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, LLC – Nashville, TN
Efforts are currently
underway to establish
an OSHA standard for
Crystalline Silica
copyright © 2006 CIH Service, LLC
Current Respirable Silica
Permissible Exposure
Limit
Based upon formula:
= 10 milligrams/meter3
(% Silica + 2)
Controls silica to ~ 0.1 mg/m3
(when respirable dust is 100%
silica)
copyright © 2006 CIH Service, LLC
History of Current Standard
1970 – PEL formula adopted by
OSHA from 1969 ACGIH TLV
1989 - OSHA established a “fixed”
PEL at 0.1 mg/m3 for respirable
quartz
1992 - Fixed PEL was vacated
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Silica Control History
August 1996 – OSHA Special Emphasis
Program (SEP) started
October 1996 – International Agency for
Research on Cancer (IARC) listed silica
as “Carcinogenic to Humans”
1997- present. Silica standard on OSHA
Unified Agenda
2003- SBREFA report completed
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Current Status of Silica
Rulemaking Process
Pre-Rule Stage
Next Target Date = April 2006
Complete Peer Review of Health
Effects and Risk Assessment
due
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Future Actions Still Needed
Advanced Notice of Proposed
Rulemaking (ANPR) must occur
Notice of Proposed Rulemaking
Public Comment period
Public Hearing
Post-Hearing Comment period
Final Rule must be published in the
Federal Register
Phase-in period for Compliance
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Other Crystalline Silica
Exposure Standards
NIOSH REL = 0.05 mg/m3
ACGIH TLV = 0.025 mg/m3
NIOSH and ACGIH do NOT
consider economic impact on
business community to meet the
standards recommended
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Draft Proposed
Crystalline Silica PEL
0.1 mg/m3 with 0.05 mg/m3
medical Action Level
0.075 mg/m3 with 0.04 mg/m3
medical Action Level
0.05 mg/m3 with no medical
Action Level
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Monitoring
 Initially (Exception for abrasive
blasters in type CE abrasive
blasting respirators or
employers with objective data)
 Quarterly if greater than PEL
 Every 6-months if greater than
Action Level
 Observation of Monitoring and
Employee Notifications
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Regulated Areas
Required for areas that exceed
or are reasonably expected to
exceed the PEL
Established by “Competent
Person”
Demarcated with signs, barriers
or negative pressure enclosures
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Competent Person
Definition – 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
Designated for each worksite
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Competent Person
Responsibilities
Evaluate exposures and existing controls
Implement corrective measures, including
temporary work stoppage
Define, demarcate and check Regulated areas
Inspect Abrasive Blasting activities
Communicate with other employers at the
worksite to inform of regulated area
boundaries around abrasive blasting
operations
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Prohibited Practices
 Job rotation
 Use of compressed air, brushing or dry
sweeping for cleaning
 Eat, drink or use tobacco in regulated areas
 Remove dust from clothing by blowing or
shaking
 Abrasive Blasting using Silica in enclosed
areas
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Abrasive Blasting
Only in Regulated areas
Type CE, continuous flow respirator
(hood or helmet)
Blasting areas cleaned using:
HEPA vacuums
Wet Methods
Dust suppressants
If dry blasting with sand in an open area,
alternative blast medias must be evaluated
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Personal Protective
Equipment
Respirators required
for employees exposed
above the PEL
Or for those who
request it
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Protective Work Clothing
New disposable
clothing provided
each day
Non-disposable
clothing such as
coveralls or full
bodied clothing
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Hygiene Facilities
 Change rooms
 Only authorized employees allowed to remove
non-disposable clothing for laundering,
maintenance or disposal
 Contaminated clothing placed and stored in
closed containers labeled with Silica hazard
warning labels
 Laundry service must be informed of potential
silica contamination including harmful effects
 Contaminated clothing transported in sealed
impermeable bags with hazard label
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Shower Facilities
Considered as an option for
those exposed above the PEL
May require employer to ensure
employees shower at the end of
each work shift
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Lunchrooms
Must be below the PEL
May require temperature controlled,
positive pressure, filtered air supply for
lunchrooms
May require HEPA filtered vacuums for
cleaning clothes before entering
lunchrooms, change rooms or shower
rooms
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Housekeeping
HEPA vacuum Silica accumulations
Prevent accumulation of silicacontaminated water that could dry
and result in residue that could
contribute significantly to airborne
exposures
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Health Screening
Offered initially and annually for all
exposed above the Action Level (or PEL if
0.05 mg/m3)
Before assignment to tasks above Action
Level
Whenever employee reports silica related
symptoms
Within 30 days of termination
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Health Screening
Content
 Occupational and
health history with
emphasis on silica
exposures and other
respiratory agents
 Physical exam with
emphasis on
respiratory system
 Chest X-Ray
 Pulmonary Function
Test (PFT)
 Any other tests
deemed necessary by
the HCP
 Annual review of
history and physical
exam with emphasis
on respiratory system
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Health Screening Info
Employer Provides to HCP
Description of employee’s job as it relates to
silica
A copy of paragraph (k), Employee Health
Screening section of the standard
Results from employee exposure monitoring
Results of previous health screening
A description of PPE
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HCP Written Opinion
 Shared with employee within 15 days
 Must include: Employee Health condition related to
silica. Non-silica findings must remain confidential
from the employer
 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
 A statement HCP has informed employee of silica
screening results
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Pulmonary Specialists
Employer must make
one choice available
from the list provided by
the HCP
Written opinion must be
obtained within 30-days
of examination
Copy of results to
employee within 15-days
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Pulmonary Specialists
(continued)
 Specialists written opinion must include:
Employee health condition related to silica
Recommended work limitations, such as
restrictions or removal with probable
durations
Statement results were shared with
employee
 Employer must report all cases of silica-related
disease identified by the pulmonary specialist to
NIOSH
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Hazard Communication
All employees potentially exposed are
informed and trained initially, prior to
assignment
Must be informed on the requirements of
the silica standard and how to access or
obtain a copy
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Recordkeeping
 Historical or objective data
 Exposure Measurements–30 years
 Health Screening Records–Employment+30 years
 Respirator Fit Test Records-most current
 All records may be kept in any form
 Available upon request to Asst. Secretary, subject
employee or qualified representative
 Provision for transfer of records upon sale or close
of business
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Some Items that Were
NOT Included
Written Control Plan
Medical Removal Provisions
Consideration for Non-standard
work shifts (greater than 8-hours)
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Potential Impacts
 At PEL of 0.1 mg/m3:
Estimated ~⅓ may have overexposure areas
or tasks
Dry sanding, sawing, abrasive blasting and
mixer cleaning tasks produce most
overexposures
Most can be controlled through improved
housekeeping, work practices and ventilation
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At PEL of 0.075 mg/m3
Estimated ~½ of workplaces may have
tasks or areas with overexposures
In addition to tasks that exceeded 0.1
mg/m3, other tasks such as additive
mixing, material loading/unloading may
produce overexposures, especially in
open cab mobile equipment
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At a PEL of 0.05 mg/m3
 MIOSHA 2004 Annual Report on Silicosis - 60% of
workplaces sampled in excess of NIOSH REL or PEL
at 0.05 mg/m3 (Note- Data summarized for all
inspected business!)
 Regulated areas now extend into more areas
 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)…
 Respirators!
copyright © 2006 CIH Service, LLC
Example of Compliance
Costs with PEL at 0.1 mg/m3
• Plant employs 20 laborers with 1/3 Above
PEL and 1/3 Above Action Level = 12
employees
• Analytical costs for quarterly and SemiAnnual monitoring = $3,360
• Signs for Regulated areas = $14 minimum
for 2 signs
• 85 boxes/yr of 3M 8210 N95 disposable dust
masks = $1,154
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Compliance Costs
(continued)
• Baseline Health Screening = $2,160 ($180
per employee for 12 employees)
– $35 Physical
– $65 PFT
– $80 Chest X-Ray
• Year1 and Year2 = $1200 (Physical and PFT
only…Chest X-ray every 3rd Year)
• Estimate does not include time away from
work!
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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
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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 Facility
Changes are needed for Lunchrooms,
Shower facilities and Exhaust
Ventilation (add~ $10K-$500K)
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Recommendations for
Action!
Evaluate your workplace!
Formulate a silica exposure
control plan!
Communicate with your NCMA
representatives on how this would impact
your business!
Communicate with your elected officials to
educate them on silica issues!
copyright © 2006 CIH Service, LLC
Summary
A specific OSHA silica standard may
cause significant changes in Concrete
Products industry
As 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