine.

While these new changes may seem excessive to those out in the field, the changes come after seeing years of workers permanently suffering due to inadequate controls. These standard changes are there for the worker’s safety. Respirable silica dust is an unforgiving health hazard. The consequences may not take effect immediately, but after repeated exposure it can be a crippling blow to a bright future.