Complying with OSHA's Respirable Crystalline Silica Standard
July 13, 2018
Author: Jim Collins, VP, EHS&Q & EHS
The enforcement of the Occupational Safety and Health Association’s regulations regarding respirable crystalline silica began June 23, including OSHA's standard for the general industry and maritime;by which BJ does comply.
The Reader's Digest version is that June 23 is when the oil field industry is supposed to be able to identify where the silica is, who's in the area with silica, and what needs to be reengineered. The industry must also provide a plan to achieve medical screening to the individuals who work within the identified area with silica.
But let’s back up a bit.
What is Silica?
Respirable crystalline silica, or silica, is a common mineral found in materials like sand, stone, concrete and mortar. Specific to the industry, it’s a durable and nonwater-soluble mineral found in cement products and sand used in hydraulic fracturing operations. Respiratory concerns exist with regard to silica exposure, so OSHA has chosen to increase controls over the exposure of employees.
In our operations, silica is mostly present when moving sand from storage to the blender. Any time you’re moving sand allows the dust to become free, which mixes with normal dust in the air, thus creating more dust.
What We’re Doing
The health and safety of our team is always a top priority for BJ and maintaining a silica environment that meets or exceeds OSHA Requirements is a commitment.
The EHSQ team at BJ conducted silica awareness training in February and March 2018 to ensure our operating teams and leaders were informed with regard to silica. We began surveillance in December 2017, which included extra testing to assess where silica dust was located. Then in May we identified who worked in areas of exposure and ensured medical screening happened immediately. Screening and testing allows us to develop a comprehensive picture of exposure areas as well as:
- Develop and validate engineering control measures
- Evaluate best practice methods employed for limiting exposure at the well site
- Identify residual hazards.
Today, and as we move forward, our engineering controls include enhancements that remove sand. All blenders have pressurized cabs, which means exposure is nearly zero for team members operating our blenders. Our tests show no measurable silica inside our blender cabs. This is an important safety measure as well as a value-add to clients in that we contribute and adhere to their safety programs.
Outside the blender cab, we deploy multiple dust vacuum trailers and we are implementing methods to limit exposure by:
- Engineering: Use of dust control technology
- Monitoring: All field frac personnel whose assigned position is within 50’ of moving sand must be in a silica surveillance program
- Reduction:Reduced stay time
- Protection:Respiratory Protection Program: All field personnel are required to use full face respirators. Fit testing was in place prior to the regulation as a standard operating procedure, but we now require both an initial fit and pulmonary function testing performed during new hire orientation. In addition, an initial fit retesting is completed annually with a pulmonary function retest done every two years.
What to Know
The new OSHA regulations were introduced in June 2016, and became enforceable June 23, 2018.
OSHA requirements include the following:
- Engineering: Implement engineering controls; Establish an exposure control plan, which must be included in a HAZCOM program
- Reduction: Reduction of the exposure Action Level to 25 µg/m3, calculated as an eight-hour time weighted average; Reduction of the Permissible Exposure Limit (PEL) to 50 µg/m3, calculated as an eight-hour time weighted average
- Protection: Develop a training program to increase awareness to the hazards of crystalline silica; Assess exposure levels through objective data and notify employees of the results of testing; Implement medical screening program and notify employees in writing of the results of screening; Establish safe housekeeping methods
The next steps for hydraulic fracturing are:
- June 23, 2020: Medical screening required for personnel exposed to levels that exceed the Action Level for 30 days in one year
- June 23, 2021: Engineering controls to reduce the exposure levels below the PEL, such as our pressurized cabs that are currently in place.
Please don’t hesitate to reach out and ask us questions about silica, the regulation and how we’re remaining in full compliance.
Jim Collins is the vice president of EHS&Q at BJ Services, the largest North American-focused, pure-play pressure pumping services provider. He brings over 35 years of experience and leads the creation and implementation of the environment, health, safety and quality system for all operating regions in the company.