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Guides for Managing Silica Control Programs in Construction PDF Version Mount Sinai School of Medicine
 

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Mark Goldberg, Nancy Clark, Katya Wanzer, Norman Zuckerman
Mount Sinai School of Medicine, Hunter College - Urban Public Health Program

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Respiratory Protection Program for Crystalline Silica
Sand City Construction Co., Inc.

Gotham City Railway Main Terminal Building
Historical Restoration, contract # NCS-7833
January 1, 2000 — June 30, 2001


Table of Contents

1.0 Purpose
2.0 Scope and Application
    2.1 Voluntary Use
3.0 Responsibilities
    3.1 Program Administrators
    3.2 Supervisors
    3.3 Employees
4.0 Program Elements
    4.1 Selection Procedures
    4.2 Hazard Assessment
    4.3 Medical Evaluation
    4.4 Fit Testing
    4.5 Respirator Use
    4.6 Emergency Procedures
    4.7 Cleaning, Maintenance, Change Out Schedule, Storage, Defective Respirators
    4.8 Training
5.0 Program Evaluation
6.0 Documentation and Recordkeeping

The Model Respiratory Protection Program is for demonstration purposes only. It is based on the Sample Respiratory Protection Program located in Appendix iv of the OSHA Small Entity Compliance Guide. All names and companies are fictitious.

1.0 Purpose

Sand City Construction Co., Inc. has been contracted to complete the Gotham City Railway Main Terminal Building Historical Restoration, contract # NCS-7833.

Sand City Construction has determined that during the course of this project some employees will be exposed to crystalline silica containing dust during routine operations. The purpose of this program is to ensure that Sand City Construction employees are protected from exposure to crystalline silica.

Whenever feasible engineering controls, such as substitution, wetting or the use of tools equipped with Local Exhaust Ventilation (LEV) will be used to reduce exposure. When engineering controls cannot be used, or have not successfully reduced the hazard sufficiently, respirators will be employed.

2.0 Scope and Application

This program applies to all Sand City Construction employees who are required to wear respirators during normal work operations. Work processes requiring the use of respirators are listed in Section 4.2 Table 1. Work activities covered by this program include the use of: jackhammers, drills, grinders, and any other tool and/or task emitting crystalline silica containing dust. Project management will assure that changes in work operations are evaluated for hazardous exposures and selection of proper respirator.

Employees participating in the respiratory protection program do so at no cost to themselves. Any expense associated with training, medical evaluations and respiratory protection equipment will be borne by the company.

    2.1 Voluntary Use

    Any employee who voluntarily chooses to wear one of the respirators selected when a respirator is not required will be subject to the provisions of this section.

    Sand City Construction will approve requests for voluntary respirator use on a case-by-case basis. Voluntary use of a respirator may be granted if such use will not jeopardize the health or safety of the worker. The Program Administrator will provide all employees who voluntarily choose to wear a respirator a copy of Appendix D of the of the OSHA respirator standard 1910.134 which details the requirements for voluntary use.

    Voluntary users are subject to the medical evaluation, cleaning, maintenance, inspection and storage elements of this program. Fit testing and training are not required but highly recommended. To date, no workers have requested respirators where not required.

    Employees voluntarily wearing filtering facepieces (dust masks) are not subject to the provisions of this program.
3.0 Responsibilities

    3.1 Program Administrator

      The Program Administrator is responsible for administering the respiratory protection program. The responsibilities of the Program Administrator include:
      • Identifying work areas, processes and tasks that require respiratory protection.
      • Selecting respirators.
      • Monitoring respirator use to ensure they are used correctly.
      • Arranging for and/or conducting respirator training.
      • Providing for proper storage and maintenance of respirator equipment in accordance with the provisions of this program.
      • Arranging for and/or conducting qualitative fit testing.
      • Administrating the medical surveillance program.
      • Keeping records.
      • Periodically evaluating the program.
      • Updating the program when required.
      The Respirator Program Administrator for Sand City Construction at the Gotham City Railway Main Terminal Building Historical Restoration Project is John Freeman Telephone number (917) 666-7876.

      The Program Administrator may appoint additional personnel to assist him/her in administrating the program. At this site John Franklin is responsible for respirator maintenance.

    3.2 Supervisors


      Supervisors are responsible for ensuring that the respiratory protection program is implemented in their work areas. In addition to being knowledgeable about the program, supervisors must also ensure that the program is understood and followed by the employees they supervise. Duties of the supervisor include:
      • Ensuring the availability of appropriate respirators and accessories.
      • Being aware of tasks requiring the use of respiratory protection.
      • Enforcing the proper use of respiratory protection when necessary.
      • Ensuring that respirators are properly cleaned, maintained, and stored according to the respiratory protection plan.
      • Continually monitoring work areas and operations to identify respiratory hazards.
      • Coordinating with the Program Administrator on how to address respiratory hazards or other concerns regarding the program.

    3.3 Employees

      Each employee has the responsibility to wear his or her respirator when and where required and in the manner in which they were trained. Employees must also:
      • Care for and maintain their respirators as instructed, and store them in a clean sanitary location.
      • Inform their supervisor if the respirator no longer fits well, and request a new one that fits properly.
      • Inform their supervisor or the Program Administrator of any respiratory hazards that they feel are not adequately addressed in the workplace and of any other concerns that they have regarding the program.
4.0 Program Elements
    4.1 Selection Procedures

    The Program Administrator has selected respirators for the site based on respiratory hazards that workers are potentially exposed to and in accordance with all OSHA standards.

    Workers are given a choice of 3M model 7500 or Survivair 7000 series 1/2 face air purifying respirator, each available in 3 sizes (small, medium and large). A copy of the manufacturers instructions for using each type respirator is attached to this program.

    The Program Administrator has reviewed the hazard evaluation for each operation, process, or work area where airborne contaminants may be present. All work activities that crush, cut, grind, burn or generate dust or fume were evaluated for hazardous exposures. Procedures for respirator selection included:
    • Inventory of hazardous substances used or produced at the project site.
    • Review of work activities to determine where potential exposures to hazardous substances may occur. This review was conducted by considering the scope of work, by surveying the workplace, and by talking with employees and supervisors.
    • Initial respirator selection for workers exposed to crystalline silica will be based on industrial hygiene best practices. At a minimum all exposed workers will be issued 1/2 face APR with 100 series filters until completion of initial exposure assessment for that task.
    • Upon completion of the initial exposure assessment, respirator selection will be based on the American Conference of Governmental Industrial Hygienist (ACGIH) TLV of 0.05 mg/m3 for crystalline silica.

      Exposure assessment (personal air monitoring) at this location was conducted by: Quality Industrial Hygiene Inc.
      1 Corporate Park Plaza, Suite 1000, Broklyn, NY
      Telephone number 718-889-4532/ 1-800-654-0987

      The results of the current exposure monitoring and respirator selections are listed in Table 1 in Section 4.2.

      Exposure monitoring reports are retained in the Program Manager's office.

      4.1(a) Only respirators approved by the National Institute of Occupational Safety and Health (NIOSH)have been selected for use at this site. All respirators shall be used in accordance with the terms of that certification. All filters, cartridges, and canisters are labeled with the appropriate NIOSH approval label. The label must not be removed or defaced while it is in use.

      Respirators selected for use at this site have a maximum use concentration equal to or greater than the air monitoring results for a particular work activity.


    4.2 Hazard Assessment

    The Program Administrator will revise and update the hazard assessment as needed, for example if there is a change in a work process that may potentially affect exposure levels. If an employee feels that respiratory protection is needed during a particular activity, they have been informed that they should notify their supervisor or the Program Administrator. The Program Administrator will evaluate the potential hazard and arrange for outside assistance as needed. If it is determined that respiratory protection is necessary, all other elements of this program will be in effect for those tasks and this program will be updated accordingly.
Table 1: Monitoring Results
Step 1: Activity
Step 2: Exposed Workers
Step 3: Morning Results (mg/m3 )
Step 4: Respirator Selector
Chipping concrete
Laborers
0.2 mg/m3
1/2-face APR
Grinding concrete
Laborers
0.8 mg/m3
Tight fitting PAPR
or
Atmosphere supplying respirator in continuous flow mode
Drilling
Laborers
0.1 mg/m3
1/2-face APR
    4.3 Medical Evaluation

      4.3(a) Employees who are either required to wear a respirator on this job, or who choose to wear one voluntarily, must be medically cleared for respirator use by a physician or licensed health care professional (PLHCP) before being permitted to do so on this job. Any employee refusing the medical evaluation will not be allowed to work in an area requiring respirator use.

      4.3(b)
      The Gotham City Occupational Medicine Clinic has been selected to conduct respirator medical clearance evaluations for Sand City Construction:

      Gotham City Occupational Medicine Clinic
      55 Sullivan Place, Brooklyn, NY 11225
      Telephone number: 718-987-0090

      4.3(c) Procedures for the medical evaluation are as follows:
      • The medical evaluation is conducted using the questionnaire provided in Appendix C of the OSHA Respiratory Protection Standard. The Program Administrator has to provide a copy of this questionnaire to all employees requiring medical evaluations.
      • To the extent feasible, the company provides translators and/or readers to assist employees who are unable to read the questionnaire.
      • All affected employees are given a copy of the medical questionnaire to fill out, along with a stamped envelope addressed to the Gotham City Occupational Medicine Clinic.
      • Employees are permitted to fill out the questionnaire on company time.
      • Follow-up medical exams are granted to employees as required by the standard, and/or as deemed necessary by the Gotham City Occupational Medicine Clinic.
      • All employees are granted the opportunity to speak with the physician about their medical evaluation, if they so request.

        The Program Administrator has provided the Gotham City Occupational Medicine Clinic with a copy of this program, a copy of the OSHA Respiratory Protection Standard, and a list of hazardous substances by work area. For each employee requiring a medical evaluation, the Clinic has been provided with the following information:

      • Work area or job title.
      • Proposed respirator type.
      • Length of time employee will be required to wear a respirator.
      • Expected physical work load (light, moderate, or heavy).
      • Potential temperature and humidity extremes.
      • Any additional protective clothing required.

        Any employee required for medical reasons to wear a powered air purifying respirator (PAPR) will be provided with a powered APR. To date, this has not been necessary.

        Any employee who has received clearance and begun to wear a respirator, will be provided with additional medical evaluations under the following circumstances:

      • Employee reports signs and/or symptoms related to their ability to use a respirator, such as shortness of breath, dizziness, chest pains, or wheezing.
      • The Gotham City Occupational Medicine Clinic physician or supervisor informs the Program Administrator that the employee needs to be reevaluated.
      • Information from this program, including observations made during fit testing and program evaluation, indicates a need for reevaluation.
      • A change occurs in workplace conditions that may result in an increased physiological burden on the employee.
        A list of Sand City Construction employees currently included in medical surveillance is provided in Section 6.0 Table 2.
        All examinations and questionnaires are to remain confidential between the employee andthe physician.

    4.4 Fit Testing

      All employees required to wear a respirator are fit tested:
    • Prior to initial use of a tight fitting facepiece respirator.
    • Annually.
    • When there are changes in the employee’s physical condition that could affect respiratory fit (obvious change in body weight, facial scarring, etc).
    • If the worker, supervisor, RPM, or PLHCP requests it

      New employees will be fit tested when they begin work in an area requiring respirators.

      Employees voluntarily wearing 1/2-face APRs may be fit tested upon request.

      Employees are fit tested with the make, model, and size of respirator that they actually wear. Employees are provided with several models and sizes of respirators so that they may find the best fit.

      Fit testing of positive pressure respirators will be conducted in the negative pressure mode.

      All fit tests follow the protocol in the OSHA Respiratory Protection Standard 1910.134, Appendix A. All 1/2-face APRs are qualitatively fit tested. All full-face respirators are quantitatively fit tested when used to a protection factor exceeding 10 x the ACGIH TLV of 0.05 mg/m3 for crystalline silica.

    4.5 Respirator Use


      4.5(a)Employees are trained to use their respirators whenever performing tasks listed in Table 1 or any other tasks specified by the Program Administrator. All use is in accordance with this program and with the training received by workers. A respirator shall not be used in a manner for which it is not certified by NIOSH or by its manufacturer.

      4.5(b) All employees will conduct user seal checks each time they wear their respirator.

      4.5(c) All employees are permitted to leave the work area to go to a clean area to maintain their respirator for the following reasons:
      • To clean their respirator if the respirator is impeding their ability to work.
      • To relieve skin irritation.
      • To change filters/cartridges or to replace parts.
      • To repair respirator malfunctions.

        Employees are informed that they should notify their supervisor before leaving the work area.

      4.5(d) Employees are trained that respirators must be worn so that a good facepiece-to-face seal is maintained.
      • Employees are not permitted to wear tight-fitting respirators if they have any condition, such as facial scars, facial hair, jewelry, or missing dentures, that prevents them from achieving a good seal.
        • Employees are not permitted to wear headphones, jewelry, or other articles that may interfere with the facepiece-to-face seal.

    4.6 Emergency Procedures

    At this site there are no work areas or processes identified to date as having foreseeable work related emergencies requiring respiratory protection. Sand City Construction employees are not trained as emergency responders, and are not authorized to act in such a manner.

      4.6(a) Respirator Malfunction

      For any malfunction of an APR (e.g., such as breakthrough, leakage, or a malfunctioning valve), the respirator wearer informs his or her supervisor and then proceeds to the designated clean area to maintain the respirator. The supervisor ensures that the employee receives the needed parts to repair the respirator, or is provided with a new respirator.

    4.7 Cleaning, Maintenance, Filter Change Out Schedule and Storage


    Respirators are inspected for defects, cleaned, disinfected, and maintained on a regular basis by the individual worker or the designated respirator program assistant. At this site John Franklin is responsible for respirator maintenance.

      4.7(a) Cleaning

      A designated respirator cleaning station is located in the employee locker room. The Program Administrator ensures an adequate supply of appropriate cleaning and disinfecting material at the cleaning station. If supplies are low, employees are informed that they should contact their supervisor, who will inform the Program Administrator or respirator program assistant.

      The following procedure is to be used when cleaning and disinfecting respirators:
      • Disassemble respirator, remove any filters, canisters, or cartridges.
      • Wash the facepiece and parts in a mild detergent with warm water. Do not use organic solvents.
      • Rinse completely in clean warm water.
      • Wipe the respirator with disinfectant wipes to kill germs.
      • Air dry in a clean area.
      • Reassemble the respirator and replace any defective parts.
      • Place in a clean, dry plastic bag or other airtight container.
      • Respirators issued for the exclusive use of an employee shall be cleaned as often as necessary.
      • Atmosphere supplying respirators are to be cleaned and disinfected after each use
      Sanitary wipes for cleaning respirators in the field are available in the supply station and gang boxes in each work location.

      4.7(b) Maintenance

      Respirators are to be properly maintained at all times in order to ensure that they function properly and adequately protect the employee. Maintenance involves a thorough visual inspection for cleanliness and defects. Worn or deteriorated parts will be replaced prior to use. No components will be replaced or repairs made beyond those recommended by the manufacturer.

      The following items will be checked when inspecting respirators:
      • Facepiece: cracks, tears, or holes
      • Facemask distortion
      • Cracked or loose lenses/faceshield
      • Headstraps: breaks or tears, broken buckles
      • Residue, dirt cracks or tears in valve material
      • Filters/cartridges, the right one for the hazard, cracked or excessively dirty
      • Gaskets and housings for cracks or dents
      4.7(c) Change Out Schedules

      Employees wearing air purifying respirators with 100 series filters are informed that they should change the filter cartridges on their respirators when they are difficult to breathe through, excessively dirty or damaged.

      4.7(d) Storage

      Respirators are stored in a clean, dry area, and in accordance with the manufacturer's recommendations. Each employee cleans and inspects his/her own air-purifying respirator in accordance with this program and stores their respirator after drying in a dry plastic bag or rigid container with a tight fitting lid.

      4.7(e) Defective Respirators

      Respirators that are defective are taken out of service immediately. If, during an inspection, an employee discovers a defect in a respirator, he/she will inform their supervisor. Supervisors give all defective respirators to the Program Administrator or his/her assistant for repair or disposal.

    4.8 Training


      4.8(a) Training Topics:
      • OSHA Respiratory Protection Standard Program.
      • Sand City Construction’s Respiratory Protection Program.
      • Worker and supervisor responsibilities under the program.
      • Respiratory hazards encountered at this site and their health effects.
      • How a respirator works including limitations of selected respirator.
      • Respirator selection.
      • Respirator use including inspecting for defects.
      • Respirator donning and user seal (fit) checks.
      • Fit testing, explanation of fit test exercises.
      • Emergency use procedures, if deemed necessary.
      • Cleaning, maintenance and storage procedures.
      • When to change filters, where to get new filters and/or replacement parts.
      • Medical signs and symptoms limiting the effective use of respirators.

      Employees will be retrained annually or as needed, for example if there is a change in work process or type of respirator required.
5.0 Program Evaluation

The Program Administrator or his/her assistant conducts evaluations periodically of the workplace to ensure the effectiveness of the respirator program. The evaluations include consultations with employees and their supervisors, site inspections, air monitoring and a review of records. The Program Administrator corrects any problems identified during these evaluations.

6.0 Documentation and Recordkeeping

A written copy of this program and the OSHA standard is kept in the Program Administrator's Office and is available to all employees who wish to review it. Other records on file include: training rosters and materials, fit test results, and medical clearance certificates. These records will be updated as new employees are trained, or as existing employees receive refresher training, or as new fit tests are conducted.

The Program Administrator also maintains copies of the medical records for all employees covered under the respirator program. The completed medical questionnaire and the physician's documented findings are confidential and will remain at Gotham City Occupational Medicine Clinic. The company will retain only the physician's written recommendation regarding each employee's ability to wear a respirator. Personnel respirator records are summarized in Table 2.

Table 2: Personnel Respirator Records
Last Name
First Name
Respirator type and size
Medical
Certificate Date
Fit Test Date
Training Date
Jones Robert 3M -model 7500 1/2 face APR (M) 03/01/00 03/04/00
02/12/01
03/04/00
02/12/01
Bidofsky Paul Survivair - 7000 1/2 face APR (M) 03/01/00 03/04/00
02/12/01
03/04/00
02/12/01
Ramos Jose Survivair - 7000 1/2 face APR (M) 03/01/00 03/04/00
02/12/01
03/04/00
02/12/01
Schwartz Harvey 3M -model 7500 1/2 face APR (M) 03/01/00 03/04/00
02/12/01
03/04/00
02/12/01

Back to Silica Control Programs in Construction: Guide for Managing a Respiratory Protection Program for Crystalline Silica

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