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How Will Silica Exposure Considerations Change the Concrete Product Industry? NCMA Annual Convention and 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, © 2006 CIH Service, LLC – Nashville, TN copyright

Efforts are currently underway to establish an OSHA standard for Crystalline Silica copyright © Efforts are currently underway to establish an OSHA standard for Crystalline Silica copyright © 2006 CIH Service, LLC

Current Respirable Silica Permissible Exposure Limit ØBased upon formula: = 10 milligrams/meter 3 (% Current Respirable Silica Permissible Exposure Limit ØBased upon formula: = 10 milligrams/meter 3 (% Silica + 2) ØControls silica to ~ 0. 1 mg/m 3 (when respirable dust is 100% silica) copyright © 2006 CIH Service, LLC

History of Current Standard Ø 1970 – PEL formula adopted by OSHA from 1969 History of Current Standard Ø 1970 – PEL formula adopted by OSHA from 1969 ACGIH TLV Ø 1989 - OSHA established a “fixed” PEL at 0. 1 mg/m 3 for respirable quartz Ø 1992 - Fixed PEL was vacated copyright © 2006 CIH Service, LLC

Silica Control History Ø August 1996 – OSHA Special Emphasis Program (SEP) started Ø Silica Control History Ø August 1996 – OSHA Special Emphasis Program (SEP) started Ø October 1996 – International Agency for Research on Cancer (IARC) listed silica as “Carcinogenic to Humans” Ø 1997 - present. Silica standard on OSHA Unified Agenda Ø 2003 - SBREFA report completed copyright © 2006 CIH Service, LLC

Current Status of Silica Rulemaking Process ØPre-Rule Stage ØNext Target Date = April 2006 Current Status of Silica Rulemaking Process ØPre-Rule Stage ØNext Target Date = April 2006 Complete Peer Review of Health Effects and Risk Assessment due copyright © 2006 CIH Service, LLC

Future Actions Still Needed ØAdvanced Notice of Proposed Rulemaking (ANPR) must occur ØNotice of Future Actions Still Needed ØAdvanced Notice of Proposed Rulemaking (ANPR) must occur ØNotice of Proposed Rulemaking v. Public Comment period v. Public Hearing v. Post-Hearing Comment period ØFinal Rule must be published in the Federal Register ØPhase-in period for Compliance copyright © 2006 CIH Service, LLC

Other Crystalline Silica Exposure Standards ØNIOSH REL = 0. 05 mg/m 3 ØACGIH TLV Other Crystalline Silica Exposure Standards ØNIOSH REL = 0. 05 mg/m 3 ØACGIH TLV = 0. 025 mg/m 3 ØNIOSH and ACGIH do NOT consider economic impact on business community to meet the standards recommended copyright © 2006 CIH Service, LLC

Draft Proposed Crystalline Silica PEL Ø 0. 1 mg/m 3 with 0. 05 mg/m Draft Proposed Crystalline Silica PEL Ø 0. 1 mg/m 3 with 0. 05 mg/m 3 medical Action Level Ø 0. 075 mg/m 3 with 0. 04 mg/m 3 medical Action Level Ø 0. 05 mg/m 3 with no medical Action Level copyright © 2006 CIH Service, LLC

Monitoring Ø Initially (Exception for abrasive blasters in type CE abrasive blasting respirators or Monitoring Ø Initially (Exception for abrasive blasters in type CE abrasive blasting respirators or employers with objective data) Ø Quarterly if greater than PEL Ø Every 6 -months if greater than Action Level Ø Observation of Monitoring and Employee Notifications copyright © 2006 CIH Service, LLC

Regulated Areas ØRequired for areas that exceed or are reasonably expected to exceed the Regulated Areas ØRequired for areas that exceed or are reasonably expected to exceed the PEL ØEstablished by “Competent Person” ØDemarcated with signs, barriers or negative pressure enclosures copyright © 2006 CIH Service, LLC

Competent Person ØDefinition – one who has the knowledge to identify and evaluate existing Competent Person ØDefinition – 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 ØDesignated for each worksite copyright © 2006 CIH Service, LLC

Competent Person Responsibilities Ø Evaluate exposures and existing controls Ø Implement corrective measures, including Competent Person Responsibilities Ø Evaluate exposures and existing controls Ø Implement corrective measures, including temporary work stoppage Ø Define, demarcate and check Regulated areas Ø Inspect Abrasive Blasting activities Ø Communicate with other employers at the worksite to inform of regulated area boundaries around abrasive blasting operations copyright © 2006 CIH Service, LLC

Prohibited Practices Ø Job rotation Ø Use of compressed air, brushing or dry sweeping Prohibited Practices Ø Job rotation Ø Use of compressed air, brushing or dry sweeping for cleaning Ø Eat, drink or use tobacco in regulated areas Ø Remove dust from clothing by blowing or shaking Ø Abrasive Blasting using Silica in enclosed areas copyright © 2006 CIH Service, LLC

Abrasive Blasting Ø Only in Regulated areas Ø Type CE, continuous flow respirator (hood Abrasive Blasting Ø Only in Regulated areas Ø Type CE, continuous flow respirator (hood or helmet) Ø Blasting areas cleaned using: v. HEPA vacuums v. Wet Methods v. Dust suppressants Ø If dry blasting with sand in an open area, alternative blast medias must be evaluated copyright © 2006 CIH Service, LLC

Personal Protective Equipment ØRespirators required for employees exposed above the PEL ØOr for those Personal Protective Equipment ØRespirators required for employees exposed above the PEL ØOr for those who request it copyright © 2006 CIH Service, LLC

Protective Work Clothing ØNew disposable clothing provided each day ØNon-disposable clothing such as coveralls Protective Work Clothing ØNew disposable clothing provided each day ØNon-disposable clothing such as coveralls or full bodied clothing copyright © 2006 CIH Service, LLC

Hygiene Facilities 1. Change rooms 2. Only authorized employees allowed to remove non-disposable clothing Hygiene Facilities 1. Change rooms 2. Only authorized employees allowed to remove non-disposable clothing for laundering, maintenance or disposal 3. Contaminated clothing placed and stored in closed containers labeled with Silica hazard warning labels 4. Laundry service must be informed of potential silica contamination including harmful effects 5. Contaminated clothing transported in sealed impermeable bags with hazard label copyright © 2006 CIH Service, LLC

Shower Facilities ØConsidered as an option for those exposed above the PEL ØMay require Shower Facilities ØConsidered as an option for those exposed above the PEL ØMay require employer to ensure employees shower at the end of each work shift copyright © 2006 CIH Service, LLC

Lunchrooms Ø Must be below the PEL Ø May require temperature controlled, positive pressure, Lunchrooms Ø Must be below the PEL Ø May require temperature controlled, positive pressure, filtered air supply for lunchrooms Ø May require HEPA filtered vacuums for cleaning clothes before entering lunchrooms, change rooms or shower rooms copyright © 2006 CIH Service, LLC

Housekeeping ØHEPA vacuum Silica accumulations ØPrevent accumulation of silicacontaminated water that could dry and Housekeeping ØHEPA vacuum Silica accumulations ØPrevent accumulation of silicacontaminated water that could dry and result in residue that could contribute significantly to airborne exposures copyright © 2006 CIH Service, LLC

Health Screening Ø Offered initially and annually for all exposed above the Action Level Health Screening Ø Offered initially and annually for all exposed above the Action Level (or PEL if 0. 05 mg/m 3) Ø Before assignment to tasks above Action Level Ø Whenever employee reports silica related symptoms Ø Within 30 days of termination copyright © 2006 CIH Service, LLC

Health Screening Content Ø Occupational and health history with emphasis on silica exposures and Health Screening Content Ø Occupational and health history with emphasis on silica exposures and other respiratory agents Ø Physical exam with emphasis on respiratory system Ø Chest X-Ray Ø Pulmonary Function Test (PFT) Ø Any other tests deemed necessary by the HCP Ø Annual review of history and physical exam with emphasis on respiratory system copyright © 2006 CIH Service, LLC

Health Screening Info Employer Provides to HCP Ø Description of employee’s job as it Health Screening Info Employer Provides to HCP Ø Description of employee’s job as it relates to silica Ø A copy of paragraph (k), Employee Health Screening section of the standard Ø Results from employee exposure monitoring Ø Results of previous health screening Ø A description of PPE copyright © 2006 CIH Service, LLC

HCP Written Opinion Ø Shared with employee within 15 days Ø Must include: Employee HCP Written Opinion Ø Shared with employee within 15 days Ø Must include: Employee Health condition related to silica. Non-silica findings must remain confidential from the employer Ø 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 Ø A statement HCP has informed employee of silica screening results copyright © 2006 CIH Service, LLC

Pulmonary Specialists Ø Employer must make one choice available from the list provided by Pulmonary Specialists Ø Employer must make one choice available from the list provided by the HCP Ø Written opinion must be obtained within 30 -days of examination Ø Copy of results to employee within 15 -days copyright © 2006 CIH Service, LLC

Pulmonary Specialists (continued) 1. Specialists written opinion must include: 1. Employee health condition related Pulmonary Specialists (continued) 1. Specialists written opinion must include: 1. Employee health condition related to silica 2. Recommended work limitations, such as restrictions or removal with probable durations 3. Statement results were shared with employee 2. Employer must report all cases of silicarelated disease identified by the pulmonary specialist to NIOSH copyright © 2006 CIH Service, LLC

Hazard Communication ØAll employees potentially exposed are informed and trained initially, prior to assignment Hazard Communication ØAll employees potentially exposed are informed and trained initially, prior to assignment ØMust be informed on the requirements of the silica standard and how to access or obtain a copyright © 2006 CIH Service, LLC

Recordkeeping Ø Historical or objective data Ø Exposure Measurements– 30 years Ø Health Screening Recordkeeping Ø Historical or objective data Ø Exposure Measurements– 30 years Ø Health Screening Records–Employment+30 years Ø Respirator Fit Test Records-most current Ø All records may be kept in any form Ø Available upon request to Asst. Secretary, subject employee or qualified representative Ø Provision for transfer of records upon sale or close of business copyright © 2006 CIH Service, LLC

Some Items that Were NOT Included ØWritten Control Plan ØMedical Removal Provisions ØConsideration for Some Items that Were NOT Included ØWritten Control Plan ØMedical Removal Provisions ØConsideration for Non-standard work shifts (greater than 8 -hours) copyright © 2006 CIH Service, LLC

Potential Impacts Ø At PEL of 0. 1 mg/m 3: v. Estimated ~⅓ may Potential Impacts Ø At PEL of 0. 1 mg/m 3: v. Estimated ~⅓ may have overexposure areas or tasks üDry sanding, sawing, abrasive blasting and mixer cleaning tasks produce most overexposures v. Most can be controlled through improved housekeeping, work practices and ventilation copyright © 2006 CIH Service, LLC

At PEL of 0. 075 mg/m 3 Ø Estimated ~½ of workplaces may have At PEL of 0. 075 mg/m 3 Ø Estimated ~½ of workplaces may have tasks or areas with overexposures Ø In addition to tasks that exceeded 0. 1 mg/m 3, other tasks such as additive mixing, material loading/unloading may produce overexposures, especially in open cab mobile equipment copyright © 2006 CIH Service, LLC

At a PEL of 0. 05 mg/m 3 Ø MIOSHA 2004 Annual Report on At a PEL of 0. 05 mg/m 3 Ø MIOSHA 2004 Annual Report on Silicosis - 60% of workplaces sampled in excess of NIOSH REL or PEL at 0. 05 mg/m 3 (Note- Data summarized for all inspected business!) Ø Regulated areas now extend into more areas Ø 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)… Ø Respirators! copyright © 2006 CIH Service, LLC

Example of Compliance Costs with PEL at 0. 1 mg/m 3 • Plant employs Example of Compliance Costs with PEL at 0. 1 mg/m 3 • 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 3 M 8210 N 95 disposable dust masks = $1, 154 copyright © 2006 CIH Service, LLC

Compliance Costs (continued) • Baseline Health Screening = $2, 160 ($180 per employee for Compliance Costs (continued) • Baseline Health Screening = $2, 160 ($180 per employee for 12 employees) – $35 Physical – $65 PFT – $80 Chest X-Ray • Year 1 and Year 2 = $1200 (Physical and PFT only…Chest X-ray every 3 rd Year) • Estimate does not include time away from work! copyright © 2006 CIH Service, LLC

Compliance Costs (continued) • Annual Fit Tests and Training = $120 (~$20 per employee) 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 copyright © 2006 CIH Service, LLC

Other Costs • Lunchroom facilities • Lunchroom HVAC • Lunchroom HEPA vacuums • Shower 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. ) copyright © 2006 CIH Service, LLC

Compliance Costs Per Facility • Minimum ~$12, 000/year • Costs go up significantly if 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~ $10 K-$500 K) copyright © 2006 CIH Service, LLC

Recommendations for Action! Ø Evaluate your workplace! Ø Formulate a silica exposure control plan! Recommendations for Action! Ø Evaluate your workplace! Ø Formulate a silica exposure control plan! Ø Communicate with your NCMA representatives on how this would impact your business! Ø Communicate with your elected officials to educate them on silica issues! copyright © 2006 CIH Service, LLC

Summary ØA specific OSHA silica standard may cause significant changes in Concrete Products industry Summary ØA specific OSHA silica standard may cause significant changes in Concrete Products industry ØAs the PEL is reduced, more areas would require actions and additional expense copyright © 2006 CIH Service, LLC

615. 791. 3379 www. cihservice. com Kevincampbell@cihservice. com copyright © 2006 CIH Service, LLC 615. 791. 3379 www. cihservice. com Kevincampbell@cihservice. com copyright © 2006 CIH Service, LLC