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Introduction The purpose of a Silica Control Program is
to ensure that employees at risk of developing occupational disease,
specifically silicosis, are adequately protected against the hazardous
effects of silica exposure. The program involves:
- Determining who is at risk (i.e., which employees are
overexposed to crystalline silica);
- Developing and implementing control measures designed to protect
those employees; and
- Monitoring the effectiveness of the control measures in
preventing occupational disease.
Implementing a Silica Control ProgramThe following steps can be used as an aid in
developing a Silica Control Program. 1. Determine which employees
are overexposed to crystalline
silica.
- Take an inventory of materials,
operations, processes and tasks to determine any potential exposure to
silica. The inventory should not only include safety data sheets of the
chemical components employees work with, but also potential exposures
from operations that produce dust from solid materials. Examples of
operations which may produce silica exposures include jack hammering,
rock crushing, concrete mixing, stone cutting and drilling, masonry
cutting and drilling and foundry operations.
- Perform initial employee exposure
monitoring in areas of potential silica exposure. For additional
information, refer to Exposure
Monitoring.
- Where air monitoring results indicate
employee 8-hour TWA exposures to respirable crystalline silica are at or
above the OSHA Permissible Exposure Limit (PEL) of 50
µg/m3, those employees should
be included in the company's Silica Control Program.
Note: OSHA recognizes that many of its PELs
are outdated and inadequate for ensuring protection of worker
health. To better protect workers, OSHA has annotated the existing
Z-Tables
with other selected occupational exposure limits, such as the ACGIH®
TLVs®. OSHA recommends that employers consider using the
alternative occupational exposure limits because the Agency believes
that exposures above some of these alternative occupational exposure
limits may be hazardous to workers, even when the exposure levels are
in compliance with the relevant PELs.
Therefore, employees
with 8-hour TWA exposures at or above the OSHA Action Level of 25
µg/m3 should also be included
in the Silica Control Program. The OSHA Action Level is the
same as the ACGIH TLV-TWA of 0.025
mg/m3 for respirable quartz and
cristobalite. 2.
Develop and implement a written Silica Control
Program.
When
developing a written program, consider addressing the
following:
- Policy statement outlining management's commitment to
an effective program
- Air monitoring procedures
- Medical management procedures
- Description of control measures
- Regulated Areas and Access Control
- Description of respiratory protection
- Training program
- Record keeping procedures
3. Per
the Silica Standards, provide medical examinations to employees included
in the Silica Control Program.
- Initial (baseline)
examinations should be performed on employees within 30 days
after initial assignment, unless the employee has received a medical
examination that meets the requirements of the OSHA Silica standard
within the last three years. The baseline examination shall include
medical and work history, a physical examination with special emphasis
on the respiratory system, a chest x-ray, a pulmonary function
tests (PFT), testing for latent tuberculosis infection, and any other
tests deemed necessary by the Practicing Licensed Health Care
Professional (PLHCP).
- Periodic medical
examinations should be performed at least every three years, or
more frequently if recommended by the PLHCP, to evaluate employees'
health and effectiveness of controls.
An
employee with or without x-ray evidence of silicosis who has respiratory
distress and/or pulmonary functional impairment should be fully evaluated
by a physician qualified to advise the employee whether he/she should
continue working in a dusty trade.
4.
Communication of respirable silica hazards to employees Include respirable
crystalline silica in the program established to comply with OSHA's Hazard
Communication Standard (29
CFR 1910.1200). Ensure the following hazards are
addressed in the training program; Cancer, lung effects, immune system
effects, and kidney effects. Ensure that each affected employee can
demonstrate knowledge of at least the following:
- The health hazards associated with
exposure to respirable crystalline silica.
- Specific operations/tasks in the
workplace that could result in exposure to respirable crystalline
silica, especially operations where exposure may exceed the
PEL.
- Specific procedures implemented to
protect employees from exposure to respirable crystalline silica,
including engineering controls, work practices and use of personal
protective equipment such as respirators and protective
clothing.
- The contents of the Silica
Standard(s).
- For construction operations, the
identity of the competent person.
- The purpose and description of the
medical surveillance program.
5. Provide respiratory protection to employees included in
the Silica Control Program.
- Respirators should be provided (1) as an
interim control until engineering controls can be implemented, or (2)
where exposures cannot be reduced below the exposure limit through
engineering controls. Per the OSHA annotated PELs (Z-Tables),
employees involved in operations/tasks resulting in full shift (8-hour)
crystalline silica exposures above the OSHA Action Level and ACGIH TLV
should use respiratory protection.
- Select and purchase appropriate
respiratory protection to control employee exposures below the PEL.
Initial monitoring data will provide the necessary information to select
the appropriate respirator for the given exposure. Respirators from
several manufacturers may need to be purchased to obtain a proper fit on
all employees in the program. Note: The Construction
Standard (1926.1053) specifies
required air purifying respirators for selected construction operations
in Table
1.
- Ensure that all employees in the
program obtain a proper initial fit. Some safety supply companies will
assist with fitting respirators to employees. Prior to initial fitting,
a medical exam should be conducted to evaluate the ability of the
employee to wear a respirator. More information on proper selection,
fitting, use and maintenance of respirators is included in the Respiratory
Protection section.
6.
Determine if engineering controls designed to reduce employee exposures
to crystalline silica are feasible.
- Review Principles
of Engineering Controls for Dusts/Silica, to determine if any of the
described principles can be applied at the work site.
- For upgrading equipment with additional controls such as enclosures
or ventilation systems, talk to equipment suppliers to determine if
retrofits are available.
- Plan for purchase of new and replacement equipment with dust control
in mind. Is equipment available to change from "dry" to "wet"
operations? Are enclosures for the machine, process or operator
available? Can local exhaust ventilation be installed to remove dust
from the operation?
7.
Implement administrative controls, such as housekeeping and hygiene
procedures, to help reduce employee silica
exposures.
Housekeeping
- Maintain surfaces free of accumulation of silica dust and promptly
clean spills to help reduce the potential for material to become
airborne.
- Compressed air, dry sweeping and dry brushing are not to be used to
clean surfaces contaminated with crystalline silica.
- Replace dust-producing cleaning methods with HEPA-filter vacuuming
or wet methods.
Maintenance and repair operations
- Implement procedures for preventive maintenance and prompt repair of
equipment to help reduce the potential for leakage and collection of
dust containing silica.
Hygiene procedures
- Prohibit smoking, eating and drinking
in areas with potential silica
exposure.
- Have employees vacuum work clothing
before entering the lunch and break area and before removal at the end
of the shift.
- Prohibit cleaning of work clothing
by shaking or blowing with compressed air.
8.
Develop a method for maintaining records.
- Records, including monitoring
results and medical information, etc., must be kept for specified
periods and must be made available to employees and designated
representatives.
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