Silica. Jim Gillespie, Hilti North America. Gary Hatcher, NiSource. Tina Weeks, Zachry Group

Transcription

1 Silica Jim Gillespie, Hilti North America Gary Hatcher, NiSource Tina Weeks, Zachry Group

2 Respirable Crystalline Silica EEI Contractor Meeting April 27, 2017

3 Introduction OSHA has issued a standard to regulate the exposures to Respirable Crystalline Silica. The effective date was The implementation date for Construction is 9/23/2017*

4 Key Issues of the Standard - The Permissible Exposure Limit (PEL) and Action Level (AL) - An exposure assessment is required where an employee can be reasonably exposed above the AL - Written exposure control plans are required - Competent Person - Access Control is required for Construction work - Specified exposure control methods for 18 common construction tasks/equipment (aka - Table 1)

5 Key Issues of the Standard (cont.) - Medical Surveillance Requirements - Acceptable (and unacceptable) housekeeping practices are specified - Specific training requirements, including Hazard Communication - Recordkeeping requirements for monitoring, objective data and medical surveillance Note: There were several changes from proposed standard

6 Exposure Limits The new Permissible Exposure Limit (PEL) is 0.05 mg/m3 (50ug/m3) as an eight hour Time Weighted Average (TWA8) The Action Level (AL) is mg/m3 (25ug/m3) as an eight hour Time Weighted Average (TWA8) The PEL for Crystalline Silica covers all types of Crystalline Silica There is no minimum amount of silica concentration required for a material to fall under the standard Monitor with aluminum or nylon cyclone as in the past. May also use particle counter which is a real advantage for sampling.

7 Written Exposure Control Plan Written exposure control plans will be required (except where exposures will remain below the AL under any foreseeable conditions). The plan needs to include a description of: - Task(s) that involve exposures to Crystalline Silica - Engineering controls used - Work practices and PPE, including respiratory protection used - Housekeeping measures to limit exposures The plan must include procedures to restrict access to work areas Calls for a designated Competent Person to implement the exposure control plan An annual review of the plan is required

8 Competent Person The employer must designate an individual at each work site as the RCS competent person RCS Competent Person must perform routine worksite inspections for the following: Identify appropriate exposure control measures for the RCS disturbance task being performed Ensure control measures are being used effectively Equipment is in good condition Appropriate housekeeping practices are being followed Appropriate PPE is being used when required There is no visible dust affecting employees or bystanders

9 Access Control

10 Engineering and Work Practice Controls If engineering and work practice controls are insufficient to reduce the silica levels to below the PEL, they still must be used in conjunction with respiratory protection Wet methods, HEPA filtered equipment and ventilation are the primary means to reduce silica exposures OSHA does not prohibit employee rotation as a means to keep exposures below the PEL

11 Personal Protective Equipment Respirator use will be required if engineering and/or administrative controls are not effective or feasible in keeping Crystalline Silica levels below the PEL Follow Respiratory Protection standard when providing acceptable protection against Crystalline Silica exposures There are no requirements for protective clothing

12 Housekeeping Dry sweeping and/or dry brushing is permitted only if other methods (i.e., wet methods, HEPA vacuuming, etc.) are not feasible. Compressed air cleaning is not permitted unless it is used in conjunction with a ventilation system or no alternative method is feasible.

13 Table 1 Paragraph (c) of the Construction standard contains Table 1 Specified Control Methods When Working With Materials Containing Crystalline Silica. For 18 tasks, it lists: Equipment/task Engineering and work practice control methods Required respiratory protection (if any) and minimum Assigned Protection Factors (APF) Tasks covered by Table 1: Stationary masonry saw Hand-held power saws Walk-behind saw Drivable saw Rig-mounted core saw or drill Impact and rotary-hammer drills Dowel drilling rigs Vehicle-mounted drilling rig Jackhammers and handheld powered chipping tools Hand-held grinders (concrete grinding) Tuck-pointing (mortar grinding) Weld-behind milling machine and floor grinder Drivable milling machines (small, large) Crushing machine Vehicle mounted chipping hammer Grading and excavating

14 Table 1

15 Table 1 For these 18 tasks, if all of the engineering, work practices and respiratory protection requirements are met, the monitoring requirements of the standard do not apply In the table, the required respiratory protection is listed for tasks that are 4 hours or less, and if the task lasts longer than 4 hours This does not permit using a respirator only after 4 hours for a task that lasts longer than 4 hours. A respirator is required for the entire job Tasks that are not addressed by Table 1 must be performed under the requirements of the standard

16 If your task is not on Table 1, or you cannot follow the exact controls listed, then you must perform the following exposure assessment steps

17 Medical Surveillance Requirements for Construction when a respirator is required under the standard for 30 days or more per year Requires an initial exam within 30 days of initial assignment and periodic exams at least every 3 years. The exam includes: - Medical and work history - Physical exam with special emphasis on the respiratory system - Chest X-ray - Pulmonary function - Test for latent TB infection - Other tests as deemed appropriate

18 Recordkeeping The recordkeeping requirements are the same as other standards, with the exception that the employee s social security number is required on the documentation. Affected employees must be notified of monitoring results within 5 working days for Construction (15 General Industry)

19 MANUFACTURER S SOLUTIONS FOR DUST CONTROL Jim Gillespie Director of Business Development Hilti Inc. EEI Spring H&S Conference Date

20 NEW STANDARD OFFERS 3 OPTIONS FOR EXPOSURE CONTROL PROVIDING FLEXIBILITY & DEFINED SOLUTIONS OSHA Table 1 Choose a pre-determined control solution, based on your application, from OSHA Table 1 Exposure Control Methods for Silica Dust. Objective data performance testing Utilize performance or objective data (internal or 3 rd party) to document that workers performing a particular application are in compliance with the permissible exposure limit of 50 μg/m 3 averaged over an eight hour day. Scheduled air monitoring Periodically test for a particular application to validate if the user falls under the permissible exposure limit of 50 μg/m 3. Customer presentation Silica dust control February,

21 DUST CONTROL SYSTEMS WILL BE EITHER WET OR DRY Dry solutions Tool Insert Accessory Vacuum Wet solutions Tool Insert Supplied Water Customer presentation Silica dust control February,

22 SOLUTIONS FOR DUST-GENERATING APPLICATIONS Drilling Cordless rotary up to 5/8 Breaking Drilling up to 1-1/8 SDS-MAX Up to 2 Dry coring up to 6 Wet coring up to 6-1/2 SDS-max rotary hammers Cutting and Grinding Wall breakers Medium-duty floor demo Heavy-duty floor demo Cutting/tuck Grinding Dry cutting up to pointing 4-3/4 Customer presentation Silica dust control February, 2017 Wet cutting up to 6 Wet slitting/cutting 22

23 CORDLESS ROTARY HAMMER WITH ON- BOARD DUST COLLECTION [TABLE 1, SECTION VII] Engineering controls 99% filter efficiency Filter-cleaning mechanism HEPA for holecleaning NOTES: Table 1 Requirements Respirator needed? No Performance data allows for use with current system without respirator, under defined conditions Table 1 solution requires a filter cleaning mechanism in the vacuum OSHA Compliance Method Objective Data Customer presentation Silica dust control February,

24 SDS+ ROTARY DRILLING WITH A SHROUD AND DUST COLLECTION SYSTEM [TABLE 1, SECTION VII] Engineering controls 99% filter efficiency Filter-cleaning mechanism HEPA for holecleaning NOTES: Table 1 Requirements System available for any Hilti rotary hammer drill with a depth gauge HEPA filter not required for drilling, only required for hole cleaning HEPA filter not required for drilling, only required for hole cleaning HEPA does not necessarily provide an added benefit: the more material collected by the filter and the smaller the filter pore size, the faster it clogs Customer presentation Silica dust control February, 2017 Respirator needed? OSHA Compliance Method No Table 1 24

25 SDS-MAX DRILLING (WITH HILTI SDS-MAX COMBIHAMMER) WITH A SHROUD AND DUST COLLECTION SYSTEM OSHA TABLE 1, SECTION VII] Engineering controls 99% filter efficiency Filter-cleaning mechanism NOTES: HEPA for holecleaning Table 1 Requirements Respirator needed? HEPA system required for cleaning out holes Compliance Method No Table 1 Consider Hilti SafeSet solution for drilling applications eliminates the requirement to clean holes for anchoring by using a Hollow drill bit Customer presentation Silica dust control February,

26 SAFESET AND HOLLOW DRILL BITS [TABLE 1, SECTION VII] Engineering controls 99% filter efficiency Filter-cleaning mechanism NOTES: HEPA for holecleaning Table 1 Requirements Respirator needed? OSHA Compliance Method No Table 1 Eliminates the need for manual hole cleaning when SafeSet system is used with either HIT-HY 200 A/R or HIT-RE 500 V3. For chemical anchoring applications in cracked/uncracked concrete, and masonry If compressed air is used to clean holes, HEPA filtered vacuum is needed Customer presentation Silica dust control February,

27 SDS-MAX CHISELING (WITH SDS-MAX COMBIHAMMER WITH A SHROUD AND DUST COLLECTION OR CONTINUOUS WATER [TABLE 1, SECTION X] Engineering controls 99% filter efficiency Filter-cleaning mechanism NOTES: Table 1 Requirements Respirator needed? Outdoor: >4 hours or any indoor (APF 10) OSHA Compliance Method Table 1 DRS-Y shroud with Hilti vacuum provides a full Table 1 compliant solution for SDS-Max drilling, chipping or breaking Customer presentation Silica dust control February,

28 JACKHAMMERS AND HANDHELD POWERED CHIPPING TOOLS SHROUD AND DUST COLLECTION SYSTEM OR CONTINUOUS WATER [TABLE 1, SECTION Table X] 1 Requirements Engineering Respirator controls needed? 99% filter efficiency Filter-cleaning mechanism NOTES: Outdoor: >4 hours (APF 10) Indoor: APF 10 OSHA Compliance Method Table 1 DRS-B shroud with Hilti vacuum provides a full Table 1 compliant solution for all Hilti breakers (except the TE 3000-AVR) Customer presentation Silica dust control February,

29 HANDHELD POWER SAWS (ANY BLADE DIAMETER) CONTINUOUS WATER [TABLE 1, SECTION II] Engineering controls Water delivery system NOTES: Table 1 Requirements Respirator needed? Outdoor: >4 hours (APF 10) Indoor: APF 10 OSHA Compliance Method Table 1 Most gas powered saws are equipped with a water delivery system Customer presentation Silica dust control February,

30 RIG-MOUNTED CORE SAWS OR DRILLS CONTINUOUS WATER SYSTEM [TABLE 1, SECTION VI] Engineering controls Table 1 Requirements Respirator needed? OSHA Compliance Method Water delivery system No Table 1 NOTES: Continuos water delivery system either tank or hose Hilti interprets hand-held core drilling as also being Table 1, section VII "handheld...drills". See previous slides for requirements. Customer presentation Silica dust control February,

31 HANDHELD GRINDERS FOR USES OTHER THAN MORTAR REMOVAL CUTTING OR GRINDING HOOD [TABLE Table 11, Requirements SECTION XII] Engineering controls NOTES: Cutting or Grinding hood Respira tor needed? 99% filter efficiency Outdoor Filter-cleaning mechanism or s: none cyclonic pre-separator Indoors: > 4 25 cubic feet per minute hours (cfm) of airflow per inch of (APF wheel diameter 10) OSHA Compliance Method Table 1 4-1/2 grinders would require cfm; 5 grinders would require 125 cfm Customer presentation Silica dust control February,

32 ELECTRIC CONCRETE CUTTERS CONTINUOUS WATER SYSTEM [TABLE 1, SECTION XII] Engineering controls NOTES: Respira tor needed? 99% filter efficiency Outdoor Filter-cleaning mechanism or s: none cyclonic pre-separator Indoors: > 4 25 cubic feet per minute hours (cfm) of airflow per inch of (APF wheel diameter Table 1 Requirements Performance data allows for use 10) with current system without respirator, under defined conditions Table 1 solution requires a vacuum with 225 cfm for the DCH 230 or 300 cfm for the DCH 300 (Table 1 compliant system available by June 2017) OSHA Compliance Method Objective Data Customer presentation Silica dust control February,

33 FLOOR GRINDER CONTINUOUS WATER SYSTEM [TABLE 1, SECTION XII] Table 1 Requirements Engineering controls Respira tor needed? 99% filter efficiency Outdoor Filter-cleaning mechanism or s: none cyclonic pre-separator Indoors: > 4 25 cubic feet per minute hours (cfm) of airflow per inch of (APF NOTES: wheel diameter Performance data allows for use 10) with current system without respirator, under defined conditions Table 1 solutions for the DG 150 (6 wheel) require vacuum with 150 cfm or greater (Table 1 compliant system available by June 2017) OSHA Compliance Method Objective Data Customer presentation Silica dust control February,

34 VACUUMS- MUST HAVE 99% EFFICIENCY AND FILTER CLEANING OR CYCLONIC PRE SEPARATOR BE CONSCIENCE OF YOUR CFM 1) CFM = Cubic Feet per Minute airflow Customer presentation Silica dust control February,

35 WHERE TO GO FOR MORE RESOURCES OSHA silica website: Tool Manufacturer websites Hilti dustless information website: Overall information on the dustless topic White paper which simplifies the standard Links to OSHA informational sites Valuable industry-related questions and answers Dustless educational webinars: Informative and complimentary a topical professional directly with questions: silicadustquestions@hilti.com Customer presentation Silica dust control February,

36 Freeport LNG Liquefaction Project Occupational Health Tina Weeks OH Manager

37 Silica Program for Construction Written Exposure Control Plan Qualitative Exposure Assessment (QEA) Sampling Plan Sampling Assessment Sampling Communications System Adjustments

38 New Silica Standard for Construction The new standard goes into effect June 23, 2017 Exposure Control Plan Monitoring Competent Persons Engineering & Work Practice Controls Medical Surveillance Training OH Recordkeeping (COC, certs, letters, lab results, photos, etc.)

39 Qualitative Exposure Assessment The QEA is the first step in determining what health hazards exist at the site The QEA is developed by reviewing Safety Data Sheets, interviewing workers, observing work activities, working with planning, procurement & supervision on appropriate engineering and work practices controls. Assign Risk Rankings based on findings Based on AIHA Exposure Assessment Strategy

40 Qualitative Exposure Assessment

41 Sample Plan Develop a Sample Plan based on the highest risk By referring to the qualitative exposure assessment to determine substance(s) and craft to sample Review Safety Data Sheets of products/materials used (chemicals, paints, rods, pipe, etc.) Talk to customer, employees performing job, etc. Gather as much information about the jobs as possible Sample plans & QEA s are revised as work scope changes

42 Sample Plan

43 Sample Tracker

44 Silica Exposures

45 Examples of Engineering Controls

46 Examples of Engineering Controls

47 Examples of Engineering Controls

48 Examples of Work Practices

49 Examples of Work Practices

50 Examples of Work Practices