Susan Wilcox, CIH, CSP, is an occupational safety and health professional with more than 30 years of experience. She holds a Bachelor of Science in Biology from Virginia Commonwealth University with a minor in Chemistry. She is both a Certified Industrial Hygienist and Certified Safety Professional with experience in a variety of sectors including consulting, laboratory management, as well as industrial and chemical manufacturing, and academia.
She has served on the local boards of both the ASSP and AIHA sections throughout her career. Susan also serves as adjunct Professor at Virginia Commonwealth University teaching Fundamentals of Industrial Hygiene.
Susan’s expertise includes: EHS Metrics / Data Collection & Analysis Radiation Safety / Toxicology Testing / Process Safety EHS Field Work / Data Management Systems Regulatory Compliance / OSHA / Manufacturing Incident Investigation, Auditing & Reporting Risk Assessment/Risk Management
She is currently Senior Engineer at Celanese, a large complex multi-chemical manufacturing site. Previous positions include: – EHS Program Manager for The Federal Reserve 5th District – OHSE Manager for Amcor Tobacco Packaging – EHS Engineer North America for Alfa Laval, Inc – Operations Manager for the EI Group, a full-service EHS consulting firm – General Manager at Schneider Laboratories.
She has also served as IH Specialist at Afton Chemical (Formerly Ethyl Corporation) and Industrial Hygienist at Honeywell (Formerly Allied Signal).
It’s always been there, always will be… only now ignoring the health risk to your people can hurt you and your pocketbook By John J. Meola, CSP, ARM
OSHA revised their long-dormant silica dust exposure regulation in 2017. The newer exposure limits are microscopically low, and it kind of makes you wonder what the heck we’ve been breathing all this time. Asbestos and lead dust? We get it; the hazards are well defined.
But silica? Every sandbox and dusty ball field is loaded with it. It is a naturally occurring element in practically all natural environments. And all of a sudden it’s blood-poison? Hard to figure.ADVERTISING
Enforcement of the new standard had been spotty — right up until last summer when Virginia Occupational Safety and Health (VOSH) cited a large regional contractor for three “willful violations of the Silica Rule.” The “willful” category essentially quintuples the proposed penalty, bringing the dollar amount close to $100,000 for each of the three transgressions.
And the odd thing about it is, the contractor is no slouch when it comes to safety. They pretty much have a program on steroids, so either someone got very lazy or VOSH decided to send a message. Either way, it’s a wake-up call to the rest of us
If your employees have any exposure to silica dust — yours or anyone else’s — you have some homework to do.
According to the new standard, here are your deliverables:
“How much dust is enough?”
That’s what OSHA calls the “Action Level” and it’s really low; 25 micrograms per cubic meter of air. If you can see the dust, you are probably overexposed and need to take action. The Action Level is a technical absurdity, since a microgram is one-millionth of a gram. The only way to measure this is to bring out an Industrial Hygienist (IH) with their pumps and hoses to take an actual reading of how much silica is in the air.
The next number to watch is the Permissible Exposure Level (PEL) which is a whopping 50 micrograms per cubic meter of air. Just for comparison, that’s the rough equivalent weight of an eyelash, or the wing of a fly.
If you can find your job on Table 1, and you stay within the strictures of the specified work activity and safety controls, you should be okay, even without the IH testing. Staying within the strictures is really important; going outside the lines can open you up to a penalty. So if you choose to use Table 1, it’s not going to be a random call.
Develop a Written Plan
In all cases, you will need a Written Exposure Control Plan. This plan defines your company policy, and details how you will comply with Table 1, for example, or any other protective measure in the standard. Add this plan to your Safety Manual, just as you would any other regulatory safety requirement such as – Haz Com or Personal Protective Equipment (PPE).
Training is Essential
You will need to train your employees in the intricacies of staying in compliance with Table 1 and any other provision, such as respirator use, using water or vacuum to minimize dust, staying upwind from dust, using PPE properly etc. Document this and all safety training.
Bonus Tip: Issue a wallet card as a reminder to each employee that they have been trained.
Establish a “Competent Person” for each Jobsite
You will need to train, educate and authorize what’s termed a Competent Person (CP) for the jobsite to keep an eye on all the safety-related pieces and parts along the way.
The CP will need to know how to minimize creating dust on any site by using Table 1 or any other means
They will need to understand the OSHA Hierarchy of Controls (Engineering, Administrative, PPE) to properly protect the employees
The CP be named in the Written Plan, along with others having authority for the Silica Program
You should name this person(s) with a Certificate of Competency, a letter and a wallet card; this is their reminder so that if you are inspected they don’t get amnesia
The CP also has authority to make changes and to STOP any work deemed to be unsafe
How to Use Respirators
The use of respirators is becoming more common in the trades, but the OSHA rubric on respirators can be confusing.
For example the voluntary use of dust masks still requires that the employer makes sure the employee can safely and properly wear the mask, i.e. proper seal, no facial hair… and the three-pack-a-day person is probably not going to pass the test.
If you plan to be in business for the foreseeable future, it probably makes more sense to have the entire crew fit-tested and medically certified for respirator use. This removes any doubt about their ability to breathe free. And for you as well.
Recertification on this respirator test is required annually
OSHA and your general contractor will ask for these records
Compliance = Protection
For the business owner and manager, compliance with the new Silica Rule is not all that complex. And OSHA did their homework on this Table 1. We advise don’t try to push your luck on it. Stay within the category guidelines and document it.
A big factor in your Silica Program will involve you being able to prove your employees are not exposed to any astronomical (i.e. visible) levels of silica dust. The only reliable way to do this is to have a representative job tested and documented by an Industrial Hygienist.
The estimated average cost for an Industrial Hygienist to come out for a day and sample your actual silica exposure is about $1500. This includes all the baggage, hardware, test results etc. Not a bad price for an insurance policy that lasts as long as you’re doing this type of work, or work that is substantially similar.
When you add up all the elements required in the silica control program, yes, it’s a laundry list. But the good thing is you only need to most of it once, as long as your business and the jobs you perform remain roughly the same.
John J. Meola, CSP, ARM is the Safety Director for Pillar, Inc., Richmond, VA. He is a consultant and safety trainer to private industry, a regular presenter at National Pavement Expo, and works with the World Sweeping Association. Reach him at JMeola@pillaroma.com
Silica Dust Defenses for Sweeper Operators
Develop a Written Silica Dust Control Plan, same as the saw-cutting people; include it in your Safety Manual.
The driver must be in an enclosed, positive-pressurized cab
Keep the rig as clean as possible to minimize random dust; pressure wash the exterior as needed
Keep good maintenance records on all the functional hardware, broom quality, change-out, control settings, hoppers emptied etc.
Vacuum trucks will likely be more prominent in certain applications; diversify your fleet
Check the cabin air filters frequently, clean or change as often as needed (hint: find washable, reusable filters)
Upgrade to High Efficiency Particulate Air (HEPA) filters when available. The added level of protection is worth the cost; document this refinement in your Written Plan.
Driver and helper or other employees are subject to the same provisions as any other worker around dust: They need safety and silica dust training, your company needs to identify and train a “Competent Person,” they should be provided and trained in proper use of dust masks, other PPE, dust controls etc.
Use a lot of water and try adding a surfactant – wetting agent – to the sweeper water supply for increased effectiveness
Whenever possible, configure the job for overnight, or at least off-peak hours. These days, anyone with a cell phone is a safety inspector.
If the dust cloud is impossibly huge and you are at risk of obstructing vision, your operator needs to know when to stop and call for reinforcements. To proceed and potentially create a hazard runs a huge risk. This actually happened not so long ago and the outcome was a serious car wreck. Guess who was the lead defendant? With practically no viable defenses.
Questions About Controlling Silica?
The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has posted new frequently asked questions (FAQs) on the agency’s standard for respirable crystalline silica in general industry.
OSHA developed the FAQs in consultation with industry and union stakeholders to provide guidance to employers and employees on the standard’s requirements, such as exposure assessments, regulated areas, methods of compliance, and communicating silica hazards to employees. The questions and answers are organized by topic, and include an introductory paragraph that provides background information about the regulatory requirements. (https://www.osha.gov/dsg/topics/silicacrystalline/generalindustry_info_silica.html)
Visit OSHA’s silica standard for general industry webpage (https://www.osha.gov/dsg/topics/silicacrystalline/gi_maritime.html) for more information and resources on complying with the standard.
Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit www.osha.gov.
Repair Equipment to Specification
If you bought a pavement saw equipped with a water-delivery system — and that system breaks or fails — you cannot substitute by using a garden pump-type sprayer to deliver the water. The first generation of water-delivery hardware on saws was notoriously prone to failure. The latest tooling is built more robustly.
This is important because OSHA will consider any hardware improvisation to be non-compliant, even though it might be equally effective. Hardware must be maintained in accordance with manufacturer’s instruction and original equipment.
Most of the tool makers got the message by now and have refitted and upgraded their hardware.
OSHA “Explains” Silica Inspection Process
The link below is to a 2017 letter of interpretation from OSHA describing the process an inspector will use to determine if you earn a silica penalty. Good luck trying to figure it out.
Safety expert John Meola, CSP, ARM, shares his list of top ten reasons for construction accidents, as well as precautions you can take to ensure safe equipment operation on your construction site.
Each year, there are thousands of injuries and triple-digit numbers of fatal accidents related to machine and equipment operation. A lot of these accidents involve the operator, but over half involve people on the ground – spotters, co-workers, laborers, shovel hands, passers-by and sidewalk superintendents who get too close. And because of the forces and physics involved, these are usually not first-aid injuries; there is often an ambulance and sometimes a coroner called to the jobsite.
A review of OSHA and MSHA Fatality Alerts & Bulletins reveals that practically all of these accidents are preventable. Safety awareness and caution when performing the most routine operation are characteristics of a good operator. Yet, if you take a few moments to read a few of the fatality reports at the above web sites, you will find operators with decades of experience on the list. Before we take a look at the list of Top 10 causes of jobsite accidents and how to avoid them, we need to offer some reminders about operator training. This is usually a topic where the owner says, “Oh, my guy has been running that machine for X amount of years; he knows all there is to know.” And that may very well be the case. It does not, however, fulfill your obligation under OSHA, MSHA or the rules of civil liability known as Tort Law.
All operators must have identifiable and verifiable training on the machine or equipment. Most equipment dealers will provide this training as part of their customer service, and you need to take advantage of it. We’re not talking about a semester credit course, but there is a Student Workbook, a video and usually a quiz. There is also a practical section where the student will operate the machine to confirm understanding of key controls and functions. A Certificate of Completion will then be issued.
The larger or more complex the machine, the more in-depth the training should be. Remind me, how much did that rig cost? And you’re going to try to skimp on the training? Better keep reading.
Getting on and off equipment Getting on and off the machine is the No. 1 cause of injury to equipment operators, forklift drivers and truck drivers, any one of whom will readily share their “learning episode.” It happens a lot. First, check your gloves and boots. Clean the mud off before climbing, and use “high grip” gloves for a secure hand hold. Next, use a three-point stance going and coming. Use large size hand and foot holds. Securely engage the entire hand and foot, avoiding a toe-hold or finger-hold grip. Use a step ladder for access when no hand or foot holds are provided. Avoid carrying objects while climbing. If the machine needs additional hand holds or steps installed, do it. Operators come in different sizes. Make it as easy and safe as possible to ascend/descend. Avoid the need to stretch by putting the grab rails where they’re easy to securely reach. When exiting the machine, correct practice is to lower yourself in a controlled manner – never jump!
Loading/unloading equipment Even on level ground, there is a risk of machine roll-over during loading or unloading. Make sure you are centered on the ramps and stay straight. Allow enough room to maneuver the trailer and machine, which is sometimes difficult on tightly compressed jobsites. Use a spotter for guidance. Make sure the machine clears the ramps before turning. Keep people away from the sides of the machine during loading/unloading. Check the trailer deck, clearances and stability. Review your lock-out/tag-out plan to be sure the machine is at “Zero Energy State” when stowed. Use proper tie-down procedures. If using compression chain binders, use caution when opening the handle. The load may shift just enough to add tension to the chain and the handle may spring open. Use safety tie wires or switch to ratchet binders.
People crowding the work area Ask any backhoe operator what their biggest headache is and they will tell you without hesitation – people on the ground crowding the machine. People love to stand at the edge of the hole and watch the dirt being moved. There is usually no reason for them to be there, just force of habit. But why create an exposure to injury when none needs to exist? People on the ground must stay well away from the machine operating area. Review this importat point at safety meetings. Foremen need to enforce this, not the operator. When ready to start work, use the horn to warn people to stay back; stop the machine if needed; and always check your back before backing up the machine.
Machine swing radius Swing radius accidents are common. How do you think all those scrape marks got on that counterweight? Unfortunately, they are also usually fatal when people are involved. Thus, it’s important to rope off the swing radius around the machine or otherwise secure it. Allow no spectators; use a spotter to keep all people clear.
Operation on slopes Caution is always required when operating on slopes. You might make it up the slope with a load, but coming down is another story! Know the limits of the machine, allow for surface conditions and don’t push it. Know the Equipment Before Hitting the Slopes
Overhead/buried obstructions Be aware of overhead obstructions and underground utilities, including electrical lines, water, sewer, gas, telecom, etc. Definitively mark or warn of overhead lines or low clearances. When digging, call Dig Safe or whichever agency has jurisdiction. Continue to use caution even after underground lines are marked, since errors in marking are common. Be prepared to hand dig when it’s getting close. Use sawhorses, signs, barrier tapes, etc., to indicate obstructions. Take no chances.
Backing Reverse motion on anything in this industry is fraught with peril. Backup alarms on construction machinery are basically cosmetic devices in terms of assuring a clear backside. As such, operators need to positively assure that no one or nothing is behind them. This is achieved by getting out and looking. Always check the machine perimeter before moving. When vision is impaired, have a spotter (in high-visibility apparel) guide you. Use wide angle mirrors. The new generation of machines is fitted with best viewable surface mirrors. Keep them clean and adjusted. Use rear-mounted cameras and/or rear-mounted presence-sensing alarms. Presence-sensing alarms are becoming more reliable as technology improves. The equipment industry recognizes the urgency of the problem and will find technical solutions to address chronic people behavior problems.
Machine upset If a piece of equipment starts to tip, your seat belt becomes your lifeline. Yet, the list of excuses for failure to use seat belts or harnesses is amazingly long. Most operators would make great fiction writers with the excuses they can come up with. If it weren’t so grim, we should offer to add their reasons to their obituary. Always use a seat belt. A professional operator will not have to be reminded of this bed-rock rule. Wear the belt even with the cab door closed. It decreases how much you will bounce around in the cab during normal operations, and may help you control the machine in a borderline upset situation. In addition, operators need to understand the machine’s stability characteristics on all surface types and conditions. Check to see if the equipment manufacturer or dealer offers an instructional video.
Instability or loss of load Moving dirt or bulk materials is fairly straightforward. It becomes more complex when you try to use the hoe as a crane, or otherwise become creative in finding new applications. The best pipe layers in the world might only be “fair” when it comes to rigging. All rigging attachments for lifting must be engineered for safety. Be sure to use: oversized fittings positive locking attachments safety latches on all hooks correct lifting angles on chains or cable bridles properly inspected nylon slings abrasion and cut protection on sharp edges and masonry spreader beams to provide correct lifting geometry Keep all people well clear of a load being lifted or handled. Either get the guys out of the trench, or send them to a safe distance when the pipe is being placed. Never lift a load over people. A lot of serious accidents also occur when trying to use one machine to do multiple functions. Rough-terrain forklifts, skid steers and similar multi-use machines are versatile, but are often pushed beyond their limits for expediency. Operators need to understand that there are limitations that must be observed and safety is primary.
Lock-out/Tag-out Most mechanics will tell you a horror story or two that illustrates why OSHA made the lock-out/tag-out (LOTO) rule. Any raised load (or object, such as the bucket or attachment) is subject to LOTO provisions. All pinch points on a machine must be identified and protected (guarded) when possible. The minimum warning is a pictorial decal advising of the hazard. If a dump body has a safety “crutch,” make sure it is functional and used. Refueling, service personnel and mechanics need to use positive means to assure their safety while servicing or working on the machine, i.e., wheel chocks, steering wheel covers with LOTO Warning imprint and LOTO locks, tags and hardware configured to the machine. Review manufacturer directions for safety in all cases, even if this is the fifth generation of machine you bought from the same manufacturer. There are illustrations and directions in all manuals to point out safety features, do’s and don’ts, good practices/bad practices, efficiency measures, etc. Safety focus The equipment and machinery produced today are the safest and most reliable ever made. To get the most out of these tools and ensure your employees’ safety, a comprehensive safety program should not only be in place on all your jobs, it should be relevant, timely, frequently referenced and backed up by top management. Keep your operators and ground crews informed of the hazards they face (i.e., by reading the machine manual), keep them motivated and aware and recognize their accident-free achievements. John J. Meola, CSP, ARM, is the safety manager for Timmons Group in Richmond, VA. He has more than 27 years’ experience in safety engineering and has served as past president of the American Society of Safety Engineers from 1993 to 2011. You can reach him at email@example.com.
JOHN J. MEOLA CSP, ARM, Safety Director at Pillar, Inc. Oct 30, 2018
It sometimes seems that every news report brings stories of fatal accidents across our Commonwealth, both in daily life and at work. The science of risk management can, however, provide a strong dose of sensitization to certain kinds of situations when things go haywire, but it requires a discipline of focused attention to absorb the lessons and change our behavior accordingly.
If you’re in business for the long haul, take a hard look at your machinery, tooling, safety program, employee training and skills development, and succession planning. For example, vintage machinery usually does not have basic safety features. Unless you retrofit, it’s time to go shopping.
Put the antiques out to pasture. Hospitalizations and amputations require direct reporting to the “safety police” and will probably result in high-dollar, wish-you-had-listened outcomes. Following many industrial accidents, investigations reveal the persistence of “denial” among management as one of the greatest safety hazards to all workers. If you are of the opinion that “all this safety stuff costs money,” wait until you see the cost of an accident.
Joggers, walkers, bikers and hikers, when you venture out wear a high-visibility garment such as those worn by construction workers. Again, the lesson here derives from accident reports: “I never saw them” is the number one answer to “What happened?”
In summary, a safety mindset can range from the simplest look-both-ways-before-crossing adage to the more intricate high-risk job planning choreography. Contact John Meola at JMeola@Pillaroma.com.