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.