The U.S. Mine Safety & Health Administration (MSHA) considers respirable dust and silica to be one of the most serious occupational hazards in the mining industry, including – metal, nonmetal, stone, sand and gravel, and coal mining operations. MSHA is now starting to look for dust testing, which they have typically not done in the past for surface mines. The requirement to sample is not new, but enforcement for both surface and coal mining has increased.
What is silica?
Crystalline silica (silica) is a mineral found in sand, concrete, stone, and mortar materials. Silica becomes hazardous when reduced to dust and released into the air where it can be inhaled, called respirable silica. This commonly occurs in operations involving cutting, sawing, drilling, and crushing materials that contain silica. Processes in which sand products are used, such as glass manufacturing, metal casting, and sandblasting, also tend to generate respirable silica.
In a CDC article from The National Institute for Occupational Safety and Health (NIOSH) in February 2016, the authors state, Silica is an inherent part of the dust present in a coal mine. Still, the silica content in the dust is highly variable both in space and over time. Because of this variability and the serious health effects related to the exposure, the Mine Safety and Health Administration (MSHA) has included in the new dust rule a stand-alone exposure limit for silica concentration, in addition to the adjustment of the allowed dust exposure limit.
Indoor, outdoor, and mining operations subject their workers to silica exposure if proper processes are not created, implemented, and monitored.
What impact can silica have on miners?
Exposure to silica in coal mines is the primary cause of the development of silicosis and lung cancer and a significant contributor to black lung. Silica is an inherent part of the dust present in a coal mine, but the silica content in the dust is highly variable both in space and over time. With industrialization and equipment modernization, exposures have increased with new processes. Miners are equipment with more than manual labor tools, and high-speed equipment can increase dust and silica production.
Here are some interesting statistics:
- From 1968 to 2016, approximately 76,000 miners died from black lung disease.
- In this same period, 3900 miners died in mining-related accidents.
- Silica and dust can occur in not-so-apparent jobs such as sweeping the floors or cleaning equipment without the use of water. Just because we don’t see silica does not mean it is not there.
Silicosis, a debilitating and potentially deadly lung disease, develops by inhaling excessive respirable crystalline silica dust concentrations. In underground coal mines, continuous miner operators have a high risk of overexposure to silica, with approximately 25% of compliance dust samples exceeding the permissible exposure limit. Continuous miners often extract high-silica-content rock from the coal seam or the surrounding strata. Large quantities of silica dust can be generated during cutting and can become entrained in the ventilating air, which can carry the dust to the breathing zones of mine workers. (cdc.gov)
What is 56-5002 mandatory testing?
The U.S. Department of Labor, MSHA states, 56/57.5002 standard:
“Dust, gas, mist, and fume surveys shall be conducted as frequently as necessary to determine the adequacy of control measures.” The purpose of the standard: reduce illness or disease due to overexposures to harmful airborne contaminants.
Exposure to respirable silica-bearing dust (silica dust) can put miners at grave risk. Silicosis, a potentially fatal lung disease associated with overexposure to silica dust, is entirely preventable if mine operators and miners act in concert to prevent exposures to hazardous levels of silica dust. As part of the Mine Safety and Health Administration’s (MSHA) national effort to eliminate silicosis in the mining industry, MSHA reminded operators of their obligation under 30 CFR 56.5002 and 57.5002 (exposure monitoring) to conduct sampling as frequently as necessary. This sampling is performed to determine the adequacy of measures implemented to control the levels of employee exposure to silica dust and other airborne contaminants.
The standard MSHA violation costs for non-compliance with section 5002 testing are estimated at $1000.00. This does not include the time and fees to comply and get the violation terminated.
MSHA compliance vs. understanding
Compliance with MSHA rules and regulations is a part of running the operations. Understanding your operation and where you stand in terms of compliance can make all the difference. You need to know what you face, and proper testing and compliance create a less fearful environment.
Compliance is planning, prevention, and protection, the three “P” components. Compliance avoids reaction and creates an understanding of the processes, people, and environment.
Good planning can steer clear of citations and fines. Understanding your processes and constructing routine surveys and samplings at least once every two years creates a history should a MSHA inspection occur. New tools and equipment should be tested regularly to monitor any changes to the work environment, good or bad. Document, document, document!
Prevention is critical, especially when introducing new or replacement equipment. Be sure that all parts necessary for proper use have been delivered and tested. There are three types of prevention measures we look at. You must turn to administrative controls if you cannot get it below the exposure levels with engineering controls.
Engineering controls. Engineering controls are the most effective and reliable method for assuring that individuals are not exposed to unhealthful levels of silica dust. These controls include ventilation, dilution, exhaust fans, and water control.
The only sure way to determine the effectiveness of these engineering controls is to conduct airborne contaminant sampling regularly.
Administrative controls. Administrative controls address rotating staff to decrease exposure by having each person exposed for shorter times. For example, placing four different people on the task on a given 8–10-hour day. This will be the only other option under MSHA if engineering controls have been exhausted. If a company can’t address it using engineering controls, it would have to use administrative controls or shut down. PPE is not an option. OSHA accepts PPE, but MSHA does not.
PPE. MSHA does not accept personal protection equipment as a control measure. OSHA allows PPE. MSHA does not.
Engineering controls are the most effective and reliable method for assuring that they are not exposed to unhealthful levels of silica dust. The only sure way to determine the effectiveness of these engineering controls is to conduct airborne contaminant sampling regularly.
PPE is allowed while working on engineering controls, especially in an urgent and immediate situation. PPE is not a long-term solution. As stated, MSHA does not accept personal protection equipment as a control measure. If engineering controls are not in place for long-term work environment safety, there may no alternative but to close.
Understanding MSHA dust monitoring requirements
Understanding silica and silica exposure increases awareness of associated health hazards and creates a safe and healthy workplace. Resources are available to help you mitigate exposure to dust and silica. Working with your management team and staff to create a safety culture and mindset will deliver successful MSHA compliance.
Catamount Consulting provides mining, construction, and general industry businesses with specialized safety services, consultation, and compliance strategies. We have the highest regard for quality and employee safety and can facilitate creating a safe work environment in your organization. Contact us to learn more or have a conversation about working together.
Click here to view the webinar and learn more about handling an OSHA inspection.