This program includes protections and safeguards for CSUN and auxiliary organizations employees who as part of their normal job duties work on projects involving potential exposure to airborne concentrations of silica.
I. Purpose/Scope
It is the goal of California State University, Northridge (the “University”) to maintain, as far as is reasonably possible, an environment that will not adversely affect the health, safety, and wellbeing of students, employees, visitors, and the surrounding community. To this end, the University has established a Respirable Crystalline Silica Exposure Control Plan.
- Purpose: To provide guidance to supervisors and employees on identify potential sources of employee exposure to respirable crystalline silica dust, specify appropriate engineering controls, and work practices to limit exposure, and address the use of personal protective equipment (i.e., a respirator) where exposures exceed applicable limits. The ECP also addresses other topics listed in 29 CFR 1926.1153, including employee training, a medical surveillance program, and a record retention policy.
This written plan meets the requirements of Occupational Safety and Health Administration (OSHA) 29 CFR 1926.1153: Respirable Crystalline Silica (Construction Industry) and 29 CFR 1910.1053: Respirable Crystalline Silica (General Industry).
- Scope: The Respirable Crystalline Silica Exposure Control Plan applies to all University employees who may, in the course of their employment, be exposed to respirable crystalline silica at or above the action level or perform construction-related tasks which are identified in Table 1 of this plan. Employees are required to follow the guidelines and procedures set-forth in this manual. Employees should read this manual carefully and questions regarding the contents of this manual should be brought to the attention of their immediate supervisor.
This Plan describes the hazards associated with projects involving potential exposure to airborne concentrations of silica and the issues to be addressed during these projects. These projects include, but are not limited to:
- Use of stationary masonry saws used to cut concrete, tile, concrete masonry block, or any other product containing quartz.
- Handheld power saws used to cut concrete, asphalt, concrete masonry block, or any other product containing quartz.
- Walk-behind saws used to cut concrete or asphalt.
- Saws or drills (including impact and rotary hammer drills) used to penetrate concrete, concrete masonry block, or any other structural component or product containing quartz.
- Jackhammers and handheld powered chipping tools used to demolish or modify concrete, concrete masonry block, or any other structural component or product containing quartz.
- Handheld grinders or cut-off wheels used for mortar removal or cutting/grinding of concrete, concrete masonry block, or any other structural component or product containing quartz.
- Selected demolition of cementitious products with quartz containing materials, excluding abatement, including cement boards, mudding, texturizing activities.
- Hand or power tool sanding of painted surfaces. Current latex paint products containing quartz and the painted substrate (cement boards, concrete masonry block, and concrete) containing quartz.
- All housekeeping operations associated with the activities described above.
II. Definitions
- Action Level (AL): concentration of airborne respirable crystalline silica of 25 μg/m3, calculated as an 8-hour TWA.
National Institute for Occupational Safety and Health (NIOSH):
- Competent Person: an individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them. The competent person must have the knowledge and ability necessary to fulfill the responsibilities.
- Employee Exposure: the exposure to airborne respirable crystalline silica that would occur if the employee were not using a respirator.
- High-efficiency Particulate Air (HEPA) Filter: a filter that is at least 99.97 percent efficient in removing mono-dispersed particles of 0.3 micrometers in diameter.
- Air Monitoring for exposure to respirable crystalline silica associated with the product: data reflects workplace conditions that closely resemble or with a higher exposure potential.
- Respirable Crystalline Silica: quartz, cristobalite, and/or tridymite contained in airborne particles.
- Permissible Exposure Limit (PEL): of 50 μg/ m3 as an 8-hour TWA.
- PLHCP: “physician or other licensed healthcare professional” whose legally permitted scope of practice (i.e., license, registration, or certification) will allow them to perform medical examinations.
III. Responsibilities
- Environmental Health and Safety:
- Develop, implement, review, and update the Respirable Crystalline Silica Exposure Control Plan.
- Identify airborne silica hazards, determine the need for initial and additional exposure monitoring, recommend and implement engineering and work practice controls, establish levels of PPE.
- Conduct and maintain records for exposure assessments.
- Send written plan to supervisors of affected employees when plan is updated.
- Ensure the written plan is made available to all employees by posting to EH&SS webpage.
- Work in conjunction with supervisors to identify employees or groups of employees who will need training.
- Ensure the coordination of fit tests and administer training for employee’s who utilize respiratory protective equipment.
- When applicable, coordinate the medical surveillance of silica workers.
- Ensure department end user follows manufacturers recommended filter change out schedule.
- Supervisors
- Have general knowledge of this ECP.
- Notify direct reports of changes to written plan.
- Ensure their employees are fully and properly implementing all controls contained in this ECP.
- Notify EH&S if there are any changes to work environments that may present new exposures to respirable crystalline silica.
- Monitors and inspects job task, equipment, and PPE to mitigate the exposure.
- Notify EH&S of employees who need training and ensure assigned training is completed by direct reports
- Purchase respirators, filters, cartridges, respirator cleaning supplies and engineering controls required for tools listed in Table 1.
- If administrative controls are used to limit exposure, establish and implement a job rotation schedule that includes employee identification as well as the duration and exposure levels at each job or work station where each affected employee is located.
- Employees
- Complete assigned training.
- Understand the applicable components and adhere to all the rules and requirements of the applicable Safety Data Sheets (SDS), and where they can be located.
- Utilize the issued respirator in accordance with instructions and training provided.
- Notify supervisor if there are any changes to health that may prevent respiratory protector’s effectiveness.
- Notify supervisor if they have reason to believe excess Silica exposure is occurring, or experience signs or symptoms of silica-related illness.
- Report any exposure, accident, or injury to their supervisor.
IV. Exposure Control Methods
Cal/OSHA has published a list of typical equipment and tasks involved in disturbing crystalline silica- containing materials. This plan only covers activities that take place at CSUN. For a full list of tasks, reference the regulatory standard. For each task identified in Table 1 below, the engineering controls, work control practices, and respiratory protection (collectively known as exposure control methods) specified for that task must be fully and properly implemented.
Table 1: Specified engineering exposure control methods when working with materials containing crystalline silica
| Equipment Operation / Construction Task | Engineering and Work Practice Control Methods | Required Respiratory Protection < 4 hours/shift | Required Respiratory Protection > 4 hours/shift | |
| 1 | Stationary Masonry Saws | Use saw equipped with integrated water delivery system that continuously feeds water to the blade. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. | None | None |
| 2 | Handheld power saws (any blade diameter) | Use saw equipped with integrated water delivery system that continuously feeds water to the blade. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. | Outdoors- None
Indoors- N95 (or Greater Efficiency) Filtering Facepiece or Half Mask | Outdoors & Indoors- N95 (or Greater Efficiency) Filtering Facepiece or Half Mask |
| 3 | Handheld power saws for cutting fiber cement board (with blade diameter of 8 inches or less) for tasks performed outdoors only | Use saw equipped with commercially available dust collection system. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency | None | None |
| 4 | Walk- behind saws | Use saw equipped with integrated water delivery system that continuously feeds water to the blade. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. | Outdoors - None Indoors or an enclosed area – N95 (or Greater Efficiency) Filtering Facepiece or Half Mask | Outdoors - None Indoors or in an enclosed area– N95 (or Greater Efficiency) Filtering Facepiece or Half Mask |
| 5 | Handheld and stand- mounted drills (including impact and rotary hammer drills) (including impact and rotary hammer drills) | Use drill equipped with commercially available shroud or cowling with dust collection system. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism. Use a HEPA-filtered vacuum when cleaning holes. | None | None |
| 6 | Jackhammers and handheld powered chipping tools | Use tool with water delivery system that supplies a continuous stream or spray of water at the point of impact. OR: Use tool equipped with commercially available shroud and dust collection system. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. Dust collector must provide the air flow recommended by the tool manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism | Outdoors - None Indoors or an enclosed area – N95 (or Greater Efficiency) Filtering Facepiece or Half Mask | Outdoors - N95 (or Greater Efficiency) Filtering Facepiece or Half Mask Indoors or an enclosed area – N95 (or Greater Efficiency) Filtering Facepiece or Half Mask |
| 7 | Handheld grinders for mortar removal (i.e., tuck- pointing) | Use grinder equipped with commercially available shroud and dust collection system. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic pre-separator or filter-cleaning mechanism. | N95 (or Greater Efficiency) Filtering Facepiece or Half Mask | Powered Air- Purifying Respirator (PAPR) with P100 Filters |
| 8 | Handheld grinders for uses other than mortar removal | Use grinder equipped with integrated water delivery system that continuously feeds water to the grinding surface. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. OR: Use grinder equipped with commercially available shroud and dust collection system. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. Dust collector must provide 25 cubic feet per minute (cfm) or greater of airflow perinch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic pre-separator or filter-cleaning mechanism | Outdoors - None
Indoors – None | Outdoors - None
Indoors – N95 (or Greater Efficiency) Filtering Facepiece or Half Mask |
| 9 | Walk- behind milling machines and floor grinders | Use machine equipped with integrated water delivery system that continuously feeds water to the cutting surface. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. OR: Use machine equipped with dust collection system recommended by the manufacturer. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. Dust collector must provide the air flow recommended by the manufacturer, or greater, and have a filter with 99% or greater efficiency and a filter-cleaning mechanism. When used indoors or in an enclosed area, use a HEPA filtered vacuum to remove loose dust in between passes. | None | None |
| 10 | Heavy equipment and utility vehicles for tasks such as grading and excavating but not including demolishin g, abrading, or fracturing silica- containing materials | Apply water and/or dust suppressants as necessary to minimize dust emissions. OR: When the equipment operator is the only employee engaged in the task, operate equipment from within an enclosed cab. | None | None |
| 11 | Concrete Mixer | RespiratorN95 | N95 (or Greater Efficiency) Filtering Facepiece or Half Mask | N95 (or Greater Efficiency) Filtering Facepiece or Half Mask |
Table 1: Specified Exposure Control Methods When Working with Materials Containing Crystalline Silica
When an employee performs more than one task listed in Table 1 during the course of a shift, and the total duration of all tasks combines is more than four hours, the required respiratory protection for each task is the respiratory protection specified for more than four hours per shift. If the total duration of all tasks on Table 1 combined is less than four hours, the required respiratory protection for each task is the respiratory protection specified for less than four hours per shift.
When implementing the exposure control methods listed in Table 1, the following must be followed:
- For tasks performed indoors or in enclosed closed areas, a means of exhaust must be used, as needed, to minimize the accumulation of visible airborne dust.
- For tasks performed using wet methods, water must be applied at flow rates sufficient enough to minimize release of visible dust.
When respiratory protection is required to be worn, all requirements of Title 8, Section 5144 and the University’s Respiratory Protection Program must be adhered to.
V. Alternative Exposure Control Methods
- Exposure Assessments
Alternative exposure controls methods that are not listed in Table 1, or where the University is unable to fully and properly implement the engineering control, work practices, and respiratory protection described in Table 1, exposure assessments will be performed for those employees who are or may be reasonably expected to be exposed to respirable crystalline silica at or above the action level. This will be done by either a performance option or a schedule monitoring option as defined below.
Environmental Health and Safety will be making the determinations for the performance option and performing the exposure monitoring for the scheduled monitoring option.
- Performance Option - Assessing the 8-hour TWA exposure for each employee on the basis of any combination of air monitoring data or objective data sufficient to accurately characterize employee exposures to respirable crystalline silica.
- Scheduled Monitoring Option - Performing exposure monitoring, on a predefined schedule, for each employee or group of employees (if jobs duties are similar) with personal breathing zone air samples to determine exposure to respirable crystalline silica.
Employees have the right to observe any monitoring of exposure to respirable crystalline silica. Within five working days after completing exposure monitoring, EH&S will notify the affected employee(s) in writing the results of that assessment. Whenever an exposure assessment indicates employee exposure is above the PEL, the University will describe in the written notification the corrective action taken to reduce exposure to or below the PEL. The University will reassess exposures whenever a change in the production, process, control equipment, personnel, or work practices will be expected to result in new or additional exposures at or above the action level.
- Methods of Compliance
If it is found an employee or group of employees are exposed to respirable crystalline silica above the PEL, engineering and work practice controls will be utilized to reduce and maintain employee exposure to respirable crystalline silica to or below the PEL. Wherever engineering and work practice controls are not feasible or when they cannot lower employee exposure to or below the PEL, the University will provide respirators to supplement the engineering and work practice controls.
VI. House Keeping
Proper housekeeping is required when cleaning up areas after performing construction tasks on crystalline silica-containing materials. The following housekeeping items must be followed:
- Dry sweeping or brushing is not allowed where such an activity could contribute to employee exposure to respirable crystalline silica unless wet sweeping, HEPA-filtered vacuuming or other methods that minimize the likelihood of exposure are not feasible.
- Compressed air is not allowed to be used to clean clothing or surfaces where such activity could contribute to employee exposure to respirable crystalline silica unless the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air or no other alternative method is feasible.
- If vacuuming is the method, selected, specialized vacuums with HEPA filtration are required. Methods to use and empty vacuums in a manner that minimizes the reentry of silica into the workplace shall be described and used. Use of household vacuums with HEPA filters are not allowed at any time for the collection of dust or debris that contains silica.
- When emptying the vacuum bag full of silica dust employees must wear an N95v respirator. After respirator is on, carefully open-up vacuum, and tie bag using a zip-tie, then throw bag in trash bin.
VII. Medical Survelliance
Medical surveillance will be made available, at no cost to employees and at a reasonable time and place, for each employee who will be required under the regulation to use a respirator for 30 or more days per year (“covered employee”). There are no known employees that meet this definition. Regardless, this section reviews medical surveillance requirements.
All medical examinations will be performed by a physician or licensed health care provider (“PLHCP”). The following information will be provided to the PLHCP:
- A description of the employee’s former, current, and anticipated duties as they relate to the employee’s occupational exposure to respirable crystalline silica;
- The employee’s former, current, and anticipated levels of occupational exposure to respirable crystalline silica;
- A description of any personal protective equipment to be used by the employee, including when and for how long the employee will use that equipment; and
- Information from records of employment-related medical examinations previously provided to the employee and currently within the control of the University.
A written medical opinion will be submitted to the University and the employee. It will include the following information only:
- The date of the examination,
- A statement that the examination has met the requirements of the standard, and
- Any recommended limitations on the employee’s use of a respirator.
A more in-depth written report with confidential medical information will be made available to the employee by the PLHCP.
- Initial Examination
An initial examination shall be made available to covered employees within 30 days after initial assignment. The examination will consist of the following:
- A medical and work history, with emphasis on past, present, and anticipated exposure to respirable crystalline silica, dust, and other agents affecting the respiratory system; any history of respiratory system dysfunction including signs and symptoms of respiratory disease; history of tuberculosis, and smoking status and history;
- A physical examination with special emphasis on the respiratory system;
- A chest x-ray;
- A pulmonary function test;
- Testing for latent tuberculosis infection; and
- And other tests deemed appropriate by the PLHCP.
- Periodic Examinations
A periodic examination will occur every three (3) years, or more frequently if recommended by the PLHCP. The examination will include procedure described in Section 6.1 of this plan, except for latent tuberculosis infection testing.
- Additional Examinations
If the PLHCP’s written medical opinion indicates that an employee should be examined by a specialist, the University will make available a medical examination by a specialist within 30days after receiving the PLHCP’s written opinion.
VIII. Hazard Communication and Training
- Hazard Communication
Communication of the hazards associated with respirable crystalline silica will comply with the hazard communication standard (CCR Title 8, Section 5194) and the University’s Hazard Communication Program Plan.
- Signs for Regulated Areas
Regulated areas must be established where respirable crystalline silica exposures at a fixed location are known to be at or above the PEL. There are no known regulated areas for respirable crystalline silica on campus.
- Training
Training and education programs are administered to employees through the CSU Learn system. Where possible, groups of employees will be auto-assigned training based on job positions; if jobs vary, individuals will be assigned. Training will be provided, at no cost to employees, prior to assignment and every three (3) years thereafter. The training will consist of, at a minimum, the following information:
- The health hazards associated with exposure to respirable crystalline silica (including signs and symptoms of silicosis);
- Specific tasks in the workplace that could result in exposure to respirable crystalline silica;
- Specific measures the employer has implemented to protect employees from exposure to respirable crystalline silica, including engineering controls, work practices, and respirators to be used;
- The importance of proper equipment and control maintenance;
- Housekeeping procedures;
- Proper use of respirators and our respirator program;
- Personal hygiene procedures to reduce exposures;
- How smoking increases the risk of developing silicosis and other lung damage; and
- The details of the ECP, and what is the responsibility of the employer and employee.
IX. Record Keeping
Air Monitoring Data will be maintained by the EH&S dept of all exposure measurements taken to assess employees’ exposure to respirable crystalline silica in accordance with CCR Title 8 Section 3204.
- Date of measurement for each sample
- Task Monitored
- Sampling and analytical method used
- Number, duration and results of sample taken
- Identity of the laboratory that performed the analysis
- Type of PPE worn by employee
- Name, social security number, job classification of all employees represented by the monitoring.
Medical Surveillance shall maintain an accurate record for each employee
X. Plan Review And Effectiveness
The Respirable Crystalline Silica Exposure Control Plan will be reviewed on an annual basis to ensure it meets regulatory requirements. The Plan will also be evaluated for effectiveness by reviewing silica related complaints and reported concerns.
XI. References
Occupational Safety and Health Administration (OSHA) 29 CFR 1926.1153: Respirable Crystalline Silica (Construction Industry) and 29 CFR 1910.1053
CCR, Title 8, Section § 1532.3. Occupational Exposures to Respirable Crystalline Silica.
CCR, Title 8, Section §5144. Respiratory Protection
CCR, Title 8, Section 5194. Hazard Communication
CFR 29, Section 1926.1153, including employee training, a medical surveillance program, and a record retention policy.
XII. Revision Record
REVISION | CHANGES | DATE |
1.0 | Plan Created | October 2023 |