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New OSHA Silica Rules Looming

Thursday, April 14, 2011

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New federal rules tightening workplace exposure limits and other requirements involving respirable crystalline silica are expected soon, likely bringing major changes for the coatings industry.

The Occupational Safety and Health Administration’s overhauled Occupational Exposure to Crystalline Silica (RIN 1218-AB70) rule completed peer review Jan. 24 and went to the Office of Information and Regulatory Affairs on Feb. 14.

OSHA said its Notice of Proposed Rulemaking would be issued in April, but an OSHA spokesman said Thursday that the process had been delayed. As of now, the spokesman said, the NPR should be available in late May or possibly early June.

2M+ Workers at Risk

More than two million workers are exposed to crystalline silica dust in general industry, construction and maritime industries, including workers involved in abrasive blasting,  paint manufacturing, brick making, and glass and concrete manufacturing. Workers performing highway repair, masonry and concrete work are also exposed to silica dust.
 
 CDC/NIOSH

 Photos: CDC/NIOSH

Respirable dust from silica sand and other abrasive materials can put abrasive blasting workers at high risk of harmful exposures, NIOSH reports.

Long-term exposure to silica dust can cause silicosis, a uniquely occupational disease that can be fatal; lung cancer; tuberculosis; and other respiratory and renal diseases.

OSHA estimates that silicosis contributed to, or caused, the deaths of  200 to 300 workers per year from 1990 to 1996 and says that many more silicosis-related deaths have gone undetected. The Centers for Disease Control and Prevention says silicosis kills more than 200 workers per year and disables hundreds more, claiming more than 14,000 lives since 1968. 

Moreover, OSHA reports, “exposure studies and OSHA enforcement data indicate that some workers continue to be exposed to levels of crystalline silica far in excess of current exposure limits.”

Obsolete Formulas, Standards

OSHA is expected to lower Permissible Exposure Limits (PEL) to silica as part of a comprehensive new standard that is likely to include provisions for exposure monitoring, medical surveillance and working training. The scope of the rule is still being deliberated, and risk analysis is underway.
 
 CDC/NIOSH
More than 2 million U.S. workers are exposed to respirable crystalline silica in a variety of industries, the federal government says.

“There is a particular need for the Agency to modernize its exposure limits for construction and maritime workers, and to address some specific issues that will need to be resolved to propose a comprehensive standard,” OSHA notes.

The current OSHA PEL for general industry is based on a 1971 formula recommended by the American Conference of Governmental Industrial Hygienists (ACGIH). The current PEL for construction and maritime (derived from ACGIH's 1962 Threshold Limit Value) is based on particle counting technology, which is considered obsolete.

ACGIH and the National Institute of Occupational Safety and Health recommend a 50µg/m3 exposure limit for respirable crystalline silica. 

Both ASTM International and the Building Construction Trades Department of the AFL-CIO have similar standards already in place.

OSHA says it has tried to address silica hazards through a variety of non-regulatory approaches, including initiating a Special Emphasis Program on silica in October 1997, co-sponsorship with NIOSH and MSHA of the National Conference to Eliminate Silicosis, and information on government web sites.

   

Tagged categories: Abrasive blasting; Abrasives; Concrete repair; Exposure conditions; Health and safety; OSHA; OSHA; Regulations; Silica

Comment from Ben Kuehl, (4/15/2011, 8:53 AM)

Let the circus begin


Comment from kent webster, (4/15/2011, 5:04 PM)

My company primarily paints water storage tanks. The blast hoods that we provide our workers protect them from silica & coal slag dust during the blasting operations. I don't understand why silica dust is and has been the focus for respiratory protection, when the coal slag dust is just as harmful. I think all of the coal miners that became ill were affected by black coal dust, not silica dust. Am I missing something on this issue?


Comment from Jeroen Keswiel, (4/18/2011, 6:06 AM)

Dear Mr. Webster, For your formation, coal slag is not coal. Actually there is no coal in coal slag at all. The Material is the by-product from coal fired power plants. The material is not harmful, it does not contain free silica (< 0,1%) and is chemically inert. Workers should be protected from any kind of dust, but the free silica dust of silica sand is much more harmful. Silica sand can create silicosis, while coal slag will not.


Comment from Stephen Mellon, (4/18/2011, 9:43 AM)

I guess the heavey metals and toxins in coal slag don't count as harmful. Although OSHA and the EPA seem to think so.


Comment from Tom Schwerdt, (4/18/2011, 10:04 AM)

Stephen, do you have a link to any independent lab results or study on the heavy metals and toxins in coal slag? I have seen this mentioned numerous times, but have never seen actual data. Thanks.


Comment from Arnold Ferguson, (4/18/2011, 10:19 AM)

Since 2006, the ACGIH TLV for crystalline silica (or quartz) has been 0.025 mg/m3 (or 25 µg/m3) for an 8-hour time weighted average. The article indicates the TLV is 50 µg/m3, which was the ACGIH TLV until 2006.


Comment from Arnold Ferguson, (4/18/2011, 10:28 AM)

Since a great deal of painting and blasting is considered construction work by OSHA, the formula in 29 CFR 1926.55, Table for Mineral Dust shows the standard as 250 mppcf/(%SiO2 +5), which cannot be measured using the current technique of a 5µ PVC filter with a cyclone. The construction industry standard has an identical formula in OSHA General Instusdry Standard, 29 CFR 1910.1000, Table Z-3, Mineral Dusts. The general industry standard has a conversion for the current sampling technique. [250 mppcf/(%SiO2 + 5) = (10 mg/m3)/(%SiO2 + 2)]


Comment from paul mellon, (4/18/2011, 11:21 AM)

Tom, is response to your question about the sources of information confirming the presence of heavy metals and toxins in coal slag abrasives there are numerous studies from OSHA,NIOSH and the EPA that can assist you. Even the coal slag industry admitting to the EPA that copper slag has a “ heavy metal “problem. I think the surface preparation industry should start paying attention to slag abrasives because the suspension of the Beneficial Use program and the EPA admisiion they never actually tested slag abrasives before allowing them in the program is going to have widespread industry repercussions. Also given the wildly inaccurate comments by people like Mr. Keswiel on coal slag, it is alarming how many people in our industry, especially the blasters, have no idea what is in the products they use everyday. Here is a small sample of the data you requested: 1997 EPA STUDY ON BLASTING http://www.epa.gov/ttn/chief/ap42/ch13/bgdocs/b13s02-6.pdf Go to page 2-1 of this EPA report on abrasive blasting guidelines and see what he EPA has to say about the Industry Leader’s of Brand of Coal Slag Product NIOSH, 1998/1998 STUDY ON NON-SILICA ABRASIVES Evaluation of Substitute Materials for Silica Sand in Abrasive Blasting This major study conducted by KTA Tator is often cited by EPA and OSHA on the metals found in slags. You should read this entire report and the studies as it debunks all the myths about the safety of all slag products. On page 145 under “Recommendations” you can see what the study says about the toxins found in coal copper and nickel slags. Also read what the study has to say about crushed glass abrasives. ( click on the Phase I Report pdf ) 2006 OSHA GUIDANCE FOR INDUSTRIAL BLASTING http://www.osha.gov/dts/maritime/standards/guidance/shipyard_guidance.html Please read the paragraph titles Abrasive Blasting Media for comments by OSHA on the toxins contained in coal slag abrasives. The above report NIOSH report is cited in the references. 2007 OSHA/NIOSH Joint Study that focused on examining BERYLLIUM in COAL SLAG ABRASIVES! They chose the Industry leading Brand of coal slag for the test! http://www.cdc.gov/niosh/surveyreports/pdfs/ECTB-263-13a.pdf See page 11 of the pdf under Conclusions where they state” the blaster exceeded the NIOSH REL and OSHA PEL for beryllium in construction on the first day. He exceeded the OSHA PEL for total dust on both days. “ Tom there is quite a bit more information from the US and UK governments on the toxic hazards contained in this products. Let me know if would like to know more.


Comment from paul mellon, (4/18/2011, 11:46 AM)

http://www.cdc.gov/niosh/abrpt946.html Tom, here is the link to the NIOSH study by KTA Tator, it didnt attach to the above comments.


Comment from Richard McLaughlin, (4/19/2011, 9:19 AM)

Once again, for the record, let it be known that coal slag, a byproduct of high temperature coal combustion that leaves a product more akin to glass, is not, nor ever has been, the same as metallic slags. Metallic slags are created from the skim removed from a smelter during the refining process and are composed of just about everything but the metal you are refining, hence the reason copper slag in particular is known to have higher levels of heavy metals due to the nature of the ore source. Oh, and I do have a full copy of the report Paul sites. It was commissioned by the CDC and conducted by KTA based on guidelines established by NIOSH as part of a study to find an alternative to silica sand only, nothing more. The results are interesting to read.


Comment from Tom Schwerdt, (4/19/2011, 9:55 AM)

Paul, I looked at your first linked study. Page 2-1 says that slags "have been documented to release other contaminants, including hazardous air pollutants (HAP), into the air." This is very vague, does not give which slags, which HAPs or how much is released. Tables later talk about emissions, but much of it was from measurements taken blasting LEAD PAINT. I've started looking at the KTA study, but it is a big one. Looks much like a much cleaner setup too (other than tables not being in the actual reports.) There was only a single crushed glass abrasive studied, but a whole host of slags. It is interesting you did not mention that glass was the most expensive average cost per square foot of blasting out of all the abrasive types. Crushed glass was just below silica sand for beryllium levels, and was above silica sand for chromium, lead (4.5 TIMES higher) and manganese. It's pretty apparent from this study that ALL abrasives commonly used in our industry have health exposure risks, and that we should do our best to minimize those risks.


Comment from paul mellon, (4/19/2011, 11:51 AM)

Richard, you honestly can not believe what you wrote about coal slag not being a slag product. Do work for a coal slag company? Coal slag contains heavy metals and toxins for the real record. Beryllium is one of the major toxins found in coal slag according to OSHA,NOISH and the EPA. Maybe you should read the information I sent before you make blatantly false statements. I sent this before but let’s try again. Please read this NIOSH/OSHA study about Beryllium in coal slag : It is very short and easy to understand: http://www.cdc.gov/niosh/surveyreports/pdfs/ECTB-263-13a.pdf Also in addition you may have the NOISH/KTA report but you failed to read it. The study repeatedly warns of the metals and toxins found in all 3 slags, coal copper and nickel. Check out page 145 in the recommendations page.


Comment from paul mellon, (4/19/2011, 12:16 PM)

Tom the KTA report has 900 pages of documented facts about the abrasives tested. It is long but is very easy to negotiate the results. In regards to beryllium the KTA report shows beryllium was 23 times higher than sand but ominously the beryllium in coal slag exceeded the personal exposure limits of BOTH NIOSH and OSHA. That is why you should read the study from 2007 because it was done because of the concern of beryllium in coal slag! And yes I do not mean to imply that there is a perfect abrasive because have their limits and issues that must be managed. That said here is what the KTA report said on page 145 after all the analysis of the various abrasives was done: Recommendations Based upon the above conclusions, consideration should be given to the following recommendations: 1. In order to reduce the airborne concentrations of the eleven hazardous health-related agents, consider the use of crushed glass or specular hematite. In addition, staurolite and olivine might be considered as alternatives to silica sand to reduce airborne concentration to most of the eleven hazardous health-related agents. 2. When coal slag, nickel slag, copper slag, garnet and/or steel grit abrasives are used as alternatives to silica sand, select specific products from within the generic category which limit worker exposure to multiple toxic contaminants and which optimize desired performance characteristics. As indicated throughout this study, the attributes of the individual products within a generic classification varied widely. 3. While no direct correlation can be established at this time, comparison of the relative concentration of health-related agents in the virgin abrasive, and assessment of the source of the raw materials and/or the manufacturing process, should be used as initial selection criteria for all of the abrasives and in particular for coal slag, nickel slag, copper slag, garnet, and steel grit abrasives.


Comment from Richard McLaughlin, (4/20/2011, 9:34 AM)

Paul, yes, I can believe what I write since it is based in facts. What I stated about the sources of different slags is true. Your reasoning to lump any product with the word “slag” associated with it as being the same type of product is simply flawed. Just because the word “milk” is used to describe both, it doesn’t mean milkweed is in the same family as a milkshake. And no, I don’t work for the coal industry. My company sells both coal slag and your crushed glass product, along with just about every other commonly used abrasive. My only interest is to keep the waters from being muddied by false or misleading information. That is the reason I read a LOT of reports and studies. Add to that years of holding a nozzle, and running a family owned general contracting business that I grew up in, you can see my opinions are based on more than a few studies.


Comment from Jerry LeCompte, (4/21/2011, 9:45 AM)

Findings of Federal Judge Jack yet the silicosis hype goes on: Judge Jack, formerly a registered nurse, studied the Centers for Disease Control and Prevention's (CDC's) statistics of silicosis cases and discovered the disease causes fewer than 200 deaths in the U.S.


Comment from Tom Schwerdt, (5/13/2011, 10:22 AM)

I think using the KTA report to "look out for this list, but glass is okay" for selection abrasives is misleading. Those abrasives each had multiple types/brands tested, with widely varying results in each category. Glass had a single material tested (and still had a lot more lead than sand). One sample can't be used authoritatively for a whole category, particularly when each category has a whole host of raw material sources.


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