Page 83 - Occupational Health & Safety, July 2018

■ Requirements for the development of a written exposure control plan with specified content, when exposures may exceed the AL.
■ Requirements for respiratory protection (but not as the pri- mary or sole method of reducing exposures).
■ Where RCS exposure is an issue, prohibitions on dry sweep- ing/brushing unless wet sweeping or HEPA vacuums are not fea- sible, and on the use of compressed air to clean clothing or surfaces unless used in conjunction with a ventilation system that captures the dust.
■ Medical surveillance provisions. The standard requires the offering of medical monitoring; the monitoring content goes be- yond what is required for respirator clearances.
■ Specific communication on silica hazards.
■ Recordkeeping (exposure assessments and lists of persons exposed, data sheets, etc.).
Some Points to Highlight
There are many requirements in the standard; one must read it to ensure compliance. However, a few key points include:
Exposure assessments: The value of your exposure assessments could get lost in the shuffle, especially if employees work inter- changeably throughout a facility, pull from utility teams, or have tasks that create exposure for only a small fraction of the work day. A cross-reference chart showing job categories, task(s) conducted during sampling, and related air sampling can be of value for lon- ger-term tracking and compliance assurance.
Air sampling devices need to be selected carefully based upon likely exposure levels, nature of work and body postures, and labo- ratory detection limits. While there are many “tools” that can be used and each can have its purpose, I’ve found that SKC PPI (Paral- lel Particle Impactor) sampling devices can be a great addition to traditional cyclone sampling. This is due to the ability to use higher flow rates as well as sampler orientation considerations.
Regulated area signage: Some changes may be necessary in your facility that “may” not be easily understood or accepted by workers. Exposure potential may dictate that “Regulated Areas” be estab- lished. If so, corresponding signs must state:
DANGER
RESPIRABLE CRYSTALLINE SILICA
MAY CAUSE CANCER
CAUSES DAMAGE TO LUNGS
WEAR RESPIRATORY PROTECTION IN THIS AREA AUTHORIZED PERSONNEL ONLY
Will your workers perceive that the company is trying to pro- tect them, or instead wonder why they weren’t told of this hazard beforehand? This sort of issue “begs” for a well-thought-out and implemented roll-out plan and communication strategy.
Coordinated efforts and culture: Are employees “used” to work- ing in ways that will now be prohibited? Changing old habits will require more than management edict. Have engineering, mainte- nance, and operations workers been involved to think about and work through the consequences of required changes and to iden- tify alternate methods? Where might vacuum systems be feasible and effective, and where must they be located? What methods will be used for emptying containers and changing filters while still protecting workers? Is there the potential to develop static electric- ity? How will the company change its practice of using brooms and
compressed air, if new methods are physically more difficult and time consuming?
Exposure Control Plan (ECP): The ECP that companies must develop should be a coordinated plan and not simply list canned requirements. The standard details required content. Organiza- tions should expect development of this plan to be more than trivial because it must describe tasks that involve exposure to RCS, as well as outline work practices, engineering controls, and other things that will take coordination among departments. You’ll need to consider things such as:
■ What requirements will your company apply to persons go- ing “into” and “out of ” regulated areas, such as for supervisors and forklift operators? What about short-duration entry? (You and I probably know the desired answer, but does your team see it the same way?)
■ What is your company’s protection philosophy and goal? Is it to (only) protect employees to the AL/PEL on an eight-hour time weighted average, or is it to consistently aim to reduce significant exposure potential wherever possible?
■ Will changes to the respiratory protection program or prac- tices be needed?
■ Will there be changes necessary to existing local exhaust ventilation systems and associated maintenance and testing?
■ Are local medical providers knowledgeable of the standard and “ready to go?”
Engineering controls and feasibility: OSHA requires that engi- neering controls be used to achieve necessary exposure reductions unless infeasible; organizations may not simply issue respirators and “be done with” their attempts to lower exposures. Investigate engineering control options in earnest. Controls that work in one industry may not work in another. Some companies may have implementation issues that are difficult to overcome or have situ- ations where the costs incurred to reduce exposure levels result in diminishing returns. Organizations should carefully manage and document their improvement efforts and feasibility criteria (costs, availability of controls, improvements, acceptance, others).
Conclusion
The respirable crystalline silica standards have changed significant- ly. Time is of the essence for companies that have work that results in employee RCS exposures that trigger the standard. Preparation should include obtaining and reading applicable regulations, as well as OSHA Directives and other available information. Action plans should be time-based and address both regulatory require- ments and organizational change issues. Some companies may have significant management decisions to make as they move to- ward improving regulatory compliance and reducing exposure. Good luck!
Greg Zigulis, CIH, CSP, is President of Sixth Sense Safety Solu- tions and provides companies with comprehensive occupational and industrial health and safety assistance. Over the span of his 30+ year career, including in the construction, manufacturing, and mining industries, he has helped numerous organizations imple- ment and improve occupational health and safety management systems, as well as specific standards such as for the assessment and control of respirable crystalline silica exposures. He can be reached at gz@sixthsensesafetysolutions.com.
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