by Linda Rawson | Feb 8, 2019 | Industrial Hygiene
As a result of the new and revised 2017 OSHA regulation for respirable crystalline silica, OSHA has been trying to clear any questions concerning compliance.
Master Sgt. Donnie Bogan saws cutting lines in concrete, licensed under the terms of the United States Government Work.
The controversial crystalline silica guideline from OSHA took effect on June 23, 2016. Industrial sectors had between one and five years to fully comply with the new standard. The building and construction sector’s conformity day was Oct. 23, 2017.
The regulation lowered the Permissible Exposure Limit (PEL) required dust controls as well as safer work techniques and called for employers to offer respirators to employees when other safe job techniques were unable to restrict respirable crystalline dust exposure.
Employers need to evaluate the exposure of each worker that is or may reasonably be anticipated to be subjected to respirable crystalline silica at or above the authorized limit making use of either an efficiency alternative or a set up monitoring option.
According to Bloomberg Environmental, a Virginia construction company was issued five citations for crystalline silica violations totaling $304,130 USD. The fines could be the largest fines ever under the new silica standard.
Recently, OSHA released a brand-new silica standard Frequently Asked Question (FAQ) to offer some clarification. The new FAQs were created after talking to the general industry and industry stakeholders.
The goal of the new silica standard FAQ is to give further guidance to both companies and employees on the silica standard’s requirements. The areas highlighted are methods of compliance, exposure assessments, regulated areas, and communication of respirable silica hazards to employees.
Here are three frequently asked questions published in the OSHA General Industry FAQ.
Q: Can employers use data from real-time monitoring and exposure mapping to assess employee exposures under the performance option?
A: Yes. Data generated by real-time monitoring of respirable dust levels (conducted using direct-reading instruments) can be combined with exposure mapping to assess employee exposures under the performance option, provided that the data can be correlated with individual employee exposures and otherwise meet the requirements for objective data. OSHA notes that in order to estimate the level of respirable crystalline silica in the air using real-time monitoring data, employers must also know the percentage of silica in the dust (e.g., from the analysis of a bulk sample or information from a safety data sheet). If an employer does not know the percentage of silica in the dust, it can assume 100% of the respirable dust is silica for purposes of determining worst case exposures from real-time monitoring data under the standard.
Q: If an employer characterizes employee exposures under the performance option using objective data from real-time monitoring and exposure mapping, how often does the employer need to repeat the monitoring and mapping process?
A: The goal of the performance option is to give employers flexibility to accurately characterize employee exposures using whatever combination of air monitoring data or objective data is most appropriate for their circumstances. Therefore, OSHA has not specified exactly how often data should be collected for these purposes. Employers may rely on existing data as long as the data continues to be sufficient to accurately characterize employee exposures. OSHA notes, however, that accurately characterizing employee exposures is an ongoing duty, and employers must reassess exposures whenever a change in the production, process, control equipment, personnel, or work practices may reasonably be expected to result in new or additional exposures at or above the AL, or when the employer has any reason to believe that new or additional exposures at or above the AL have occurred. See 29 C.F.R. § 1910.1053(d)(4)
Q: If personal sampling results show that one employee, who works in a small, non-enclosed area of a large building, is exposed above the PEL, but another employee, who is only a short distance away, is exposed below the PEL, how does the employer decide how far to extend the regulated area?
A: Because there is an exposure above the PEL, the facility must determine which task or operation is creating the overexposure and create a regulated area around that task or operation. In the example provided, the regulated area may include only the first employee’s work station. If the second employee is not exposed above the PEL and is not reasonably expected to be exposed above the PEL, the regulated area does not have to cover that employee’s work area. An employer could choose to use area sampling, real-time monitoring, or exposure mapping to assist in identifying the boundaries of a regulated area.
For a full copy of the General Industry FAQ please see this link -> https://www.osha.gov/dsg/topics/silicacrystalline/generalindustry_info_silica.html
by Linda Rawson | Feb 4, 2019 | Industrial Hygiene
Black Lung is still around.
This last week the National Public Radio (NPR) collaborated with PBS investigative series Frontline on an article titled: “An Epidemic Is Killing Thousands of Coal Miners. Regulators Could Have Stopped It.” The multiyear investigation by NPR and Frontline found that these coal miners are part of an unfortunate, tragic, discovered outbreak of black lung disease, known as progressive massive fibrosis.
Ex Coal Miner with Black Lung, NARA/EPA via pingnews
Beyond mountain roads, deep in Appalachia, the article describes the familiar story of past coal miners, young and old, coughing uncontrollably and packing an oxygen tank on their back. Children are wondering what is wrong with their rapidly aging parents and grandparents. The concerned children watch them hack, cough, and spit up dead, black lung tissue onto the ground. The lung tissue dies so fast that the respiratory therapists describe it as “peeling away.”
NIOSH, unfortunately, is seeing some trends in the extensive spread of coal workers’ pneumoconiosis (CWP, commonly called Black Lung).
The investigation suggests that for decades, the government regulators had evidence of excessive and toxic mine dust exposures but did nothing about it.
Thousands of cases of Black Lung are being reported to the National Institute for Occupational Safety and Health (NIOSH).
Yes. It is 2019. Black Lung should not be an occupational health problem in this time period.
According to Dr. Robert Cohen, a pulmonologist at the University of Illinois in Chicago, “the advanced stage of black lung leaves lungs crusty and useless.” He has spent decades studying black lung and other lung diseases.
They’re essentially suffocating while alive.
The airborne poison that triggers serious condition isn’t coal mine dust alone. It consists of respirable crystalline silica, dangerous dust that is generated when miners reduced sandstone as they mine coal. Coal seams in central Appalachia are ingrained in sandstone which contains quartz; therefore when mining techniques reduce quartz, it produces respirable crystalline silica. The silica is inhaled deep into the lungs where it is lodged permanently.
Miners Waiting for Their Examination at the Appalachian Regional Hospital in Beckley, West Virginia, U.S. National Archives and Records Administration
This excessive exposure to respirable crystalline silica almost certainly happened more often than the data suggests. Respirable crystalline silica sampling takes place during regular inspections, which are scheduled twice a year in surface mines and four times a year in underground mines.
The sampling should be occurring over 8 hours according to the OSHA Respirable Crystalline Silica Standard.
Related article: OSHA Publishes Silica Standard FAQ
Most of the sick and dying miners that were interviewed used dust masks and said they often didn’t work. With real-time monitoring of respirable crystalline silica masks only need to be worn during high levels of silica. By analyzing minute particles, a dangerous level can be determined, and miners do not have to wear a mask all the time.
Have your employees wear a real-time DustCount 8899 – Respirable Dust Monitor – Click Here to Learn More
This investigation is a sad case of human illness that might have been prevented with adequate safety measure and monitoring.
References:
An Epidemic Is Killing Thousands Of Coal Miners … (n.d.). Retrieved from http://www.capradio.org/news/npr/story?storyid=675253856
by Linda Rawson | Feb 3, 2019 | General, Industrial Hygiene
For National Women Physician’s day, we choose to commemorate the success of Dr. Alice Hamilton. As consumers, we support a marketplace that allows us to acquire low-cost products quickly. Sometimes production of those consumer products comes at a human health cost. Alice Hamilton was a pioneer in the field of occupational health and safety. There is no individual, male or female, that was much more instrumental in making the worker and employer aware of the occupational health and wellness dangers and prospective dangers of the industrial workplace than Alice Hamilton.
Alice Hamilton in 1893, the year she graduated from medical school. PDH at Smithsonian Institution and en.wikipedia [Public domain], from Wikimedia Commons.
The Early Years
Alice Hamilton was born in Fort Wayne, Indiana in 1869 into a family with privilege. Privilege did not make Alice Hamilton selfish, and she aspired to provide some type of useful service to the world. She wasn’t always the best student especially in reading and science but she studied hard and made up the deficit.
She earned her medical degree from the University of Michigan in 1893. In the 1890s, according to the census, there were about 4,500 female doctors in the United States. It was extremely unusual for a woman to be a doctor but Alice persevered.
Pioneering Industrial Hygiene
In 1897, Dr. Hamilton took a setting teaching pathology at Northwestern University’s Female’s Medical Institution in Chicago. In the “Windy City,” she came to be associated with Hull House, the world-famous settlement residence founded by Jane Addams in 1889. A settlement house brought the poor and the rich of society together in physical and social proximity. As higher education opened to women, young female graduates brought their energy to the settlement movement. She lived there for 22 years.
Deeply devoted to her work at Hull House, Dr. Hamilton additionally took on investigations of typhoid high temperature, tuberculosis and drug abuse in Chicago. In 1908, she was assigned to the Illinois Compensation of Occupational Diseases as well as, in 1911, to the U.S. Division of Labor. It was then that she began a vigorous search of what she called “exploring the dangerous trades.”
In 1919, Hamilton became the very first woman professor, in ANY field, at Harvard Medical College, albeit on a part-time basis. New York times announced her appointment with the headline: “A Woman on Harvard Faculty—The Last Citadel Has Fallen—The Sex Has Come into Its Own.” Her rebuttal to this headline was:
“Yes, I am the first woman on the Harvard faculty—but not the first one who should have been appointed!”
Hamilton faced gender discrimination. She was continually excluded from social activities, could not enter the Harvard Union, could not attend the Faculty Club, and did not receive football tickets. The worst thing was Hamilton was not allowed to march in the university’s commencement ceremonies with her male faculty counterparts.
In 1925, Hamilton testified at a Public Health Service conference on the use of lead in gasoline. She warned of the danger it posed to people and the environment and especially children. Nevertheless, at the prompting of big business, leaded gasoline was allowed. By 1988, the Environmental Protection Agency (EPA) estimated that 68 million children suffered toxic exposure from lead in leaded fuels over the previous 60 years.
Dr. Alice Hamilton, pioneer of occupational medicine in the United States. PDH at Smithsonian Institution and en.wikipedia [Public domain], from Wikimedia Commons.
Hamilton was the pioneer of occupational epidemiology and industrial hygiene. She created the specialized field of industrial medicine in the United States. Her findings from her research were well written and scientifically persuasive. Regarding her research, she influenced massive health reforms that changed laws and improved the health of workers.
Hamilton’s best-known research included studies on:
- Workers getting sick through contact with the explosive trinitrotoluene (TNT).
- Steelworkers suffering carbon monoxide poisoning.
- Hatters suffering mercury poisoning which caused mental illness and spawned the phrase “mad as a hatter.”
- Jackhammer operators suffering debilitating hand conditions.
- Limestone cutters suffering spastic anemia also is known as “dead fingers.”
- Tombstone carvers suffering a high incidence of pulmonary tuberculosis.
- Matchstick factory workers suffering phosphorus necrosis of the jaw commonly called “phossy jaw.”
She uncovered the dangers in unsafe factories and workplaces with unconventional methods and fearlessly acting to become an advocate for a safe workplace in the industrial revolution. Up until her death in 1970, Hamilton continued to campaign for the health of all Americans, leaving an enduring, positive and long lasting mark on the public’s wellness.
We should all strive to emulate her talents in listening attentively to those that think they do not have a voice.
References
https://cfmedicine.nlm.nih.gov/physicians/biography_137.html
https://en.wikipedia.org/wiki/Alice_Hamilton
by Machelle | Jan 22, 2018 | General, Industrial Hygiene
The need for a Respirable Dust Monitor
It wasn’t until August 1st, 2014; a groundbreaking respirable dust rule went into effect. The rule which was introduced by the United States Mine Safety and Health Administration (MSHA) further adds to the increased list of various protections designed for coal miners. While effectively closing some loopholes that expose workers to unhealthy coal mine dust at the workplace.
The rules have been part of a government joined efforts aimed at monitoring and reducing the risk of respirable dust. This dust is harmful to human health, particularly for mine workers.
The historical path to ending the risk of respirable dust
Since 2009, the battle to end or minimize the life-threatening effects of respirable dust gain momentum following the launching of the “End Black Lung–Act Now.” The campaign enables the mining industry and government watchdog agencies like the MSHA to turn from mere safety matters to critical health challenges in the mining sector. Efforts to lower silica and levels of respirable coal mine dust in the country’s coal mines were ramped up. They have remained on track in the aftermath of the “End Black Lung—Act Now!”
Effects of the respirable coal dust rule
The respirable coal dust rule that went into effect on August 1st, 2014. It was another indication of government efforts to curtail the negative effects of respirable dust on coal mine workers and the environment at large. During this period, dust samples results collected by the MSHA, containing this new rule, indicates that compliance can be achieved. Most importantly, the results show that samples from the dustiest occupations in underground coal mine facilities dropped to a record low of 0.64 milligrams per cubic meter (mg/m3) for 2016. This was far better than the 2015 average year sample record of 0.70 mg/m3.
What the new respirable dust rule entails is that miners across the nation’s coal mines are now better protected. This improvement is better than before from the destructive black lung diseases.
Certification testing introduced by the new rule of August 1st, 2014
The new respirable coal dust rule requires that every certified person must pass the applicable MSHA examination. The examination demonstrates competence in sampling procedures slated under the final mark of 70.202. Or they will undergo a competency in calibration and maintenance under a final mark of 70.203, for every three years.
Such certification and its strict application have led to a great reduction in cases of black lungs. Seeing the general effects of respirable coal dust among mine workers reduced from 2014 to 2017. For instance, data released by the MSHA for October 1, 2015, to September 30, 2016, shows there were only 24 deaths recorded in more than 13,000 mines across the nation. This is the lowest from the 34 recorded in 2013.
The MSHA is currently working on a fixed certification testing schedule that will include location and time of test schedules. The third phase of the MSHA respirable dust rule took effect from August 1st, 2016, to date.
Results show that the concentration level of respirable coal mine dust in the air has been limited from 2.0 mg/m3 to 1.5 mg/m3 at the surface and underground coal mines. Also, the concentration for respirable dust is lowered from a range of 1.0 mg/m3 to 0.5 mg/m3 regarding intake air at underground mines, and for miners suffering from pneumoconiosis.
Conclusion
The MSHA has been making a giant stride in the quest to minimize the level of respirable coal mine dust in the air, under and around mining locations in the United States. These efforts have been a work-in-progress, spanning a period of years, with success recorded on every new sample year.
Linda Rawson is the CEO, and Founder of DynaGrace Enterprises, (http://DynaGrace.com) which is a Women-Owned, 8(a) Minority, Small Business. She is also the author of The Minority and Women-Owned Small Business Guide to Government Contracts.
Resource:
Image Resource: Featured Image Source: Jean Beaufort via https://www.publicdomainpictures.net/en/view-image.php?image=224094&picture=coal-miners, https://www.youtube.com/channel/UCvPmhyCdDijBz5SpaJB-L0g via https://www.youtube.com/watch?v=agTfGHUfFNQ, https://pixabay.com/en/users/Clker-Free-Vector-Images-3736/ via https://pixabay.com/en/red-circle-backslash-no-symbol-24018/
