This article discusses the Occupational Safety and Health Administration (OSHA) regulations that went into effect on June 23, 2016 with required compliance by June 30, 2017. Although many in the industry believe there will be a delay in the regulatory action due to further research that is taking place, we believe it is in your best interests as an employer and as a for-profit company to understand the history of the issue, the regulations that have been established and the impact this will have on the tilt-up and related concrete work in which you are involved. Therefore, we have taken the opportunity to interview several of TCA’s leaders to understand their approach and opinions on this matter.

THE ISSUE: HEALTH HAZARD
Crystalline silica are defined as the fine particles stemming from soil, sand, granite and other minerals that are made airborne during construction activities involving chipping, cutting, drilling and grinding, as well as more invasive operations such as abrasive blasting. The presence of these particles affects more than 2,000,000 U.S. workers annually. OSHA states on their website: www.osha.gov:

“The seriousness of the health hazards associated with silica exposure is demonstrated by the fatalities and disabling illnesses that continue to occur in sandblasters and rock drillers. Crystalline silica has been classified as a human lung carcinogen. Additionally, breathing crystalline silica dust can cause silicosis, which in severe cases can be disabling, or even fatal. The respirable silica dust enters the lungs and causes the formation of scar tissue, thus reducing the lungs’ ability to take in oxygen. There is no cure for silicosis. Since silicosis affects lung function, it makes one more susceptible to lung infections like tuberculosis. In addition, smoking causes lung damage and adds to the damage caused by breathing silica dust.”

OSHA’s warning, however, is followed by good news: silicosis is 100% preventable! Using power tools with dust attachments and/or accessories and dust extractors with the right filters, exposure to silica can be drastically reduced. This exposure reduction is made possible by technological improvements that have been made throughout the industry to equipment, monitoring and PPE. Nearly every company that manufactures drills, saws, chippers and other equipment essential to the nature of performing concrete construction and repair operations now has equipment marketed with new OSHA Silica Compliant ratings.

“Tool manufacturers have made significant strides to make our lives easier,” states Scott Bunney, vice president of KB Concrete Systems in Commerce City, Colorado. “We’re seeing a lot of vacuum systems and other dry collection methods to make it all possible. It is time that this happens; it is overdue for our employees.”

Concrete contractors have been quick to note the tone of the regulation and the source of the initial hazards that instigated the development for the new regulation, namely sandblasting and rock drilling. Yet when a regulation to control a hazard is initiated, it is normal for the impact of that regulation to be felt on a much broader spectrum. In the case of silica, that impact includes many common functions found in the tilt-up industry. Through early work being documented by such firms as TAS Commercial Concrete, Seretta Construction and KB Concrete Systems, construction data is being generated on the impact these regulations will have to the employer and the workforce, as well as the reality to the solutions proposed.

“We do a lot of drilling during tilt-up operations,” states Bunney. “Whether we are drilling holes to connect the brace shoes to the floor slab or pilot holes for attaching forms, we’re on every job creating a lot of silica dust. Sacking remains our biggest concern, though. Our guys are considered artists. They are often within fourteen inches of a surface trying to make it flat and flawless. Everything they do is dry and they need to figure out how to grind without a shroud so they can maintain a visual perspective on being flat and flawless. We know we can’t meet the standard by just blowing air through and grabbing the particles, as that won’t maintain levels for the rest of the jobsite.”

DO THE RESEARCH
Tim Manherz, Vice President of Operations for TAS Commercial Concrete Construction from Houston, Texas knows that the Silica Regulation will have an extreme impact on his company. TAS is consistently in the top 100 contractors in the country for overall business volume and has even been in the top 10. Their tilt-up business runs between 15 and 25% of their business and involves a considerable amount of grinding, drilling and even sandblasting operations.

“The moment we heard of this regulation we knew it would dramatically change the work we do,” states Manherz. “At the same time, we already had procedures in place to address silicosis concerns. Additionally, if it were to impact our business, we would need to see the results. Reading about overall workforce and the measured rates of inhalation is one thing but seeing it in action, with your operation and on your crew is another. In more than 23 years of working for this company, we’ve had zero cases of lung issues like silicosis from our crews. Our standard PPE for these operations involves respiratory protection and extraction systems for all employees grinding. We traditionally sub-contract out any abrasion operations. Drilling, however, is our most common activity for tilt-up panels, as every brace is anchored to the floor slab using a drilled hole. Therefore, we established a test for a typical jobsite using our standard PPE and the equipment we have always used.

When asked what would be his first piece of advice for tilt-up contractors, or really any contractor in the concrete industry, Manherz stated, “You’ve got to do the research. We hired an industrial hygienist to take measurements of airborne particles during these operations. The samples were sent to a lab for examination. Next, we repeated the same operations in a different area but with the same conditions. Our findings so far indicate that our previous efforts had been effective. However, with OSHA’s new drastically reduced permissible levels of exposure, we must update our existing program. Our biggest challenge is that it is impossible to test for all the different condition variables on every jobsite. However, we believe that we have gathered sufficient representative sampling to implement effective procedures. With updates to our procedures and the replacement of some of our existing equipment with new product lines rated for OSHA Silica compliance, we will keep our crews protected while conducting these tasks.” He is quick to clarify that doing the research does not mean you need to physically challenge the levels and conduct testing; but you do need to know what it is that OSHA is regulating, how it impacts your company and what changes will need to be made. This may involve further research and it may not.

THE REGULATION: PROTECTING YOUR COMPANY & YOUR EMPLOYEES
OSHA has an established Permissible Exposure Limit, or PEL, which is the maximum amount of crystalline silica to which workers may be exposed during an eight-hour work shift (29 CFR 1926.55, 1910.1000). OSHA also requires Hazard 2002. This is one in a series of informational fact sheets highlighting OSHA programs, policies, and standards; it does not impose any new compliance requirements.

The key provisions to ensure jobsite compliance are as follows:

• Reduce the permissible limit (PEL) to 50 μg/m3 (micrograms of silica per cubic meter of air), averaged over an eight-hour day. (Note to reader: the former PEL was 100 μg/m3.)
• Require employers to:
  – Use engineering controls (such as water or ventilation) to limit worker exposure to respirable silica dust to the PEL
  – Provide respirators when engineering controls cannot adequately limit exposure
  – Limit worker access to high exposure areas
  – Develop a written exposure control plan
  – Train workers on silica risks and how to limit exposures
  – Provide medical exams to monitor highly exposed workers and give them information about their lung health
• Establish and implement a written exposure control plan to identify tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur. Also, employers need to designate a competent person to implement the written exposure control plan.
• Provides flexibility to help employers
  — especially small businesses
  — protect workers from silica exposure.

Bunney comments that this regulation is fairly well written when it comes to the complexity of OSHA topics. “We’ve had little trouble determining what we need to do, now it is just fitting it in to how we do it. We can’t work wet in this setting, we have to find a way to keep these operations dry.”

IMPACTING YOUR OPERATION
So, what does this mean to your business? Current TCA president, Andrew McPherson of Seretta Construction and his safety director, Anthony Cardamone, had this to offer:

“As soon as we heard this ruling and pending regulation was coming, we started to consider the variables in our own business and the impact that this might have. We began with a lot of the typical efforts such as air analysis on early-entry sawing and drilling operations. What we found is that our current systems were safe, even for the tighter regulations. However, we found the real problem to be the sweeping up of the floor slabs after saw cutting. This is where we began exceeding the new regulatory limits. What this means for our operation is that we’re going to have to go to vacuums behind our early entry saw cutting equipment. The cost for these are typically $10,000 (US) or more. So, on just a 30,000 sq. ft. slab pour we would need a minimum of two saws. Adding vacuums to just the one placement operation would be an additional $20,000 in vacuums, and we’re running multiple slab pours each day.”

However, the duty to provide safety cannot be ignored or determined infeasible due to cost. “The bigger problem we see, beyond the acquisition and maintenance costs for the additional vacuums,” states McPherson, “is the logistics. We deliver place and finish equipment on drop deck trailers. By the time you get rider trowels, screeds, early-entry saws, pressure washers and everything else you need for a slab placement crew on these trucks, they are jam packed. There is no room for these big backpacks for the saws. We will now have to add another vehicle and driver specifically for the vacuum equipment or rearrange our shipping. This is where the cost really escalates, even though we know it doesn’t alleviate us from the responsibility. You’ve got the additional $20k per pour per day for our average crew and now you have an additional truck and driver to get the increased equipment to and from the site. We’ve always used respirators for our patch and rub guys, the full-fit test respirators, rather than just your basic dust masks as they don’t do anything for silica.”

Cardamone agrees and adds that their operations will also be changing. “Grinding is one operation that we have always been able to fit out our crews for protection but stay ahead or above the airborne dust and let it just blow or fall out of exposure. Now, our grinding equipment will have to be dustless, making the sawing and grinding equipment much more awkward or cumbersome to manipulate in the aerial lifts we provide. The awkwardness of the equipment makes the quality of the operation much more of a challenge. You can’t see what you are doing as well and you can’t maneuver the grinders with as much fine control. We anticipate this to be an issue which will affect the time spent perfecting the surfaces for the architectural nature these walls carry in reputation.”

McPherson knows that it doesn’t end there in its impact. “We send these guys up in aerial lifts every day to complete the finish on these panels to specification. We own and maintain a sizeable fleet of lifts that now must be assessed for both their weight and space capacity. The grinders will now weigh four to five times more than our normal pieces of equipment plus the weight of all the material being used. This additional weight builds quickly and will force us to look at our maximum lift capacity, which may impact the pieces of equipment we maintain while the work area in the basket is taken up by the collection bags, making movement a real challenge.”

HIDDEN SURPRISES
Transition is the biggest key to any change in regulation, both the planned and unplanned, or the seen and unforeseen. Bunney agrees and adds that he also sees a hidden risk now that they and their specialists have been attacking OSHA’s new regulation and operations. “We believe stripping the forms is also now an issue. The drilling operation for attaching forms to the slab is often done through the wood. This traps the silica at the surface between the slab and the wood bracket or form board. When we go to strip the forms and then sweep up the slab for cleanliness, there is all that silica that was ground up from the holes. We’re going to have to use a wet clean operation or a ‘Dust Barrier’ system to prevent this trapped silica we were ignoring from being presented in opposition to the new limits. So, we are now headed into a series of tests ourselves to measure the limits of airborne silica during stripping and cleaning as well as the modified sacking processes we are coming up with.”

OSHA also provides a fact sheet on crystalline silica that can be obtained at: https://www.osha.gov/OshDoc/data_General_Facts/crystalline-factsheet.pdf. In this document, employers are given a list of considerations for protecting employees against exposure. They include:

• Replace crystalline silica materials with safer substitutes whenever possible.
• Provide engineering or administrative controls where feasible, such as local exhaust ventilation, and blasting cabinets.
• Where necessary to reduce exposures below the PEL, use protective equipment or other protective measures.
• Use all available work practices to control dust exposures, such as water sprays.
• Wear only a N95 NIOSH certified respirator, if respirator protection is required. Do not alter the respirator. Do not wear a tight-fitting respirator with a beard or mustache that prevents a good seal between the respirator and the face.
• Wear only a Type CE abrasive-blast supplied-air respirator for abrasive blasting.
• Wear disposable or washable work clothes and shower if facilities are available. Vacuum the dust from your clothes or change into clean clothing before leaving the worksite.
• Participate in training, exposure monitoring, and health screenings and surveillance programs to monitor any adverse health effects caused by crystalline silica exposures.
• Be aware of the operations and tasks creating crystalline silica exposures in your workplace environment and know how to protect yourself.
• Be aware of the health hazards related to exposures to crystalline silica. Smoking adds to the lung damage caused by silica exposures.
• Do not eat, drink, smoke, or apply cosmetics in areas where crystalline silica dust is present. Wash your hands and face outside of dusty areas before performing any of these activities.
• Remember: If it’s silica, it’s not just dust.

OSHA 1926.1153 TABLE 1 SILICA REGULATIONS FOR POWER TOOLS

https://www.boschtools.com/us/en/more/news-and-extras/knowledge-center/dust-control/osha-silica-standard

Want to know more? Contact TCA’s Manager for Regulatory and Technical Affairs, Jim Baty at 319-895-6911 or by email at jbaty@tilt-up.org. The mission of the Tilt-Up Concrete Association is to expand and improve the use of tilt-up as the preferred building system by providing education and resources that enhance quality and performance. More information can be found at the association website, www.tilt-up.org.

For a comprehensive list of compliance requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations. This information will be made available to sensory-impaired individuals upon request. The voice phone is (202) 693–1999. See also OSHA’s website at www.osha.gov

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OSHA to Delay Enforcing Crystalline Silica
Standard in the Construction Industry

WASHINGTON – On April 6, 2017 the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced a delay in enforcement of the crystalline silica standard that applies to the construction industry, to conduct additional outreach and provide educational materials and guidance for employers.
The agency has determined that additional guidance is necessary due to the unique nature of the requirements in the construction standard. Originally scheduled to begin June 23, 2017, enforcement will now begin Sept. 23, 2017.
OSHA expects employers in the construction industry to continue to take steps either to come into compliance with the new permissible exposure limit, or to implement specific dust controls for certain operations as provided in Table 1 of the standard. Construction employers should also continue to prepare to implement the standard’s other requirements, including exposure assessment, medical surveillance and employee training.
Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit www.osha.gov.