By James L. Curtis, Jeryl L. Olson, and Craig B. Simonsen
Is respirable silica the “new” asbestos-like hazard for workplace exposure? OSHA and Canada appear to think so.
OSHA, along with its sister agency, NIOSH (National Institute for Occupational Safety and Health), have recently posted a “hazard alert” for Worker Exposure to Silica during Hydraulic Fracturing. In British Columbia, a proposed construction safety rule for silica has just been published to amend the Provincial Occupational Health and Safety Regulations
The U.S OSHA hazard alert indicates that NIOSH identified exposure to respirable crystalline silica as a health hazard to workers conducting some hydraulic fracturing operations during recent field studies. In its studies, NIOSH identified seven primary sources of silica dust exposure during fracking operations:
- Dust ejected from access ports on sand movers during refilling operations while the machines are running;
- Dust ejected and pulsed through open side fill ports on the sand movers during refilling operations;
- Dust generated by on-site vehicle traffic;
- Dust released from the transfer belt under the sand movers;
- Dust created as sand drops into, or is agitated in, the blender hopper and on transfer belts;
- Dust released from operations of transfer belts between the sand mover and the blender; and
- Dust released from the top of the end of the sand transfer belt on sand movers.
(See the OSHA hazard alert for a full details about NIOSH’s findings.)
After sampling eleven fracking sites in five states, NIOSH found thirty-one percent of all samples showed silica exposures ten or more times the NIOSH REL (recommended exposure limit), with one sample more than 100 times the REL.
In the British Columbia construction safety rule for silica, new sections are proposed to address silica exposure in the workplace. The silica provisions appear similar to asbestos provisions in British Columbia rules. The new silica sections proposed in British Columbia include:
- Assessment of risk to health created by work involving exposure to dust containing respirable crystalline silica;
- Prevention or control of exposure;
- Use of control measures;
- Maintenance, examination, and testing of control measures;
- Monitoring exposure at the workplace;
- Instruction and training for persons who may be exposed; and
- Emergency procedures.
These actions, both the issuance of the OSHA hazard alert, and the publication of the British Columbia proposed rules, telegraph a trend in assessing and negotiating risks associated with working around and handling silica based materials.
Employers here in the United States and internationally should be mindful of these developments, and take steps to ensure that they are in compliance with OSHA and local laws and regulations. Proactive steps now may allow the company to avoid costly enforcement and litigation in the future.