It’s Not Just Dust: Implementing a Respirable Crystalline Silica Training Program

By: Rachel Krubsack, Contributor

More than 2 million workers in the U.S. are exposed to crystalline silica on the job. Crystalline silica is a natural component of sand, rock and mineral ores. It’s also found in materials such as concrete, mortar, granite and artificial stone. The most common form of crystalline silica is quartz.

Simply being near silica-containing materials is not hazardous. The hazard exists when specific activities create respirable dust that’s released into the air.

Respirable crystalline silica—very small particles at least 100 times smaller than ordinary sand found on beaches—is created when cutting, sawing, grinding, drilling and crushing stone, rock, concrete, brick, block and mortar.

Overview

Employees must be trained at the time they’re assigned to a position involving exposure to respirable crystalline silica. (photo courtesy J.J. Keller & Associates, Inc.)

OSHA has two standards for crystalline silica–one at 1910.1053 for general industry, and one at 1926.1153 for construction. This article will focus on a training program for general industry.

Employees must be trained at the time they’re assigned to a position involving exposure to respirable crystalline silica. While there’s no annual training requirement in the standard, additional training must be provided as often as necessary to ensure that employees know and understand respirable crystalline silica hazards and the protections available in their workplace. Additional training may be necessary when:

• Employees are asked to perform a task that is new to them
• The employer introduces new protections
• Employees are working in a manner that suggests they have forgotten what was learned in training

Getting Started

Establishing an effective training program may seem overwhelming as you read through the standard’s many requirements. Here are six steps to get you started.

1) Identify the tasks that may expose workers to respirable crystalline silica.

In general industry, the most severe exposures to respirable crystalline silica result from abrasive blasting. Other exposures occur in cement and brick manufacturing, asphalt pavement manufacturing, and the tool and die, steel and foundry industries. Crystalline silica is used in manufacturing, household abrasives, paints, soaps and glass.

Respirable crystalline silica exposure during the fabrication of artificial stone countertops is an emerging hazard that has been associated with several recent outbreaks of severe accelerated silicosis in young workers in the U.S.

2) Explain the health hazards associated with exposure to respirable crystalline silica.

Employees exposed to respirable crystalline silica are at increased risk of developing serious adverse health effects, including silicosis, lung cancer, chronic obstructive pulmonary disease (COPD) and kidney disease.

Silicosis is a life-threatening disease. It typically occurs after 15–20 years of occupational exposure to respirable crystalline silica. Crystalline silica dust particles that are small enough to be inhaled enter the lungs and cause scar tissue to form. The scarring reduces the lungs’ ability to take in oxygen. The worker may experience shortness of breath, fatigue, weakness, chest pain and weight loss.

3) Describe how OSHA regulates exposure to respirable crystalline silica.

OSHA’s standard on respirable crystalline silica sets the permissible exposure limit (PEL) as 50μg/m³ (micrograms of silica per cubic meter of air), calculated as an 8-hour, time-weighted average (TWA).

The rule includes provisions for:

• Exposure assessment
• Regulated areas
• Engineering and work practice controls
• Written exposure control plan
• Abrasive blasting
• Respiratory protection
• Housekeeping
• Medical surveillance
• Hazard communication
• Signs
• Employee information and training
• Recordkeeping

A copy of 1910.1053 must be readily available without cost to each covered employee. Employers may provide access by means of a printed or electronic copy in a central location or company website. When access is provided electronically, however, employees must receive training on accessing designated computers that must be available at all times, without any barriers to access.

4) Outline the specific measures implemented to reduce exposure in the workplace.

Employers monitor the air and use the results to make decisions on engineering controls, work practices, PPE and the need for a medical surveillance program.

Within 15 working days after completing an exposure assessment, the employer must individually notify each affected employee, in writing, of the results of that assessment or post the results in an appropriate location accessible to all affected employees.

Examples of controls include exhaust-ventilation and dust-collection systems, water sprays, wet drilling, substitution of less hazardous materials for abrasive blasting, using vacuums with HEPA filters and wet sweeping of work areas. Use warning signs to identify hazardous work areas.

5) Explain the medical surveillance program.

A medical surveillance program is available at no cost, and at a reasonable time and place, to each employee who will be occupationally exposed to respirable crystalline silica at or above the action level for 30 or more days per year. The action level for airborne respirable crystalline silica is set at 25μg/m³ (micrograms of silica per cubic meter of air), calculated as an 8-hour TWA.

The initial, baseline medical examination will be given to each affected worker within 30 days of his or her initial assignment. The exam consists of taking the employee’s medical and work history, with an emphasis on exposure to respirable crystalline silica, dust and other agents affecting the respiratory system; along with any history of respiratory system dysfunction, including signs and symptoms of respiratory disease; any history of tuberculosis; and smoking status and history.

The physical exam will include a chest x-ray, a pulmonary function test, testing for latent tuberculosis infection and any other tests deemed appropriate by the physician. Periodic examinations will be available at least every three years or more frequently, if recommended by the physician.

The physician will give each affected employee a written medical report within 30 days of the exam. The report includes information on any medical conditions that need further evaluation or treatment; recommendations on the worker’s fitness to use a respirator; any recommended limitations on the employee’s exposure to respiratory crystalline silica; and any referrals to a specialist.

If there is a referral to a specialist, the employer must make a medical examination by a specialist available to the worker within 30 days of receiving the written medical opinion.

6) Explain what employees can do to protect themselves.

Workers exposed to respirable crystalline silica should:

• Learn about the health effects of respirable crystalline silica and know that smoking adds to the damage.
• Participate in air monitoring and training programs.
• Know the work operations where exposure to respirable crystalline silica may occur.
• Follow all safe work procedures for the job.
• Use all available engineering controls, such as blasting cabinets, water sprays and local exhaust ventilation. If a less hazardous material can be substituted for crystalline silica, use the less hazardous material.
• Use an N95 NIOSH-certified respirator if a respirator is required. Wear a type-CE, abrasive-blast, supplied-air respirator for abrasive blasting.
• Change into disposable or washable work clothes at the worksite, if possible; shower and change into clean clothing before leaving the worksite.
• Never eat, drink, use tobacco products or apply cosmetics in areas where there is dust containing crystalline silica.
• Wash their hands and face before they eat, drink, smoke or apply cosmetics outside of the exposure area.

While the silica standard has numerous requirements related to training, these six steps can provide a starting point for an effective program. Employers can assess employees’ understanding through discussion of the required training subjects, written tests or oral quizzes.

About the Author:

Rachel Krubsack is an Associate Editor on the Environmental, Health and Safety (EHS) Publishing Team at J. J. Keller & Associates, Inc. She researches and creates content on a variety of workplace safety topics, including hearing conservation, training requirements, bloodborne pathogens, emergency action plans, hazard communication and lockout/tagout. She is Editor of the Employee Safety Training Advisor newsletter and the following manuals: OSHA Rules for General Industry, Hazard Communication Compliance and Hazard Communication Pro.