Silica Control
Program Audit
Why conduct an audit of your program?
A periodic audit of your Silica Control Program helps to ensure that key program elements are in place
and operating so your goals of controlling silica exposures and preventing silicosis are achieved. The
questions in this checklist are designed as a management tool for assessing your Silica Control Program.
In addition to verifying the appropriate program elements currently in place, this checklist also will help
you identify weaknesses or gaps in your program and guide you in developing appropriate solutions.
How to conduct an audit of your program
Use this audit checklist to review your Silica Control Program as it currently operates, not as you think it
should be operating or as it was originally intended to operate. Review the pertinent records (for example,
air monitoring results, respiratory protection program, training records) to help you determine the status of
key program elements in the checklist. After completing the checklist, determine which program elements
need improvement (i.e., where there are "No" answers) and complete the Silica Control Program Audit
Results found at the end of this booklet.
Please Note: The audit procedures in this booklet are based on OSHA's National Emphasis Program – Crystalline Silica and
NIOSH's Recommended Standard for Occupational Exposure to Crystalline Silica. Some states may impose more stringent
requirements than those covered in this booklet. Be sure to refer to all applicable state and local regulations when conducting your
audit.
This booklet is informational only and was compiled from sources believed to be reliable. Zurich Services Corporation Risk
Engineering makes no guarantee of results and assumes no liability in connection with the information, methods or safety
suggestions contained herein. Moreover, it cannot be assumed that every acceptable safety or compliance procedure is contained
herein or that abnormal or unusual circumstances may not warrant or require additional procedures.
1
Silica Control
Program Audit Checklist
A. Exposure Assessment
Begin your audit
with a review of the
air sampling records
related to employee
exposure to
respirable silica. Be
sure to consider any
new areas or
processes where
employee silica
exposure occurs,
but which have not
been monitored yet
Yes
1.
Has air monitoring been conducted to identify employees
(all job classifications) exposed to crystalline silica?
2.
Are air samples representative of the breathing zone of
employees, for every operation or process, and evaluated
on a full-shift basis?
3.
Does survey information include sampling and analytical
methods; type of personal protective equipment, if any, in
use at the time of sampling; environmental conditions; and
the monitoring results?
4.
Was all monitoring equipment calibrated before and after
the survey(s) and is calibration documentation available?
5.
Are reports from silica surveys available for review?
6.
Are all employees found to be exposed to respirable silica
above the Permissible Exposure Limit (PEL) informed of
the survey results?
7.
Have all employees found to be exposed above the PEL
been included in your Silica Control Program?
8.
If initial sampling results were between the PEL and Action
Level (50% of the PEL) was additional air monitoring
conducted at least every 6 months to further assess
exposure?
9.
Have supervisors been provided summaries of airborne
silica exposure monitoring results for employees in their
departments/areas?
10.
Are airborne silica monitoring results used to prioritize
areas and operations for control measures implementation?
11.
Is breathing zone air sampling conducted within 30 days
after changes in production processes, equipment,
materials, or controls?
12.
Are records maintained for all air sampling surveys?
13.
Are records maintained for at least 30 years following
termination of a worker's employment?
14.
Are records maintained for at least 30 years following
termination of a worker's employment?
2
No
B. Evaluation of the Written Program
Next, evaluate the
content and
implementation of
your written Silica
Control Program.
The written program
must reflect what
you are doing in
your workplace. For
example, the written
program must list
the affected
employees or areas
at your site, indicate
who is responsible
for the various
aspects of the
program, and
indicate how any
written materials or
exposure records
will be made
available to
employees.
Yes
1.
Has a written silica control program been established and
implemented for your facility or job site?
2.
Does the written program include a description and
instruction for the following:
a. Policy statement outlining management's
commitment to an effective program?
b. Exposure assessments, including identification of
employees/tasks where exposure to crystalline
silica exists, and ongoing air monitoring
procedures?
c.
Work practice and engineering control measures in
place and planned?
d. Use of personal protective equipment and work
clothing, including respiratory protection
procedures, if respirators are utilized?
e. Labeling and warning procedures?
f.
Housekeeping and hygiene procedures?
g. Employee Training procedures?
h. Recordkeeping procedures?
3
No
C. Engineering and Administrative Controls
Engineering controls
include substitution
with less toxic
materials, dust
suppression
methods, and
ventilation control
measures.
Administrative
controls include
work practices such
as appropriate
housekeeping,
maintenance and
repair operations,
hygiene procedures,
and prohibited
practices.
1.
Are engineering controls (such as substitution, dust
suppression, ventilation, and isolation) used wherever it is
economically and technically feasible to lower the silica
exposure of workers?
2.
Are inspection and maintenance of engineering controls
scheduled regularly to ensure their continued effectiveness?
3.
Have preventive maintenance and prompt repair of
equipment been implemented to help reduce the potential
for leakage and collection of dusts containing silica?
4.
Housekeeping
a. Are surfaces maintained free of silica dust
accumulation?
b. Are spills promptly cleaned to help reduce the
potential for material to become airborne?
c.
Is cleaning with compressed air and dry sweeping
prevented?
d. Have dust controlling cleaning methods such as
vacuuming and washing down with water been
implemented where appropriate?
5.
Hygiene Procedures
a. Are smoking, eating and drinking prohibited in
areas with potential silica exposure?
b. Are employees' work clothing vacuumed before
entering the lunch and break area and before
removal at the end of the shift?
c.
Is cleaning of work clothing by shaking or blowing
with compressed air prohibited?
4
Yes
No
D. Respiratory Protection
Approved respiratory
protection, governed
by a respiratory
protection program, is
required for every
worker exposed to
silica above the
OSHA PEL when
exposures are not
controlled by
engineering means.
When evaluating
respiratory protection,
be sure to review the
most recent exposure
assessments to help
determine that
respirators currently
assigned are
appropriate (i.e., have
an adequate
Assigned Protection
Factor). A "walkthrough" should be
conducted to
determine, first hand,
that employees are
wearing and
maintaining their
assigned respirators,
as directed
Yes
1.
Are respirators required wherever employee exposures can
not be controlled below the exposure limit by engineering
means?
2.
Are respirators required as interim control measures until
engineering methods have been installed and proven
effective in reducing employee exposures below the
Permissible Exposure Limit?
3.
Is each respirator, currently assigned and in use, a NIOSH
approved respirator?
4.
Has each respirator been selected based on NIOSH
Assigned Protection Factors and results of the most recent
silica exposure assessments (See Table 1)?
5.
Are NIOSH approved, Type CE abrasive blasting
respirators (continuous flow air-line respirators) required
during silica sand abrasive blasting operations?
6.
Based on your observations during a walk-through, are
employees wearing the respirators assigned to them for the
job/task that requires respirator use?
7.
Are supervisors adequately enforcing use of respirators
where needed?
8.
Is the use of respiratory protection governed by a
respiratory protection program which meets the
requirements of 29 CFR 1910.134, Respiratory Protection,
including procedures for:
a) respirator selection
b) medical evaluations
c) training
d) fit testing
e) use
f) cleaning and storage
5
No
E. Labeling and Warning
The purpose of
warning signs and
labeling is to inform
and alert potentially
exposed workers of
the presence and
type of hazard
associated with the
area and/or product
so appropriate
precautions may be
taken. Labeling and
warnings described in
your written program
should be verified by
a "walk-through".
Yes
1.
Are required warning signs printed in English and the
predominant language of non-English speaking employees
(unless otherwise trained and informed of the hazardous
areas)?
2.
Are illiterate employees otherwise trained and informed of
the hazardous areas?
3.
Is a warning sign restricting access posted and readily
visible at entrances to work areas where exposure to
crystalline silica exists?
4.
Is a warning sign or other labeling with appropriate hazard
warning posted or readily available in any work area where
exposure to crystalline silica exists (and where respirators
are required)?
For manufacturers and distributors:
5.
Is a warning label with appropriate hazard warning placed
on all materials, mixtures, and other products containing
more than 0.1% crystalline silica, or on their containers?
Note: These labels must be in addition to or in combination
with labels required by other statutes, regulations or
ordinances?
6.
Do Material Safety Data Sheets indicate the presence of
silica for concentrations at or above 0.1% and indicate the
IARC (International Agency for Research on Cancer)
carcinogenic designation?
6
No
F. Medical Surveillance
An effective medical
surveillance program
should (1) establish a
baseline with which to
assess changes in an
exposed worker's
respiratory system,
(2) provide for early
detection of
abnormalities, and (3)
identify failures in the
dust control program
and potentially
hazardous work
areas not found by
inspection and
exposure monitoring.
The audit should
include a review of
available, non
confidential records to
determine that the
appropriate level of
medical surveillance
is performed for
employees. An
interview with the
medical provider may
be needed to
complete the audit.
Yes
1.
Are medical examinations conducted on individuals who are
potentially exposed to crystalline silica at one-half the
permissible exposure limit (PEL) or more?
2.
Do medical examinations include:
a. Baseline examinations, which include a medical
and occupational history to elicit data on signs and
symptoms of respiratory disease, performed prior
to exposure to crystalline silica?
b. Baseline and follow-up chest x-ray performed prior
to placement?
c.
Chest roentgenogram (posteroanterior 14"x17" or
14" x 14") classified according to the 1970 ILO
International Classification of radiographs of
Pneumoconiosis by certified class "B" reader?
d. Baseline and follow-up pulmonary function tests
which include FEV1 (forced expiratory volume in 1
second), FVC (forced vital capacity) and DLCO
(diffusion lung capacity)?
e. A baseline tuberculosis evaluation (intradermal skin
test using pure protein derivative)?
3.
Are follow-up medical examinations emphasizing the
respiratory system, including the chest x-ray and PFT,
conducted on at least the following schedule:
a. Every three (3) years if the employee has less than
15 years of exposure to crystalline silica, every two
(2) years if the employee has 15 to 20 years of
exposure and annually if over 20 years of
exposure?
b. A more frequent medical examination if respiratory
symptoms develop or upon the recommendation of
the examining physician?
4.
Are chest x-rays obtained upon employment termination?
Medical Management Procedures
5.
Is a worker with a positive chest x-ray (1/0 or greater)
placed in mandatory respiratory protection, or if already
wearing a respirator, is the program re-evaluated to assure
proper fit and that the elements of 29 CFR 1910.134 are
being met?
7
No
Yes
6.
Is the worker referred to a physician specializing in lung
diseases for a medical evaluation and medical monitoring
as warranted by the examining physician?
7.
Is a written opinion from the examining physician as to
whether the employee has any detected condition that
would place the worker at an increased risk provided to the
employer and employee, while specific medical findings
remain confidential?
8.
Are employees, with or without roentgenographic evidence
of silicosis who have respiratory distress and/or pulmonary
functional impairment, fully evaluated by a physician
qualified to advise the employee whether he/she should
continue in a dusty trade?
9.
Are all medical test results discussed with the worker by the
physician and is each employee able to obtain information
on his/her medical exam?
10.
Are medical records maintained for at least 30 years
following the employee's termination of employment, unless
the employee is employed for less than one year and the
records are provided to the employee upon termination?
8
No
G. Training Program
Employee training is
an integral part of any
effective safety and
health program. A
training program and
material safety data
sheets are required to
inform employees
about the hazards of
crystalline silica, the
controls implemented
to prevent
overexposure, and
precautions to take in
areas of potential
exposure. For the
audit, review the
written program and
training records.
Yes
1.
Has a training program for the prevention of silicosis been
developed and implemented?
2.
Are all employees exposed to respirable silica included in
the training program?
3.
Do new employees receive the training as part of their
orientation?
4.
Is the training repeated annually?
5.
From the training program materials, determine if they
include at least the following information:
a. The effects of silica exposure on the lungs and
symptoms of exposure.
b. The increased risk of impaired health due to the
combination of smoking and respirable silica dust
exposure.
c.
The specific nature of work place operations that
could result in exposure to silica above the OSHA
PEL and the type and function of engineering
controls.
d. Instruction about obeying signs that mark the
boundaries of regulated areas containing crystalline
silica.
e. Proper conditions and precautions for safe use or
exposure.
f.
Appropriate emergency procedures.
g. The purpose of respiratory protection, with
instruction on fitting, use and care.
h. Description and purpose of the medical surveillance
program.
i.
6.
Availability and location of written procedures and
health information, such as the material safety data
sheet, and the company's Silica Control Program.
Are records of employee training maintained?
9
No
Table 1: Recommended Respiratory Protection based on NIOSH Assigned
Protection Factors
Exposure Condition
Up to 5 x PEL
Respiratory Protection
Single-use or quarter mask respirator
Up to 10 x PEL



Up to 25 x PEL


Up to 50 x PEL




Air-purifying half-mask respirator.1
Air-purifying full-facepiece respirator equipped with
any type of particulate filter.
Supplied-air half-mask respirator operated in a
demand mode.
Powered, air-purifying respirator with a hood or helmet
and any particulate filter.
Supplied-air respirator equipped with a loose fitting
facepiece and operated in a continuous-flow mode.
Air-purifying full-facepiece respirator equipped with a
high efficiency particulate (HEPA)3 filter.
Powered, air-purifying respirator with a tight-fitting
facepiece and a high-efficiency particulate (HEPA)3
filter.
Supplied-air or self-contained2 respirator equipped
with a full facepiece and operated in a demand
(negative pressure) mode.
Supplied-air respirator equipped with a tight-fitting
facepiece and operated in a continuous-flow mode.
Up to 1,000 x PEL
Supplied-air respirator equipped with a half-mask and
operated in a pressure-demand or other positive pressure
mode
Up to 2,000 x PEL
Supplied-air respirator equipped with a full facepiece and
operated in a pressure-demand or other positive pressure
mo
Up to 10,000 x PEL


Self-contained breathing apparatus equipped with a
full facepiece and operated in a pressure-demand or
other positive-pressure mode.
Supplied-air respirator equipped with a full facepiece
and operated in a pressure-demand or other positive
pressure mode in combination with an auxiliary selfcontained breathing apparatus operated in a pressuredemand mode.
PEL = Permissible Exposure Limit
1Includes disposable half-mask and elastomeric facepieces
2Self-contained breathing apparatus
3Also known as N100, P100, or R100.
10
Silica Control
Program Audit Results
1.
List below the item numbers that were answered "No" in the audit checklist.
2.
Identify the Corrective Action that will be taken to address each item.
3.
When the Corrective Action has been completed, fill in the Completion Date.
Example:
Item #
A14
Item #
Corrective Action
Make results of Silica Survey available for
review
Corrective Action
Date of Audit:
Audited By:
11
Completion Date
5/30/08
Completion Date