Environmental, Health and Safety Brief

Each year thousands of workers are either injured or killed by circuits that they thought were turned off and/or locked out.  OSHA estimates there are approximately 187 electrical-related fatalities a year. While electrical hazards are not the leading cause of on-the-job injuries and fatalities, they are disproportionately fatal and costly.  For every 13 electrical injuries, one worker dies. According to the Consumer Product Safety Commission, each workplace death costs the U.S. economy $5 million. 

Simply turning the power off is not enough as hazardous conditions can still exist. Now is a good time to address electrical issues at your hot mix facilities or in your shops and in the field. Most of our members have generators that they use in the field or shops and any hot mix facilities have MCCs where voltages can run as high as 480 to 600 volts. Arc flash is a real possibility in such facilities as well as in shops (electrical panels where there are breakers and voltages can be as high as 220). OSHA follows the NFPA 70E standards for arc flash. Take time to review your electrical lockout procedures and the NFPA 70E standard. The standard addresses labels on equipment, arc flash hazard analyses, required personal protective equipment (PPE), calculation of the protection boundary and training requirements. 

On March 25, 2016, the U.S. Occupational Safety and Health Administration (OSHA) published its final silica rule in the Federal Register (Citation: 81 FR 16285 Page: 16285 -16890 (606 pages)). The rule, which lowers the permissible exposure limit (PEL) for respirable crystalline silica on job sites, will take effect on June 23, 2016. A good practice would be to start training or re-training your employees on how to use dust respirators and how to reduce their exposure to silica. 

A short but good video on silicosis can be found on You Tube at: 

https://www.youtube.com/watch?v=cGXWCn8op10

The final rule, Occupational Exposure to Respirable Crystalline Silica (Docket Number OSHA-2010-0034), also is designed to protect employees from exposure to silica dust. It includes provisions for assessing and controlling exposure, respiratory protection, medical surveillance, hazard communication and recordkeepping. 

The final rule:

•Reduces the PEL to 50 micrograms of respirable crystalline silica per cubic meter of air (50 µg/m3) as an eight-hour time-weighted average in all industries covered by the rule and imposes an even lower 25 µg/m3 action level. (The new PEL is approximately half the current general industry PEL.)

•Requires employers to use engineering controls (such as water or ventilation) to limit worker exposure to silica dust, provide respirators when engineering controls cannot adequately limit exposure, limit worker access to high exposure areas, develop a written exposure control plan, and train workers on silica risks and how to limit exposure.

•Requires employers to provide medical exams to monitor highly exposed workers and give workers information regarding their lung health.

The final rule is issued as two separate standards, one for general industry and maritime (including hydraulic fracturing) and one for construction. After both standards take effect on June 23, 2016, industries have one to five years to comply with most requirements, based on the following schedule:

•Construction: June 23, 2017

•General industry (e.g. hot mix plants): June 23, 2018

-Milling Operations

-Sweeping Operations

-Dust Control Mechanisms at Plants (Hot Mix and Quarries)

-Saw Cutting Operations

-Baghouse Cleaning 

-Grinding and Crushing operations (RAP, Quarry)

Link to the final rule: https://www.federalregister.gov/articles/2016/03/25/2016-04800/occupational-exposure-to-respirable-crystalline-silica

Another reminder: Toxic Release Inventory Reporting (TRI) – Time to start collecting data for TRI reports to the TCEQ on or before July 1, 2016 for year 2015.  Refer to the March EHS Briefs issue from TXAPA.

https://www.epa.gov/toxics-release-inventory-tri-program/tri-threshold-screening-tool?_ga=1.260457997.1622065116.1432185014

As noted in past issues of the EHS Brief... the Texas Commission on Environmental Quality (TCEQ) will re-issue the Storm Water General Permit on August 14th. All current TXR05 permits will have to be renewed. More to come on this topic in the next few months.

Toxicity – What does it mean?

As we all know, many substances can be toxic if we get over exposed to that substance. A substance can be either "acutely toxic" or "exhibit chronic toxicity". Simply, "acute toxicity" means that a substance either immediately, or within a very short time period after exposure, causes some sort of negative effect, usually severe or fatal. Chronic toxicity, on the other hand, is the ability of a substance or mixture of substances to cause harmful effects over an extended period, usually upon repeated or continuous exposure, sometimes lasting for the entire life of the exposed organism. 

An example of a substance that would exhibit chronic toxicity is silica. Whereas a substance that would exhibit acute toxicity could be a gas such as hydrogen sulfide. An oxygen deficient atmosphere (such as might be found in a confined space) would also be acutely toxic. 

It’s important to know the difference, as the type of protection needed to avoid exposure maybe different. Additionally, it is important to train your employees as to the difference. This should be a part of your HazCom program.