8/12/2019 jk, inc - region iii assp pdc
TRANSCRIPT
18/12/2019 JK, Inc - 8926 Kirby Drive, Houston Texas 77054 713-664-1597 [email protected]
ABSTRACT Assist with OSHA compliance for identification, evaluation,
and further implementation of control measures for limitationof occupational airborne exposure to Respirable CrystallineSilica (RCS) during:
1) Drywall installation and finishing,2) Saw cutting and drilling concrete, and3) Jackhammering concrete.
Improve compliance to applicableOSHA Standards elements andsafety and health requirements
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 2
FINISHER/TAPER
Criteria 1926.1153(a) Scope and Application.
This section applies to all occupationalexposures to Respirable CrystallineSilica (RCS) in construction work,except where employee exposure willremain below 25 micrograms per cubicmeter of air (25 μg/m3) as an 8-hourTime-Weighted Average (TWA) underany foreseeable conditions.
8/12/2019 JK, Inc - 8926 Kirby Drive, Houston Texas 77054 713-664-1597 [email protected] 3
OSHA 29CFR1926.1153Respirable Crystalline Silica (RCS)
1926.1153(c)(1) For each employee engaged in a task identified on Table1, the employer shall fully and properly implement the engineeringcontrols, work practices, and respiratory protection specified for thetask on Table 1, unless the employer assesses and limits the exposure ofthe employee to RCS in accordance with paragraph (d) of this section.
Table 1—Specified Exposure Control Methods When Working With
Materials Containing Crystalline Silica
Criteria Table 1 has criteria for hand-held
power saws, walk-behind saws,jackhammers, chipping tools, etc. andno specific reference for dry wall work.
Performance Option. Employer shallassess 8-hour TWA exposure for eachemployee based on any combination ofair monitoring data or objective datasufficient to accurately characterizeemployee exposures to RCS.
8/12/2019 JK, Inc - 8926 Kirby Drive, Houston Texas 77054 713-664-1597 [email protected] 4
DRYWALL HANGER
1926.1153(d)(2)(iii) Scheduled Monitoring Option. 1926.1153(d)(2)(iii)(A) The employer shall perform initial monitoring to
assess the 8-hour TWA exposure for each employee on the basis of one ormore personal breathing zone air samples that reflect the exposures ofemployees on each shift, for each job classification, in each work area.Where several employees perform the same tasks on the same shift and inthe same work area, the employer may sample a representative fraction ofthese employees in order to meet this requirement. In representativesampling, the employer shall sample the employee(s) who are expected tohave the highest exposure to RCS.
Plan Assessments by personal
breathing zone airborne silicamonitoring and workplace fieldobservations were to be plannedfor:
➢ Two drywall installer job positions: 1. Sheetrock Installer, and
2. Finisher/Taper.
➢ Three concrete workers: 1. Remote Jackhammer Operator,
2. Drill/Core Drill Operator, and
3. Slab Saw Operator.
8/12/2019 JK, Inc - 8926 Kirby Drive, Houston Texas 77054 713-664-1597 [email protected] 5
Plan If results of personal monitoring
indicated potential elevatedairborne exposure to RCS aboveguidelines, then proceduralchanges were to be implementedwith additional air monitoring.
Investigation of various controlmeasures and provision ofequipment recommendations aswell as assistance withdevelopment of an updatedwritten Respiratory ProtectionProgram for the Company.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 6
MANUAL HAND SANDING
Details Substantial job site observations
of various construction tradeswere noted at several facility workareas. Specific focus was directedfor drywall installation andfinishing operations and site workpractices employed by companypersonnel and crew members.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 7
FLOOR SWEEP
Floor Sweep Compound Use at Site
Details Appropriate data review for RCS, including airborne quartz,
results was completed for OSHA compliance determinationsespecially related to selection and use of respiratoryprotection.
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DUST COLLECTION
8-Hour TWA OELs➢ OSHA Action Level (AL) =
25 ug/m3
➢ OSHA Permissible ExposureLimit (PEL) = 50 ug/m3
➢ ACGIH Threshold LimitValue (TLV) = 25 ug/m3
Monitoring Methods The validated industrial hygiene sampling
and analytical methods were: NIOSH0600 for respirable particulates using SKCaluminum cyclones, and NIOSH 7500 forcrystalline silica with lab analysis forcristobalite, quartz, and tridymite formsof RCS. Personal pumps were pre- andpost-calibrated with a primary standardand PVC filter media and processed to anaccredited American Industrial HygieneAssociation (AIHA) laboratory. Fieldblank samples were also prepared andincluded for analysis and proper QC.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 9
Monitoring Methods TSI Q-TRAK IAQ unit for CO2, CO,
Temperature, and %RH parameters atgenerally unconditioned work sites.
3M EVM-7 Unit: EnvironmentalAssessment of Particulate Matter (PM)concentrations in mg/m3 through use ofimpactor selection of airborne size criteria:- PM10, - PM4, and - PM2.5.
Grab samples collected at project workareas during separate drywallinstallation/hanging activities, and alsofinishing/sanding operations.
Other reported data documentationincluded concentrations of CO2 and CO,and Temperature and % Relative Humidityas well as Volatile Organic Compounds(VOCs) in units of parts per billion (ppb).
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 10
Drywall Project Scope of DiscussionLocations and Study Dates:
Houston, Texas and surroundingareas (i.e. Baytown, Friendswood,and Missouri City, Texas) for newconstruction projects involvingdefined work activities for drywallinstallation and hanging as well asdrywall finishing including tapeand float application, andpredominantly surface sanding. IHmonitoring and site observationswere performed for 12 site visitsduring February, March, May,October, and November 2017.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 11
SANDING
Drywall Project Scope of DiscussionTypes of Facilities:
Examples: school districts,colleges and university buildings,and a church.
Other construction trades/craftswere additionally performingcurrent work within the facilitiesassociated with new construction.
Specific segregated operationareas were not observed forfinishing/sanding activities.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 12
ELECTRIC SANDER
Drywall Work Results Some results for respirable particulates did
exceed published OELs [i.e. AmericanConference of Governmental IndustrialHygienists (ACGIH) Threshold Limit Values(TLVs)] and also OSHA regulations for RCSin the Construction industry.
Site observations and notation of existingcontrol measures and current work practicesand procedures were essential for datainterpretation and project documentation.Investigation of further control options wasalso conducted in addition to provision oftechnical recommendations related toavailable equipment modifications forassistance with limitation of existingoccupational airborne exposures to RCS.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston TX 77054 713-664-1597 [email protected] 13
MANUAL POLE SANDING
Drywall Work Results Use of available control measures for
dust collection resulted in decrease ofairborne RCS concentrations forinvestigated construction drywall worksite job positions.
Direct observations and assessment ofnoted variations in drywall finishingoperations at separate constructionprojects and use of source controlmeasures for dust collection indicateddecreased personal breathing zoneexposures for respirable particulates,airborne quartz concentrations, andalso calculated 8-hour Time WeightedAverage (TWA) exposures.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 14
POLE SANDING WITH VACUUM
Drywall Work Results Representative full-shift monitoring results
confirmed greater impact for sanding workactivities, and noted pertinent effectivenessof control measures employed.
An overall combination of naturalventilation, position and use of area fans fordilution ventilation and air cooling as wellas observations of most construction crewmembers employing N95 filtering facepieces were noted.
Appropriate written program documen-tation for Client site PPE requirementsshould be confirmed.
158/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 15
Drywall Work Results – Monitoring Data Summary
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 16
SELECTED DATA COMPARISONS
DRYWALL HANGER:
Without Use of Controls
Number of
Data Points
Range of Respirable
Particulates (mg/M3)
Range of Quartz
Concentrations
(mg/M3)
Calculated 8-Hour
TWAs
4 0.21 – 1.1 < 0.009 – 0.04 < 0.008, 0.008,
and 0.036
5 0.08 – 0.15 < 0.009 – 0.008 0.0079
With Use of Controls
4 0.33 – 0.51 < 0.010 < 0.009
Drywall Work Results – Monitoring Data Summary
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 17
SELECTED DATA COMPARISONS
FINISHER/TAPER:
Without Use of Controls
3 0.11 – 0.26 < 0.010 < 0.008, < 0.009
2 0.73 – 1.2 0.03 – 0.05 0.016, 0.027
With Use of Controls
2 0.02 – 0.05 < 0.01 < 0.009
2 0.028 – 0.040 < 0.009 – 0.02 < 0.009, 0.019
Drywall Work Results - Graph
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 18
0
10
20
30
40
50
60
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
µg/m
3
AIRBORNE RCS MONITORING RESULTS RELATED TO USE OF CONTROL MEASURES AT PROJECT
WORK SITES
WITHOUT
WITH
OSHA PEL
OSHA AL
DRYWALL WORK CONCLUSIONS
Exposure assessment monitoring and job positionobservations of drywall hanging and finishing operationswere addressed for various new construction work sites byIndustrial Hygiene (IH) personnel for airborne RCS datareview and interpretation.
Generally new construction projects investigated involvedextensive installation of drywall building materials withnecessary hanging on metal studs, fitting through use ofrasps or saws, tape and float of seams and surfaces,finishing, and sanding activities with visible dustparticulates generated, and work area cleaning using floor-sweep compounds.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 19
Concrete Project Scope of DiscussionLocations and Study Dates:
Houston, Texas for newconstruction projects involvingdefined work activities for variousconcrete cutting and demolitionoperations. Standard activitiesinvolved use of various automaticand manual saws employing wetmethods and other current controlmeasures, at a minimum, andconstruction equipment operationfor an outlined project scope ofwork as directed by the Client.
IH monitoring and site observationswere performed in 2017 and 2018.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 20
Concrete Project Scope of DiscussionTypes of Facilities:
Project observations verified useof wet methods, vacuum, anddebris collection to limit airbornebreathing zone exposures.Ambient environments providedaccess to dilution ventilation.
For segregated interiorenvironments, provision ofsupplemental ventilation wasemployed as an effective controlmeasure, and manual versusremote control equipmentoperations were investigated.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 21
Concrete Work Results Some results for respirable particulates did
exceed published OELs [i.e. AmericanConference of Governmental IndustrialHygienists (ACGIH) Threshold Limit Values(TLVs)] and also OSHA regulations for RCSin the Construction industry.
Site observations and notation of existingcontrol measures and current work practicesand procedures were essential for datainterpretation and project documentation.Investigation of further control options wasalso conducted in addition to provision oftechnical recommendations related toavailable equipment modifications forassistance with limitation of existingoccupational airborne exposures to RCS.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston TX 77054 713-664-1597 [email protected] 22
Concrete Work Results
Use of Table 1control measures fordust collectionresulted in decreaseof airborne RCSconcentrations forinvestigatedconcrete work jobpositions.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 23
(x) Jackhammers and handheld
powered chipping tools
Use tool with water delivery
system that supplies a
continuous stream or spray
of water at the point of
impact:
-When used outdoors None APF 10
-When used indoors or in an
enclosed area
APF 10 APF 10
OR
Use tool equipped with
commercially available
shroud and dust collection
system
Operate and maintain tool in
accordance with
manufacturer's instructions
to minimize dust emissions
Dust collector must provide
the air flow recommended
by the tool manufacturer, or
greater, and have a filter
with 99% or greater
efficiency and a filter-
cleaning mechanism:
-When used outdoors None APF 10
-When used indoors or in an
enclosed area
APF 10 APF 10
Concrete Work Results
Direct observations and assessment ofnoted variations in drywall finishingoperations at separate constructionprojects and use of source controlmeasures for dust collection indicateddecreased personal breathing zoneexposures for respirable particulates,airborne quartz concentrations, andalso calculated 8-hour Time WeightedAverage (TWA) exposures.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 24
Concrete Work Results Representative full-shift
monitoring results confirmedgreater impact for sawingwork activities, and notedpertinent effectiveness ofcontrol measures employed.
An overall combination ofnatural ventilation, positionand use of integrated waterdelivery system thatcontinuously fed water to thecutting surface was noted.
258/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 25
Appropriate written program documentation for Client site PPErequirements should be confirmed.
Concrete Work Results – Monitoring Data Summary
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 26
TYPE SAMPLE DESCRIPTION
TIME
(Min)
RESULTS
Respirable
Particulates
(mg/M3)Personal Core Drill Operator 388 < 0.02
TYPE
SAMPLE
DESCRIPTION
TIME
(Min)
RESULTS
Respirable
Particulates
(mg/M3)
RESULTS/%Si
Quartz
(mg/M3)
PersonalRemote Jack
Hammer Operator
339 < 0.02 0.01 [100%]
Personal Core Drill Operator 335 0.02 0.01 [50%]
Personal Slab Saw Operator 333 0.08 0.02 [29%]
CONCLUSIONS
Some personal monitoring results for airborne respirableparticulates did exceed published OELs including ACGIH TLVand OSHA PEL and AL new regulatory requirements for RCSwithout respect to considered use of respiratory protection.
Recommendation for revision of the company writtenRespiratory Protection Program (RPP) was provided to thespecific Client’s Safety Representative. Current exposuremonitoring data was used to assess employee protection andeffectiveness of control measures.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 27
CONCLUSIONS
Investigation of further existing control measures was alsoconducted in addition to provision of technicalrecommendations related to available equipmentmodifications for assistance with limitation of existingoccupational airborne exposures to RCS.
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 28
Some Additional Resources
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 29
Silica Resource Guide for Contractors published by ASSPIndustrial Hygiene Practice Specialty, September 2019
NIOSH 7500 SILICA, CRYSTALLINE, by XRD (filterre-deposition)
OSHA - Controlling Respirable Crystalline Silica inConstruction: Handheld Power Saws (Any BladeDiameter)
https://www.youtube.com/watch?v=pfYI31pF4Ng&feature=youtu.be
OSHA - Controlling Respirable Crystalline Silica: Handheld and Stand-Mounted Drills
https://www.youtube.com/watch?v=Yzo-sZ_PSic&feature=youtu.be
OSHA - Controlling Respirable Crystalline Silica: Jackhammers and Handheld PoweredChipping Tools
https://www.youtube.com/watch?v=e2uRD2dJ8vs&feature=youtu.be
JAN KOEHN, M.S., CIH
JK, INC.8926 Kirby Drive
Houston, TX 77054
Phone: (713) 664-1597E-mail: [email protected]
8/12/2019 JK, Inc - 8926 Kirby Drive Houston Texas 77054 713-664-1597 [email protected] 30