safety essentials - annualmeeting.nadca.com · 3/14/2018 4 asbestos management • if you work...

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Safety EssentialsSafety EssentialsSafety EssentialsSafety EssentialsIntroduction to the NEW Introduction to the NEW Introduction to the NEW Introduction to the NEW

NADCA Safety ManualNADCA Safety ManualNADCA Safety ManualNADCA Safety Manual

Copyright © 2018 NADCA, All Rights ReservedNo part of this publication may be reproduced or distributed by any means, electronic or mechanical, including photocopy, recording, or any other information storage and retrieval system, without prior written consent from the publisher.

Greg Santo

�This presentation is not intended to be a comprehensive

program covering all aspects of this topic.

�All participants are encouraged to read and follow

applicable standards, codes and regulations related to

this topic.

�The views and opinions following are the presenter’s

opinions and not necessarily the official position of the

National Air Duct Cleaners Association.

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Safety Manual Reflects Industry ChangesSafety Manual Reflects Industry ChangesSafety Manual Reflects Industry ChangesSafety Manual Reflects Industry Changes

• Best Practices Update Incorporates• Consensus standards

• Updated OSHA Standards• Construction (29 CFR 1926) • General Industry (29 CFR 1910)

• Companies operating in OSHA approved State Plans will need to make adjustments to reflect those applicable standards

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Consensus StandardsConsensus StandardsConsensus StandardsConsensus Standards• 22 Organizations Recognized by OSHA including:

• American Conference of Governmental Industrial Hygienists (ACGIH)

• American National Standards Institute (ANSI)

• American Society of Mechanical Engineers (ASME)

• American Society for Testing Materials (ASTM)

• American Welding Society (AWS)

• Compressed Gas Association (CGA)

• National Fire Protection Association (NFPA)

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NADCA Consensus StandardsNADCA Consensus StandardsNADCA Consensus StandardsNADCA Consensus Standards

The Standard for the Assessment,Cleaning and Restoration (ACR) of HVAC Systems

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Dropped Object ProtectionDropped Object ProtectionDropped Object ProtectionDropped Object Protection

• The International Safety Equipment Association (ISEA) is seeking public comments in response to its proposed new standard dropped object prevention solutions. Currently designated as ISEA 121, the standard seeks to establish minimum design, performance, and labeling requirements for solutions that reduce dropped objects incidents in industrial and occupational settings.

• An industry first, the standard focuses on preventative solutions actively used by workers to mitigate the potential effects of falling objects.

• Dropped objects include hand tools, instrumentation, small parts, structural components and other items that have to be transferred and used at heights. The implications from struck-by injuries can range from inconvenience or loss of productivity to life-altering injury or death.

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Abrasive BlastingAbrasive BlastingAbrasive BlastingAbrasive Blasting

• Updated to require management and employees to be aware of crystalline silica in safety data sheets from blasting ‘sand’.

• Most companies now use silica-free products in sand blasting activities… but verify safety data sheet (SDS)

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Rotating Aerial LiftsRotating Aerial LiftsRotating Aerial LiftsRotating Aerial Lifts

• Updated to reflect the latest consensus best practices

• ANSI A92.2 - 2015 Version

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Asbestos ManagementAsbestos ManagementAsbestos ManagementAsbestos Management

• If you work in areas where exposure is possible, you must train your employees annually

• OSHA has minimum guidelines, and states and some cities have stricter regulations.

• Class III Operations and Maintenance may be for the removal of small amounts of asbestos. Requires 16 hours of training and may be regulated in some states.

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Alcohol and Substance Abuse PolicyAlcohol and Substance Abuse PolicyAlcohol and Substance Abuse PolicyAlcohol and Substance Abuse Policy

• No substantive changes in program

• Commercial Driver’s License (CDL) may have applicability to your program. Drug testing would be covered by 49 CFR 40 requirements

• Marijuana Legalization in some states creates issues

• Marijuana use should be treated the same as Alcohol use

• Breathalyzer commercially available for Marijuana (and alcohol)

• Safety Sensitive Working Environment should be considered.

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Behavior Based Safety (BBS)Behavior Based Safety (BBS)Behavior Based Safety (BBS)Behavior Based Safety (BBS)

• Good Program for Managing Risk

• Identifies At-Risk Behaviors

• Once you start, you need to continue the process to validate

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PermitPermitPermitPermit----Required Confined SpacesRequired Confined SpacesRequired Confined SpacesRequired Confined Spaces

• Expanded into construction ( 29 CFR 1926. 1200-1213)

• Expands communication between owner and all subcontractors.

• Competent Person must Evaluate Confined Spaces.

• Constant Air Monitoring.

• Continuous Monitoring of Engulfment Hazards.

• Temporary Suspension of a Permit When Conditions Change.

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Crystalline SilicaCrystalline SilicaCrystalline SilicaCrystalline Silica

• Construction (29 CFR 1926) or

• Maintenance or general industry (29 CFR 1910)

There are new standards that will affect every company that may work with concrete, brick, block, or disturb concrete, brick or block

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Hawk’s Nest, WV Mining Disaster

In the 1920’s & 30’s a 3-mile tunnel was dug through

Gawley Mountain, adjacent to the New River Gorge to

provide hydroelectric power.

� 2,500 workers dug the tunnel with no engineering

controls and no respiratory protection.

� 764 developed acute silicosis.

� 1,500 developed chronic silicosis.

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What is crystalline silica?• Crystalline silica is the compound silicon dioxide (SiO2)

• Its most common form is the mineral quartz. Two other common forms are cristobilite and trydimite

• Crystalline silica is found naturally in soil, sand, granite and other rock types

• Crystalline silica is a significant constituent of many materials:

-concrete -bricks -decorative stone

-wallboard -blocks -quartz/granite counter tops

Health hazards of crystalline silica exposure.• Silicosis, a disabling, non-reversible and sometimes fatal lung disease;

• Acute silicosis (short duration, high dose exposure)

• Chronic silicosis (long duration, low dose exposure)

• Accelerated silicosis (short duration, extremely high exposure)

• Lung cancer.

• Emphysema

• Other non-malignant respiratory diseases, such as chronic bronchitis and chronic obstructive pulmonary diseases (COPD).

• Kidney disease, including nephritis and end-stage renal disease.

• Suspected to be associated with some auto-immune disorders and cardiovascular disease.

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What is the new exposure standard?

• Previous OSHA permissible exposure limit (PEL) was 250 micrograms per cubic meter (250 µg/m3)

• OSHA lowered the PEL to 50 µg/m3

• OSHA also established an Action Level of 25 µg/m3

• These exposure limits are based on full-shift (8-hour) time-weighted average (TWA) exposures

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Silica standard requirements.

• Employers to limit worker exposures to respirable crystalline silica

and to take other steps to protect workers.

• Provides flexible alternatives to reduce exposures (especially useful for small employers).

• Employers can either use a control method presented in Table 1 of the construction standard, or

• They can measure workers’ exposure to silica and independently decide which dust controls work best to reduce exposures to PEL in their workplaces.(Required in General Industry Standard)

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Construction employers covered by the standard are required to:

• Establish and implement written exposure control plan

• Designate a competent person

• Restrict housekeeping practices

• Offer medical exams—every three years for workers who are required to wear a respirator for 30 or more days per year, and establish a respiratory protection program (29 CFR 1910.134)

• Train competent persons and affected workers

• Keep records of workers’ silica exposure and medical exams.

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Exposure Control Plan

Employer must develop a written Exposure Control Plan with at least the following elements:

• Tasks that involve exposure to respirable crystalline silica.

• Engineering controls, work practices, and respiratory protection used to limit employee exposures for each task.

• Housekeeping measures to limit employee exposures

• Procedures to restrict access to work areas where exposure to silica could occur (including areas where other contractors generate silica dust)

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Competent Person

• An employee who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them.

• The competent person is responsible for implementing the exposure control plan for crystalline silica at the jobsite

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Duties of competent person

• Conduct frequent and regular inspections

• Recognize situations where silica exposures could potentially occur

• Evaluate the potential for exposure including routes of exposure

• Identify initial controls that should be implemented

• Have working knowledge of HAZCOM and be able to read SDS

• Coordinate activities onsite with other trades to reduce exposures to and from other trades

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Housekeeping Measures

• No dry sweeping, sweeping compound is allowed

• No dry brushing

• Do not use compressed air to clean surfaces or clothing

Use wet methods to clean or

use a HEP vacuum cleaner

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Training Requirements

• Hazard communication (HAZCOM) –crystalline silica explained.

• Health hazards associated with exposure

• Specific tasks in the workplace that could result in exposure

• How the employer can control exposures.

• Respiratory protection.

• Who are the Competent Persons.

• Medical surveillance requirements.

• Provide a copy of the silica standard.

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Respirator Program

• Respirators may be required for some tasks listed in Table 1 (discussed later) or if sampling determines that employee exposures are above the PEL (50 µg/m3)

• If respirators are required, then a written respirator program consistent with 29 CFR 1910.134 must be implemented.

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Elements of Respirator Program

• Documents the Hazard Evaluation

• Procedure for respirator selection, use and maintenance.

• Results of sampling to document employee exposures to atmospheric contaminants in the workplace

• Medical evaluations (every 3 years per 1926.1153)

• Annual fit testing

• Annual respirator trainingCompetent Person is assigned as the

Administrator of the Respirator Program

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Medical Surveillance

• Examination by physician or licensed health care professional (PLHCP) for a baseline and repeated every 3 years thereafter

• Work history of respiratory exposure

• Baseline Medical Examination w/emphasis on silica exposure

• Testing for tuberculosis

• Chest x-ray

• Pulmonary function test

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Respiratory Protection

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Assigned Protection Factor (APF)•The minimum level of protection

(assigned) for a given type of respirator

•An APF of 10 means that the air inside

the respirator contains (at most) one-tenth

the concentration of contaminants outside

the respirator.

•A respirator with APF of 10 is valid to use in

an atmosphere of up to 10 times the PEL for

the contaminant of concern – for silica this is

500 µg/m3 (0.5 mg/m3)

OSHA did not specify a specific

efficiency for respirator filters.

Filters rated at N-95 or greater

are acceptable.

Reusable half-face respirator

with P-100 (HEPA) cartridge.

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Other APF-10 acceptable respirators

•Disposable (single use) filtering face-piece respirators

•Must be NIOSH-approved devices

N-100 filtering face-piece respirator N-95 filtering face-piece respirator

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High Efficiency required for dust control

HEP-filtered vacuum cleaner

connected to saw used to cut

cement board

Dust collection vacuum systems used

on equipment that generates silica dust

must have a 99% or greater high

efficiency filter on the exhaust.

Not HEPA but HEP (high efficiency)

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Exposure Assessment

The exposure assessment can be accomplished in one of three ways:

• Use Table 1 controls to reduce worker exposures;

• Use the Performance Option; or

• Use Scheduled Monitoring.

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What is Table 1?

• Table 1 lists 18 common construction tasks with dust control methods

• The dust control measures in the table include methods known to be effective.

• In some operations, respirators may also be needed.

• Having engineering controls onsite is not compliance unless the controls are used and maintained per manufacturer’s recommendations.

Employers who follow Table 1 correctly are not required to document workers’ exposure

to silica.

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(i) Stationary Masonry Saws

• Use saw equipped with integrated water

delivery system that continuously feeds water

to the blade

• Operate and maintain tool in accordance with

manufacturer's instructions to minimize dust

emissions

• No respirator necessary

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(ii) Handheld Power Saw (any blade diameter)

• Use saw equipped with integrated water

delivery system that continuously feeds

water to the blade

• Operate and maintain tool in accordance

with manufacturer's instructions to

minimize dust emissions

• Respirator (APF 10) required if used > 4 hrs

outdoors; in enclosed areas or indoors.

• Respirator not required if used < 4 hrs

outdoors

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(iii) Handheld power saws for cutting fiber-cement board (blade diameter of 8 in or less)

• Task must be performed outdoors

• Use saw equipped with commercially

available dust collection system with flow

rate recommended by tool manufacturer

and 99% efficient filter

• Operate and maintain tool in accordance

with manufacturer's instructions to

minimize dust emissions

• No respirator needed

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(iv) Walk-behind saws

• Use saw equipped with integrated

water delivery system that

continuously feeds water to the

blade

• Operate and maintain tool in

accordance with manufacturer's

instructions to minimize dust

emissions

• Respirator (APF 10) necessary if used

indoors38

(v) Drivable saws

• Use saw equipped with integrated

water delivery system that

continuously feeds water to the

blade

• Operate and maintain tool in

accordance with manufacturer's

instructions to minimize dust

emissions

• No respirator needed39

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(vi) Rig-mounted core saws or drills

• Use tool equipped with water delivery system to cutting surface

• Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions


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(vii) Handheld and stand-mounted drills

• Use drill equipped with shroud or cowling

and dust collection system with air flow recommended by tool

manufacturer; 99% efficient filter; and filter-cleaning mechanism

• Operate and maintain tool in accordance with manufacturer's

instructions to minimize dust emissions

• Use HEPA-filtered vacuum when cleaning holes


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(viii) Dowel drilling rigs for concrete

• For outdoor tasks only

• Use shroud around drill bit with

a dust collection system with

99% efficient filter.

• Use HEPA-filtered vacuum when

cleaning holes.

• Use respirator (APF 10)

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(ix) Vehicle-mounted drilling rigs for rock & concrete • Use dust collection system with close

capture hood or shroud around drill bit with

a low-flow water spray to suppress dust at

the discharge point from the dust collector

Or

• Operate from enclosed cab and use water

for dust suppression on drill bit

• No respirator required43

(x) Jackhammers & handheld powered chipping tools

• Use tool with water delivery

system that supplies a continuous

stream or spray at point of impact

• Operate/maintain to

manufacturer’s recommendations

to reduce emissions

• If used outdoors > 4 hrs or indoors,

respirator (APF 10) necessary

• No respirator if used outdoors < 4

hrs44

(xi) Handheld grinders for mortar removal (tuckpointing)

• Use grinder with commercially available shroud dust

collection system with: flow rate of 25 CFM per inch of

wheel diameter; 99% efficient filter, and self-cleaning

mechanism or cyclonic separator

• Operate/maintain to manufacturer’s recommendations

to reduce emissions

• Respirator with APF 10 required if used < 4 hrs

• Respirator with APF 25 required if used > 4 hrs

This unit has no dust collection system

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Handheld grinders for other uses

• Use integrated continuous water delivery system

• Follow manufacturer's recommendations

• Respirator not required for outdoor use

Or

• Use commercially available dust collection system

with: 25 CFM or greater of air flow per inch of wheel

diameter; 99% efficient filter; and cyclonic separator

or filter cleaning mechanism.

• Respirator (APF 10) required if used > 4 hrs indoors or

in enclosed areas.

• No respirator for outdoor use or < 4 hrs indoors 46

(xiii) Walk-behind milling machines & floor grinders

• Use integrated continuous water delivery system.

• Operate/maintain per manufacturer to minimize dust emissions.

Or

• Use dust collection system recommended by manufacturer with: manufacturer recommended air flow rate; 99% efficient filter; and filter-cleaning mechanism.


• Use HEPA vacuum to clean loose debris between passes.

• Respirator not required.

(xiv) Small drivable milling machines

• Use a machine equipped with supplemental water sprays to suppress dust.

• Water must be combined with a surfactant



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(xv) Large Drivable milling machines

For cuts of any depth on asphalt only:

• Machine equipped with exhaust ventilation on drum enclosure


OR:

• Use and supplemental water sprays designed to suppress dust



(xvi) Crushing machines

• Use equipment with water spray or mist for dust suppression at crusher and other points where dust is generated


• Use a cab or booth that provides fresh, ventilated, climate-controlled air or remote control station

• No respirator required

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(xvii) Heavy equipment used to fracture concrete

• Operate equipment from enclosed cab

• Protect employees outside of the cab (if present) by applying water and/or dust suppressants to minimize dust emissions

• No respirator required

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Alternative exposure control assessments

Employers who cannot implement control methods in Table 1 or havetasks that are not listed in the table have two options to assess worker exposures:

1. Performance Option

A. Determine 8-Hr. time weighted average (TWA) exposures to crystalline silica to all employee suspected to be exposed above the action level of 25 µg/m3 by combination of air monitoring and objective data.

B. Objective data can be data from studies conducted by others

Or Use:

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Alternative exposure control assessments2. Scheduled MonitoringCollect air samples for all personnel or job categories with potential exposures

A. If initial monitoring results less than Action Level (AL) then no further monitoring required.

B. If most recent monitoring results greater than AL but less than PEL, repeat monitoring within 6 months.

C. If most recent monitoring results are greater than PEL, repeat monitoring within 3 months

D. If monitoring (other than initial) results are less than AL, then repeat monitoring within 6 months until two successive results taken at least seven

days apart indicate exposures below AL, then suspend monitoring.

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Air Sampling for Crystalline Silica

• Air samples are collected from workers with a personal air sampling pump in a sampling train with a cyclone collected on a filter.

• The pump must be calibrated for accurate flow rate

• The sample must be collected in the breathing zone

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Cyclones

Cyclones come in different types, each requiring a

unique flow rate to capture respirable sized particles

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Parallel Particle Impactors (PPI’s)

�Disposable, one-time use PPI filter (PVC)

can be preloaded by the lab

�Check flow rate on PPI sampler as they vary

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Emergency Action PlansEmergency Action PlansEmergency Action PlansEmergency Action Plans

• Must be developed for your shop

• Must be developed for every remote project

• Considerations:

• Nearest hospital and urgent care

• Owner/general contractor person

• Security

• Key management staff

• Site safety rules & permits

• Safety Data Sheets

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Hazard Communication (HazCom)Hazard Communication (HazCom)Hazard Communication (HazCom)Hazard Communication (HazCom)

• Material Safety Data Sheets (MSDS)

• Safety Data Sheets

• Hazard Communication programs and related training should have been updated.

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Questions?

Presenter Contact Information

• Greg Santo

• Occupational Safety & Environmental Assoc., Inc.

• Charlotte, NC

• [email protected]

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Thank you for participating!