Christine Reed, CHCM

1. Silica Rule Update / Silica Mitigation Equipment
Christine Reed, CHCM

2. Silica Rule Update
 Few updates since the standards were implemented
New Sample Training PowerPoint for Construction
• Basic info – what is silica, where is it found, health hazards, protecting
employees (Eng, A/WP, Resp, HK), competent person, medical)
Video Protecting Workers from Silica Hazards in the Workplace, 5 minutes -
basic overview for the new employee
• Other videos for Table 1 Tasks (next slide)
Table 1 Task Fact Sheets for Construction (next, next slide)

3. Controlling Silica Dust in Construction, Videos for
Table 1 Tasks
 Stationary Masonry Saws
 Handheld Power Saws
 Handheld and Stand-Mounted Drills
 Jackhammers or Handheld Powered Chipping Tools
 Handheld Grinders for Mortar Removal (Tuckpointing)
 Handheld Grinders for Uses Other than Mortar Removal

4. Table 1 Tasks, Fact Sheets for Construction
•Handheld Power Saws
•Handheld Grinders for Tasks Other Than Mortar
Removal
•Handheld Power Saws Used to Cut Fiber-Cement
Board
•Jackhammers or Handheld Powered Chipping Tools
•Handheld and Stand-Mounted Drills
•Stationary Masonry Saws
•Handheld Grinders for Mortar Removal (Tuckpointing)
•Walk-Behind Saws
•Drivable Saws
•Rig-Mounted Core Saws or Drills
•Dowel Drilling Rigs for Concrete
•Vehicle-Mounted Drilling Rigs for Rock and
Concrete
•Walk-Behind Milling Machines and Floor Grinders
•Small Drivable Milling Machines ( < Half Lane)
•Large Drivable Milling Machines ( > Half Lane)
•Crushing Machines
•Heavy Equipment and Utility Vehicles Used
During Demolition Activities
•Heavy Equipment and Utility Vehicles Used for
Grading and Excavating Tasks

5. Engineering Controls
Only As Good As Maintained!

6. FAQs for the Construction Industry, August 2018
 Scope
 Definitions
 Exposure Control Methods
 Housekeeping
 Written Exposure Control Plan
 Medical Surveillance
 Employee Information and Training
 Recordkeeping

7. Citations / Penalties
Construction (1926.1153) all industries
 202 Inspections
 556 citations
 avg. 2.75 citation / inspection
 $816,926 penalties
 avg. $1,469.29 / citation
General Industry (1910.1053) all industries
 5 Inspections
 12 citations
 avg. 2.4 citations / inspection
 $22,315 penalties
 avg. $1,859.58 / citation
October 2017 thru September 2018

8. Citations / Penalties
 1926.1153(c)(1) the employer shall fully and properly implement
engineering controls, work practices, and respiratory protection
specified for tasks on Table 1, unless employer assesses and limits
exposure to RCS, IAW para (d)

9. Citations / Penalties
 1926.1153 (d)(2)(i) - assess exposure of each employee who is or may
reasonably be expected to be exposed to RCS at or above the action
level IAW either the performance option or the scheduled monitoring
option

10. Citations / Penalties
 Performance option - assess exposure for each employee on basis of
any combination of air monitoring data or objective data sufficient to
accurately characterize employee exposures to RCS

11. Citations / Penalties
 Scheduled monitoring option
─ sample employees each shift, each job classification, each work
area
─ exposures below the action level, discontinue monitoring
─ exposures at or above action level but at or below PEL, repeat
monitoring within 6 months
─ exposures above the PEL, repeat monitoring within 3 months

12. Citations / Penalties
*repeat monitoring is two samples taken seven or more days apart

13. Citations / Penalties
 1926.1153(g)(1) Exposure Control Plan
─ description of the tasks in the workplace
─ description of engineering controls, work practices, respiratory protection
─ description of housekeeping measures
─ description of procedures used to restrict access to work areas

14. Citations / Penalties
 1926.1153(I)(1) Communication of RCS hazards to employees -
Hazard Communication
 1910.1053(j)(1) Communication of RCS hazards to employees -
Hazard Communication

15. Citations / Penalties
 1910.1053(c) Permissible Exposure Limit
─ (d)(1) assess exposure
─ (e)(1) regulate areas
─ (f)(1) engineering controls, work practices
─ (f)(2)(i)(C) housekeeping measures
─ (l)(1)(i) failure to implement the standard

16. Citations / Penalties
 1910.1053(g)(2) Respiratory Protection Program
Where respiratory protection is required, employers must provide each
employee with an appropriate respirator

17. Citations / Penalties
 Virginia Department of Labor
 Inspection date, for one company, 02202018 – 08062018
 Fines assessed at $296,065.00
 Specifically:
1. Communication of RCS hazards to employees
2. Not fully and properly implementing engineering controls, work practices
and respiratory protection
3. Not assessing employee exposures to RCS
4. Not implementing respiratory protection

18. Respirator Use, 1910.1053
 Respirators required
 When PEL exceeded during periods to install/implement eng/work practice controls
 When PEL exceeded during tasks, in which engineering and work practice controls
are not feasible
 When engineering/work practice controls are not sufficient to reduce exposures to
or below the PEL
 When in a regulated area
• The employer must assess whether the observer already has the equipment,
medical clearance, and training necessary to enter the area in question, including
observers not employed by the employer

19. Respirator Use, 1926.1153
 For tasks specified on table 1
 For tasks not specified on table 1 in which exposures exceed the PEL
 When engineering controls and work practices have not been fully and
properly implemented

20. Respirator Use, 1926.1153
Fully and properly implemented means…
 For tasks performed indoors or in enclosed areas, provide a means of exhaust as
needed to minimize the accumulation of visible airborne dust
 For tasks performed using wet methods, apply water at flow rates sufficient to
minimize release of visible dust

21. Respirator Use, 1926.1153
 For measures implemented that include an enclosed cab or booth, ensure that the
enclosed cab or booth
 Is maintained as free as practicable from settled dust
 Has door seals and closing mechanisms that work properly
 Has gaskets and seals that are in good condition and working properly
 Is under positive pressure maintained through continuous delivery of fresh air
 Has intake air that is filtered through a filter that is 95% efficient in the 0.3-10.0 μm
range (e.g., *MERV-16 or better)
 Has heating and cooling capabilities
*minimum efficiency reporting value

22. Medical Surveillance
 1910.1053(i)(1)(i)The employer shall make medical surveillance available at no cost
to the employee, and at a reasonable time and place, for each employee who will be
occupationally exposed to respirable crystalline silica at or above the action level for
30 or more days per year.
 1926.1153(h)(1)(i)The employer shall make medical surveillance available at no cost
to the employee, and at a reasonable time and place, for each employee who will be
required under this section to use a respirator for 30 or more days per year.

23. Silica Mitigation Equipment
 Exhaust Systems
 Design for collection at the source, not for the area
 Regular system inspections
 Regular preventive maintenance

27. Silica Mitigation Equipment
 Vacuums – w / HEPA filtration
─ Shop Vacs
─ Master Force
─ Nilfisk

28. Silica Mitigation Equipment
Central Vac Systems
─ American Vacuum Company
─ Vac-U-Max

29. Silica Mitigation Equipment
Sweepers
─ Tennant – S9 / S10
─ Power Boss

30. Silica Mitigation Equipment
 Sweeping Compounds
 Delta Foremost
 Tough Guy

31. Silica Mitigation Equipment
 SonicAire – Blowers
 Designed to create a barrier overhead to reduce dust
accumulation
 Creates downward draft
 Size of facility determines # of blowers to install