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Introduction Definitions Air Monitoring Regulated Areas (General Industry) Labels and other warnings Hygiene Procedures Medical Management Program Recordkeeping	Our Silica Control Program Specified Exposure Control Methods (Construction) Engineering and Work Practice Controls Exposure Control Plan Housekeeping Employee Training Respiratory Protection

Introduction

The sample Silica Control Program (“Sample Program”) outlined below is a generic, hypothetical example of a written program. It can be used as a resource in developing a program. Although such a sample may be helpful in developing a program, an actual written program must reflect, and be specific to, the applicable workplace. Therefore, the Sample Program should only be used as a resource, and must be adapted to address the specific facility that it covers. A written program should convey the actions that are being taken to help reduce the risk of silicosis. Those elements not applicable to your operations can be edited or removed, and additional program elements can be added. An editable version of the sample program is included.

Our Silica Control Program

General Company Policy

The purpose of this notice is to inform you that our company has established a Silica Control Program that includes all employees exposed to respirable crystalline silica at or above the OSHA Action Level in this program. The program will include air monitoring to assess employee exposures, engineering and work practice controls to reduce silica exposures, medical examinations (with emphasis on the lungs) to check on employees' health, providing appropriate respiratory protection, and employee training. The purpose of this program is to prevent occupational disease, primarily silicosis, from silica exposures in the workplace. The program applies to employees in the following departments in our company:

Maintenance
Fabrication
Abrasive Blasting
Department 356

The safety and health manager, <name> is the program coordinator, acting as the representative of the plant manager/project manager, who has overall responsibility for the program. <name> will review and update the program, as necessary. Copies of the written program may be obtained from <name> in Room 555 (and are available in the job office trailer).

Under this program, you will be informed of the possible effects of silica exposure on your health; the control measures implemented to reduce exposures; the purpose and selection of respiratory protection and instructions on fitting, use and care; and the purpose of medical monitoring.

Compliance with our company's safety and health requirements, including the Silica Control Program, is a condition of employment. Failure to comply with the requirements of this program will result in disciplinary action outlined in the company's safety and health program.

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Definitions

Action Level means a concentration of airborne respirable crystalline silica of 25 micrograms per cubic meter of air (µg/m³) or 0.025 milligrams per cubic meter of air (mg/m³).

Employee Exposure means the exposure to airborne respirable crystalline silica that would occur if the employee were not using a respirator.

Respirable Crystalline silica means quartz, cristobalite and/or tridymite contained in airborne particles that are determined to be respirable by a sampling device designed to meet the characteristics for respirable-particle-size-selective samplers specified in the International Organization for Standardization (ISO) 7708:1995: Air Quality - Particle Size Fraction Definitions for Health Related sampling.

Permissible Exposure Limit (PEL) means a concentration of airborne respirable crystalline silica of 50 µg/m³ or 0.05 mg/m³, calculated as an 8-hour Time Weighted Average (TWA).

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Specified Exposure Control Methods (Construction)

For each employee engaged in a task identified in Table 1 of the OSHA Respirable Crystalline Silica standard for Construction (29 CFR 1926.1153), we will fully and properly implement the engineering controls, work practices, and respiratory protection specified for the task in Table 1. In implementing these control measures, we will:

For tasks performed indoors or in enclosed areas, provide a means of exhaust as needed to minimize the accumulation of visible airborne dust;
For tasks performed using wet methods, apply water at flow rates sufficient to minimize release of visible dust;
For measures implemented that include an enclosed cab or booth, ensure that the enclosed cab or booth;

Is maintained as free as practicable from settled dust;
Has door seals and closing mechanisms that work properly;
Has gaskets and seals that are in good condition and working properly;
Is under positive pressure maintained through the continuous delivery of fresh air;
Has intake air that is filtered through a filter that is 95% efficient in the 0.3-10 µm range (e.g., MERV-16 or better); and,
Has heating and cooling capabilities.

Where an employee performs more than one task in Table 1 during the course of the shift, and the total duration of all tasks combined is more than four hours, the required respiratory protection for each task will be the respiratory protection specified for more than four hours per shift. If the total duration of all tasks in Table 1 combined is less than four hours, the required respiratory protection for each task will be the respiratory protection specified for less than four hours.

For tasks not listed in Table 1, or where engineering controls, work practices, and respiratory protection are not fully implemented, alternative control measures will be implemented as discussed below.

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Air Monitoring

Air monitoring surveys are used to evaluate personal, breathing zone, employee exposure levels for each process and operation. Air sampling is conducted on representative employees in each department/job category on each shift to evaluate 8-hour time-weighted average exposures to respirable crystalline silica. The monitoring results are used to:

Determine which employees should be included in the Silica Control Program.
Identify which equipment, employee locations, and areas are candidates for installation of engineering control measures; and
Select appropriate respirators to reduce employee exposures.

Air sampling will be conducted by a Certified Industrial Hygienist (CIH) through our insurance provider and/or an outside Consulting Firm. Monitoring will be conducted using high flow sample pumps and cyclones, or other recognized size selective devices, and analyzed by an AIHA accredited laboratory using OSHA Method ID-142 or NIOSH Method (Method 7500). The air sampling pumps are to be calibrated before and after the survey to ensure validity of the measurements and results.

Initial surveys are conducted to evaluate representative employees' exposures during operations at this facility/job site. If initial monitoring indicates that employee exposures are at or above the OSHA Action Level, but below the OSHA PEL, monitoring will be repeated within six months of the most recent monitoring. Where initial or subsequent exposure monitoring reveals that employee exposures are above the OSHA PEL, monitoring will be repeated within three months of the most recent monitoring. Monitoring will continue at the required frequency until at least two consecutive measurements, taken at least seven days apart, are below the Action Level.

Employees will be informed of air sampling results within 15 working days after completion of an exposure assessment (five days for construction). Affected employees will be notified of the air sampling results either individually in writing, or by the posting of the results in an appropriate location that is accessible to all affected employees. Where exposure monitoring shows employee exposures are at or above the OSHA PEL, the notification will inform the employee of the actions that will be taken to reduce employee exposures to or below the PEL.

Additional monitoring will be conducted if changes in production, equipment or controls are implemented to determine the effect of those changes on employee respirable crystalline silica exposures. Any employee wishing to obtain further information or the monitoring results should contact <name>.

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Engineering and Work Practice Controls

If silica exposures exceed the OSHA PEL, feasible engineering and/or work practice controls will be implemented to reduce employee exposures to nonhazardous levels. The ultimate goal is to eliminate hazardous employee exposures to silica levels (i.e., above the OSHA PEL). However, where this is not feasible, measures to reduce employee exposures to respirable silica will be implemented. For example, the following controls have been implemented to date:

General Industry Examples

In the Paint Prep Department, an abrasive blasting room, with ventilation system, was constructed for blasting operations. The blasting employee is required to wear an abrasive blasting respirator during blasting operations.
The possibility of using a substitute material for the currently used silica sand in abrasive blasting is being investigated and studied.
In the Fabrication Department, local exhaust ventilation was installed on the grinders and polishers to reduce airborne respirable silica levels. This significantly reduced the operator's exposures to respirable silica.
An equipment inspection, maintenance and testing program was established to reduce airborne silica generated by poorly maintained equipment. Periodic inspections are conducted to ensure equipment is operating properly with all enclosures and ventilation systems in place and operating effectively.
An industrial ventilation consulting firm will continue to work with us on designing and installing effective engineering controls for dust-generating equipment.

Construction Industry Examples

Engineering controls have been implemented to reduce employee exposures to airborne silica and respirable dust associated with the operation of the heavy equipment, including trucks, loaders, etc. Examples of the engineering controls include:
1. Providing enclosed cabs for trucks and front-end loaders
2. Ordering new equipment with air-conditioned cabs to provide for the safety and comfort of equipment operators.
3. Controlling dust generated by frequently wetting down roadways used by trucks and other mobile equipment.
Concrete cutting operations are no longer performed "dry." Wet cutting equipment has been purchased for concrete cutting operations to reduce airborne dust levels.
An equipment inspection, maintenance and testing program was established to reduce airborne silica generated by poorly maintained equipment. Periodic inspections are conducted to ensure equipment is operating properly with all enclosures and ventilation systems in place and operating effectively.

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Regulated Areas (General Industry)

Access to areas where employee exposures to airborne concentrations of respirable crystalline silica is, or can reasonably be expected to be, in excess of the OSHA PEL will be designated as Regulated Areas. Access to Regulated Areas is limited to authorized persons required by work duties to be in the regulated area, designated representatives of employees observing monitoring procedures, and any person authorized by the Occupational Safety and Health Act.

Regulated areas are marked with warning signs. The warning signs are posted at or near entrances to work areas, and in work areas where a potential crystalline silica exposure exists.

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Exposure Control Plan

A written Silica Exposure Control Plan has been developed as a separate document. The plan contains the following information:

A description of the tasks in the workplace that involve exposure to respirable crystalline silica;
A description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task; and,
A description of the housekeeping measures used to limit employee exposure to respirable crystalline silica.
(Construction) A description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed to respirable crystalline silica and their level exposure. This includes exposures generated by other employers or sole proprietors.

The safety director <name> will review and evaluate the effectiveness of the written exposure control plan at least annually and update as necessary.

(Construction) - <name> has been designated as the competent person who will make frequent and regular inspections of job sites, materials, and equipment to implement the written exposure control plan.

The written exposure control plan is available for examination and copying, upon request, to each employee and their designated representatives.

Sample Exposure Control Plan (General Industry) Sample Exposure Control Plan (Construction)

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Labels and Other Warnings

The purchasing department manager and/or quality control manager (for company produced products) is responsible for ensuring that new materials, mixtures and other products containing more than 0.1% crystalline silica will have required specific labels, and Safety Data Sheets are on file and available to employees.

The purpose of warning signs and labeling is to inform and alert workers of the presence and type of hazard associated with the area or product so that appropriate precautions may be taken.

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Housekeeping

The following housekeeping control measures have been established to reduce airborne dust exposures. Each department supervisor is responsible for housekeeping in their area.

Cleaning with compressed air and dry sweeping silica are prohibited.
HEPA- filtered vacuuming and washing down with water are used in place of dust-producing methods.
Emphasis has been placed on maintaining surfaces free of accumulation of silica dust and on prompt spill cleanup to help reduce the potential for material to become airborne.

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Hygiene Procedures

The following hygiene procedures have been implemented to reduce employee exposures at the site and the potential for contamination of the employees' vehicle and home. Each department manager is responsible for enforcing hygiene procedures.

Smoking, eating and drinking are prohibited in areas with potential silica exposure.
Employees' work clothing must be HEPA-filtered vacuumed before entering the lunch and break area and before removal at the end of the shift.
Cleaning of work clothing by shaking or blowing with compressed air is prohibited.
Work clothing must be removed at the end of the shift and employees must change into clean clothes prior to leaving the site.

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Employee Training

As part of our Hazard Communication Program, employees will be informed of silica health hazards; the specific operations that could result in exposure to respirable crystalline silica above the OSHA PEL; the specific procedures implemented to protect employees from exposure to respirable crystalline silica including work practices and the use of personal protective equipment (e.g., respirators and protective clothing); the contents of the OSHA Silica Standard; the purpose and description of the medical surveillance program; and the identity of the competent person (construction).

The safety and health manager will review our employee training program and advise the plant manager/project manager on training and retraining needs. As part of the assessment of the training program, the safety and health manager will obtain input from employees regarding the training they have received, and any suggestions for improvement.

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Medical Management Program

All employees exposed to crystalline silica above the OSHA Action Level will be included in the medical management program. Employees assigned to the following departments or areas are included in the program.

Maintenance
Fabrication
Department 356

Our company has contracted with <Name> to perform baseline and periodic medical examinations, evaluate chest x-rays and advise of any action needed as a result of the evaluation. The medical examination is performed by a licensed or certified physician. The chest x-rays are classified according to the 1970 ILO International Classifications of radiographs of Pneumoconiosis by a NIOSH certified class "B" reader.

Problem chest x-rays are reviewed to determine if further evaluation is needed. The following steps are taken:

With a positive chest x-ray (1/0 or greater) the worker is placed in mandatory respiratory protection, or if already wearing a respirator, the program is reevaluated to assure proper fit and that the elements of the OSHA Respirator Standards 29 CFR 1910.134/1926.134 are being met.
The worker is referred to a physician specializing in lung diseases for a medical evaluation and medical monitoring as warranted by the examining physician. A written opinion from the examining physician as to whether the employee has any detected condition that would place the worker at an increased risk is provided to the employee, and the company, while specific medical findings remain confidential.
An employee with or without roentgenographic evidence of silicosis who has respiratory distress and/or pulmonary functional impairment will be fully evaluated by a physician qualified to advise the employee whether he/she should continue working in a dusty trade.
All medical test results will be discussed with the worker by a physician.

The company's policy is to continually evaluate the effectiveness of our Silica Control Program. One way is through periodic medical examinations so that our employees' health and well-being are maintained. We want to secure day-to-day cooperation from our employees to ensure the success of this program.

In accordance with 29 CFR 1910.1020/1926.1020, medical records will be maintained for at least 30 years following the employee's termination of employment, unless the employee is employed for less than one year and the records are provided to the employee upon termination.

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Respiratory Protection

All employees exposed to crystalline silica above the OSHA Action Level will be included in the respiratory protection program.

Appropriate respirators are selected based on the employee exposure levels. Employees will be fit tested to ensure an adequate fit. Employees are then trained in the use and care of respiratory protection as part of the training program.

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Recordkeeping

Records are maintained, and made available to employees upon request, for all medical examinations, air sampling surveys and training sessions. Employees' requests for records should be directed to <name> in Room 555.

Survey information includes sampling and analytical methods; type of personal protective equipment, if any, in use at the time of sampling; and the monitoring results.
Records will be maintained for at least 30 years following termination of a worker's employment.
Each employee is able to obtain information on his/her exposure and medical examinations.

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Additional Information

All employees or their designated representatives can obtain further information on the written program, the OSHA Respirable Crystalline Silica standard, and/or records of air monitoring results or medical exams at the Safety and Health Office, Room 555.