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Introduction Implementing a Silica Control Program

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:

  1. Determining who is at risk (i.e., which employees are overexposed to crystalline silica);

  2. Developing and implementing control measures designed to protect those employees; and

  3. Monitoring the effectiveness of the control measures in preventing occupational disease.
Implementing a Silica Control Program

The 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Note: OSHA recognizes that many of its PELs are outdated and inadequate for ensuring protection of worker health.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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