how will silica exposure considerations change the concrete product industry? ncma annual convention...

How Will Silica Exposure Considerations Change the Concrete Product Industry?

NCMA Annual Convention and MCPX

Anaheim, CA

February 23, 2006

Kevin Campbell, CIH, CSP, CEM

CIH Service, LLC – Nashville, TN

copyright © 2006 CIH Service, LLC

Efforts are currently underway to establish an OSHA standard for

Crystalline Silica


Current Respirable Silica Permissible Exposure

LimitBased upon formula:

= 10 milligrams/meter3 (% Silica + 2)

Controls silica to ~ 0.1 mg/m3 (when respirable dust is 100% silica)


History of Current Standard

1970 – PEL formula adopted by OSHA from 1969 ACGIH TLV

1989 - OSHA established a “fixed” PEL at 0.1 mg/m3 for respirable quartz

1992 - Fixed PEL was vacated


Silica Control HistoryAugust 1996 – OSHA Special Emphasis

Program (SEP) startedOctober 1996 – International Agency for

Research on Cancer (IARC) listed silica as “Carcinogenic to Humans”

1997- present. Silica standard on OSHA Unified Agenda

2003- SBREFA report completed


Current Status of Silica Rulemaking Process

Pre-Rule Stage Next Target Date = April 2006

Complete Peer Review of Health Effects and Risk Assessment due


Future Actions Still NeededAdvanced Notice of Proposed Rulemaking (ANPR)

must occur Notice of Proposed Rulemaking

Public Comment periodPublic HearingPost-Hearing Comment period

Final Rule must be published in the Federal RegisterPhase-in period for Compliance


Other Crystalline Silica Exposure Standards

NIOSH REL = 0.05 mg/m3

ACGIH TLV = 0.025 mg/m3 NIOSH and ACGIH do NOT

consider economic impact on business community to meet the standards recommended


Draft Proposed Crystalline Silica PEL

0.1 mg/m3 with 0.05 mg/m3 medical Action Level

0.075 mg/m3 with 0.04 mg/m3 medical Action Level

0.05 mg/m3 with no medical Action Level


Monitoring

Initially (Exception for abrasive blasters in type CE abrasive blasting respirators or employers with objective data)

Quarterly if greater than PEL Every 6-months if greater than

Action Level Observation of Monitoring and

Employee Notifications


Regulated Areas

Required for areas that exceed or are reasonably expected to exceed the PEL

Established by “Competent Person”

Demarcated with signs, barriers or negative pressure enclosures


Competent Person

Definition – one who has the knowledge to identify and evaluate existing and predictable crystalline silica hazards in the workplace and who has authorization to take corrective measures to control employee exposure to crystalline silica

Designated for each worksite


Competent Person Responsibilities

Evaluate exposures and existing controlsImplement corrective measures, including

temporary work stoppageDefine, demarcate and check Regulated areasInspect Abrasive Blasting activitiesCommunicate with other employers at the

worksite to inform of regulated area boundaries around abrasive blasting operations


Prohibited Practices Job rotation Use of compressed air, brushing or dry

sweeping for cleaning Eat, drink or use tobacco in regulated areas Remove dust from clothing by blowing or

shaking Abrasive Blasting using Silica in enclosed

areas


Abrasive BlastingOnly in Regulated areasType CE, continuous flow respirator

(hood or helmet)Blasting areas cleaned using:

HEPA vacuums Wet MethodsDust suppressants

If dry blasting with sand in an open area, alternative blast medias must be evaluated


Personal Protective Equipment

Respirators required for employees exposed above the PEL

Or for those who request it


Protective Work Clothing

New disposable clothing provided each day

Non-disposable clothing such as coveralls or full bodied clothing


Hygiene Facilities

Change rooms Only authorized employees allowed to remove

non-disposable clothing for laundering, maintenance or disposal

Contaminated clothing placed and stored in closed containers labeled with Silica hazard warning labels

Laundry service must be informed of potential silica contamination including harmful effects

Contaminated clothing transported in sealed impermeable bags with hazard label


Shower Facilities

Considered as an option for those exposed above the PEL

May require employer to ensure employees shower at the end of each work shift


Lunchrooms

Must be below the PELMay require temperature controlled,

positive pressure, filtered air supply for lunchrooms

May require HEPA filtered vacuums for cleaning clothes before entering lunchrooms, change rooms or shower rooms


Housekeeping

HEPA vacuum Silica accumulationsPrevent accumulation of silica-

contaminated water that could dry and result in residue that could contribute significantly to airborne exposures


Health Screening

Offered initially and annually for all exposed above the Action Level (or PEL if 0.05 mg/m3)

Before assignment to tasks above Action Level

Whenever employee reports silica related symptoms

Within 30 days of termination


Health Screening Content

Occupational and health history with emphasis on silica exposures and other respiratory agents

Physical exam with emphasis on respiratory system

Chest X-Ray

Pulmonary Function Test (PFT)

Any other tests deemed necessary by the HCP

Annual review of history and physical exam with emphasis on respiratory system


Health Screening Info Employer Provides to

HCPDescription of employee’s job as it relates to

silicaA copy of paragraph (k), Employee Health

Screening section of the standardResults from employee exposure monitoringResults of previous health screeningA description of PPE


HCP Written Opinion Shared with employee within 15 days Must include: Employee Health condition related to

silica. Non-silica findings must remain confidential from the employer

A statement whether employee should be referred to a pulmonary specialist. A list of three reasonably accessible pulmonary specialists must be provided if referred for additional testing

A statement HCP has informed employee of silica screening results


Pulmonary SpecialistsEmployer must make

one choice available from the list provided by the HCP

Written opinion must be obtained within 30-days of examination

Copy of results to employee within 15-days


Pulmonary Specialists (continued)

Specialists written opinion must include:Employee health condition related to silicaRecommended work limitations, such as

restrictions or removal with probable durations

Statement results were shared with employee

Employer must report all cases of silica-related disease identified by the pulmonary specialist to NIOSH


Hazard Communication

All employees potentially exposed are informed and trained initially, prior to assignment

Must be informed on the requirements of the silica standard and how to access or obtain a copy


Recordkeeping

Historical or objective data Exposure Measurements–30 years Health Screening Records–Employment+30 years Respirator Fit Test Records-most current All records may be kept in any form Available upon request to Asst. Secretary, subject

employee or qualified representative Provision for transfer of records upon sale or close

of business


Some Items that Were NOT Included

Written Control PlanMedical Removal Provisions Consideration for Non-standard

work shifts (greater than 8-hours)


Potential Impacts

At PEL of 0.1 mg/m3:Estimated ~⅓ may have overexposure areas

or tasksDry sanding, sawing, abrasive blasting and

mixer cleaning tasks produce most overexposures

Most can be controlled through improved housekeeping, work practices and ventilation


At PEL of 0.075 mg/m3

Estimated ~½ of workplaces may have tasks or areas with overexposures

In addition to tasks that exceeded 0.1 mg/m3, other tasks such as additive mixing, material loading/unloading may produce overexposures, especially in open cab mobile equipment


At a PEL of 0.05 mg/m3

MIOSHA 2004 Annual Report on Silicosis - 60% of workplaces sampled in excess of NIOSH REL or PEL at 0.05 mg/m3 (Note- Data summarized for all inspected business!)

Regulated areas now extend into more areas Control options include automation, control rooms,

enclosures, isolation, closed cabs on mobile equipment, wet methods for cleaning, part-time work shifts (4-6 hours duration)…

Respirators!


Example of Compliance Costs with PEL at 0.1 mg/m3

• Plant employs 20 laborers with 1/3 Above PEL and 1/3 Above Action Level = 12 employees

• Analytical costs for quarterly and Semi-Annual monitoring = $3,360

• Signs for Regulated areas = $14 minimum for 2 signs

• 85 boxes/yr of 3M 8210 N95 disposable dust masks = $1,154


Compliance Costs (continued)

• Baseline Health Screening = $2,160 ($180 per employee for 12 employees)– $35 Physical– $65 PFT– $80 Chest X-Ray

• Year1 and Year2 = $1200 (Physical and PFT only…Chest X-ray every 3rd Year)

• Estimate does not include time away from work!


Compliance Costs (continued)

• Annual Fit Tests and Training = $120 (~$20 per employee)

• Disposable Protective Clothing = $5,595 ($3.73 per employee per day)

• HAZ-COM Training = $160• Recordkeeping = $60• Minimum Annual Total ~ $12,000 per

facility


Other Costs• Lunchroom facilities• Lunchroom HVAC• Lunchroom HEPA

vacuums• Shower Facilities• Uniforms• Laundry Service, or• Washer/Dryer eqt.• Utility Costs

• Dust Collectors or other Local Exhaust

• HEPA Vacuum for Work Areas

• Rent or buy sampling equipment

• Quarterly Survey by Consultant

• Miscellaneous costs (laundry bags and labels, S&H samples, communications, etc.)


Compliance Costs Per Facility

• Minimum ~$12,000/year

• Costs go up significantly if Facility Changes are needed for Lunchrooms, Shower facilities and Exhaust Ventilation (add~ $10K-$500K)


Recommendations for Action!

Evaluate your workplace!Formulate a silica exposure

control plan!Communicate with your NCMA

representatives on how this would impact your business!

Communicate with your elected officials to educate them on silica issues!


Summary

A specific OSHA silica standard may cause significant changes in Concrete Products industry

As the PEL is reduced, more areas would require actions and additional expense


615.791.3379

www.cihservice.com

[email protected]

http://www.cihservice.com/

mailto:[email protected]

how will silica exposure considerations change the concrete product industry? ncma annual convention...

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