OSHA Considerations for Reducing PELs for Crystalline Silica

OSHA Considerations for Reducing PELs for Crystalline Silica OSHA considerations for reducing PELs for crystalline silica Presented by: Sepideh Sadeghi Introduction Crystalline silica is known as an important constituent in some construction materials like stone, sand, concrete, and granite (1, 2). It comes from different industrial activities such as agriculture, sandblasting, mining, foundry, construction, oil and gas extraction, and hydraulic fracturing (3). Crystalline silica is present in the form of Quartz, Cristobalite and tridymite and all of them are known as a source of exposure in the work places (1, 2). Exposure to crystalline silica can cause silicosis, and a progressive fibrosis of the lungs (2). The National Toxicology Program (NTP) and International Agency for Research on Cancer (IARC) have found two forms of quartz and cristobalite carcinogenic (4, 5). There is a possible mechanism that denotes how this material causes lung disease; when active oxygen species (AOS) is generated by chemicals reactions, it can interact with DNA, proteins, and lipids in macromolecules, then mutation in DNA can initiate the process of cancer or DNA damage (6). The permissible exposure limit (PEL) for respirable crystalline silica (RCS) which is adopted by OSHA is, (RCS): PEL = (10 mg/m3)/ (%silica+2) which restricts both the exposure to RCS and respirable dust (7). The PEL has not updated since the agency was established in 1971. There are many techniques to identify and quantify crystalline silica such as X-ray diffraction methods, Infrared methods, optical and electron microscopy techniques, chemical and thermal analysis. However, some of these techniques have some limitations in their process (8). The purpose of this study is reviewing the OSHA considerations for reducing PELs for crystalline silica. Background Based on the researches done to identify the reason of workers’ illnesses in Vermont granite occurred in 1940 the OSHA proposed the current PEL in 1971(7). The most common symptoms among the workers in Vermont granite were shortness of breath, dry cough, and reduced pulmonary function (9). Then, a recommended exposure limit (REL) of 0.05 mg/m3 for RCS was proposed by NIOSH in 1974 (7, 10) In 1989, NIOSH testified to OSHA that silica should be considered a â€Å"potential occupational carcinogen.† And IARC attested to classify crystalline silica as a carcinogen (7, 11). As a result, the ACGIH accepted to list the silica as an â€Å"A2 Suspected Human carcinogen† In 1999, and, in 2000, adopted a TLV of 50 ÃŽ ¼g/m3 for RCS. In 2006, additional evidences indicated the relation between lung cancer and the inflammation caused by silica, and it led the ACGIH to reduce the TLV to 25ÃŽ ¼g/m3 (9, 12). Results and discussion The detrimental effects of silica on the workers’ health such as lung cancer, kidney diseases and sometimes death necessitated OSHA proposing a new PEL for respirable crystalline silica of 50ÃŽ ¼g/m3 (9). The investigations conducted in the industries showed that workers were at the risk of illnesses and death below the current PELs (9). The following paragraphs address the OSHA considerations for reducing the PEL for crystalline silica. Possibility of Sampling and Analytical Methods The possibility of sampling and analytical methods is between the several limitations that can affect the OSHA decision to reduce the silica PELs. There are some available and accurate personal sampling cyclones like SKC G-3, Higgens-Dowel, Dorr-Oliver, and BGI GK 2.69 which were examined by OSHA for collecting the respirable crystalline silica. According to OSHA, all of these devices are able to collect the silica as low as 25 ÃŽ ¼g/m3 which is needed for the OSHA analytical method of ID-142 (9). Regarding analytical methods to measure silica, two factors of sensitivity and accuracy are investigated by OSHA. The first method that OSHA concludes it has a reasonable sensitivity for measuring the silica was the X-Ray Diffraction (XRD) and Infrared Spectroscopy (IR). However, the poor inter-laboratory results indicated that the mentioned methods are lack of precision. The XRD method of ID-142 presents the precision of  ±23 for the crystalline silica of 50 to 160 ÃŽ ¼g and  ±19 percent for the sampling and analytical error. Therefore, the OSHA could not rely on such colorimetric methods to measure the low amount of silica. Finally, OSHA’s analysis found the laboratories good agreement for the samples in the range of 49-70 ÃŽ ¼g. Therefore, OSHA believes that a PEL of 50ÃŽ ¼g/m3 is more appropriate in the workplaces (9). Possibility of Control Technologies According to possibility of control technologies the OSHA has conducted an analysis for both of general industry sectors and construction industry activities that are potentially affected by the proposed silica standard. 3.2.1. Possibility Findings for the Proposed Permissible Exposure Limit of 50ÃŽ ¼g/m3 According to the results of findings, OSHA assumed that the proposed PEL of 50ÃŽ ¼g/m3 is appropriate for all affected general industries as well as construction activities (9). Thus, OSHA discerned that the PEL of 50ÃŽ ¼g/m3 will be sufficient to maintain in engineering and work practices. And for those few activities within an industry where the proposed PEL is not technologically achievable the workers can achieve the exposure levels at or below the proposed PEL by wearing the protective equipments such as respirators (9). 3.2.2 Feasibility Findings for an Alternative Permissible Exposure Limit of 25ÃŽ ¼g/m3 Regarding to the results of possibility analysis, OSHA concludes that a proposed PEL of 25ÃŽ ¼g/m3 would not be achievable for many industries, and using respiratory protection would have to be required in most operations to achieve compliance. However, there are several industries that have achieved an alternative PEL of 25ÃŽ ¼g/m3 such as asphalt paving products, dental laboratories, mineral processing, and paint and coatings manufacturing in general industry, and drywall finishers and heavy equipment operators in construction industry. In these industries, small amounts of silica containing materials cause to have low concentrations of airborne respirable silica (9). The ferrous foundry industry would not be able to agree with the PEL of 25ÃŽ ¼g/m3 without using the respirators. In the ferrous foundry industry silica is used and recycled to create castings and there is a big amount of silica dust during the process of recycling. Also, the high level silica dust is generated during the shakeout process. The engineering controls determine the exposures below 50ÃŽ ¼g/m3, but the exposure above 25ÃŽ ¼g/m3 still occur. Therefore, the engineering controls in place, reported the exposure range of 13 ÃŽ ¼g/m3 53 ÃŽ ¼g/m3, with many of the reported exposures above 25ÃŽ ¼g/m3(9). The construction industry is similar to the ferrous industry with regarding the generation of dust. Thus, the engineering controls cannot comply to maintain exposures at or below the alternative PEL of 25ÃŽ ¼g/m3. 3.3. Cost of compliance In this section the detailed assessment of the costs to establishments in all affected industry sectors was provided for supporting of the proposed silica rule of reducing worker exposures to silica to an eight-hour time-weighted average (TWA) permissible exposure limit (PEL) of 50ÃŽ ¼g/m3.Table 1 describes the annualized costs of the proposed rule by cost category for general industry, maritime, and construction. The cost is including the engineering controls, respirators, exposure assessment, medical issue, training and regulating areas or access control. Table 1. Annualized Compliance Costs for Employers in General Industry, Maritime, and Construction Affected by OSHA’s Proposed Silica Standard (2009 dollars) (13) Table 1 depicts the total annualized costs of the proposed rule, $132.5 million by general industry, $14.2 million by maritime, and $511.2 million by construction. So, considering the economic feasibility, OSHA standards are economically feasible so long as their costs do not threaten the existence of, or cause massive economic dislocations within, a particular industry or alter the competitive structure of that industry. For example, firms that want to have a profitable line of business may have to increase prices to stay viable. Increases in prices typically result in reduced quantity demanded, but rarely eliminate all demand for the product. This decrease in the total production of goods and services results in smaller output for each establishment within the industry or the closure of some plants within the industry, or a combination of the two, is dependent on the cost and profit structure of individual firms within the industry. So, the economic matter is the controversial subj ect to discuss and there are always some contradictions in companies to accept the cost of new proposed PELs. Conclusion The limitations in the characterization of the precision of the analytical method preclude the Agency from proposing a PEL of 25ÃŽ ¼g/m3. First, the measurement error increases by about 4 to 5 percent for a full-shift sample taken at 25ÃŽ ¼g/m3 compared to one taken at 50ÃŽ ¼g/m3, and the error would be expected to increase further as filter loads approach the limit of detection. Second, for an employer to be virtually certain that an exposure to quartz did not exceed 25 ÃŽ ¼g/m3 as an exposure limit, the exposure would have to be below 21 ÃŽ ¼g/m3 given the error of  ±16 percent calculated from the OSHAs Salt Lake Technical Center (SLTC) study. Based on the information presented in the technological feasibility analysis, the Agency believes that 50 ÃŽ ¼g/m3 is the lowest feasible PEL. An alternative PEL of 25ÃŽ ¼g/m3 would not be feasible because the engineering and work practice controls identified to date will not be sufficient to consistently reduce exposures to levels below 25 ÃŽ ¼g/m3 in most operations most of the time. OSHA believes that an alternative PEL of 25ÃŽ ¼g/m3 would not be feasible for many industries, and that the use of respiratory protection would be necessary in most operations most of the time to achieve compliance. Additionally, the monetary matter is the controversial subject that raises many contradictions in firms to accept the new proposed PELs by OSHA. References 1. Beaudry C., Lavouà © J., Sauvà © J-F., Bà ©gin D., Senhaji Rhazi M., Perrault G., Dion C., Gà ©rin M., (2012), Occupational Exposure to Silica in Construction Workers: A Literature-Based Exposure Database, Journal of Occupational and Environmental Hygiene, 10: 71–77. 2. www.osha.gov/Occupational Health/Projects/Crystalline Silica Exposure.htm 3. Esswein E. J., Breitenstein M., Snawder J., Kiefer, M., Sieber WK., (2013), Occupational Exposures to Respirable Crystalline Silica During Hydraulic Fracturing, Journal of Occupational and Environmental Hygiene, 10: 347-356. 4. International Agency for Research on Cancer (IARC), (2012), A Review of Human Carcinogens. Part C: Arsenic, Metals, Fibres, and Dusts. Lyon, France: IARC. 5. U.S. Department of Health and Human Services (DHHS), Public Health Service (PHS), and the National Toxicology Program (NTP), (2011), Silica, Crystalline (Respirable Size). In Report on Carcinogens. Research Triangle Park, N.C.: DHHS, PHS, NTP, 377–379. 6. Mossman B. T., Jimenez L.A. , Bà ©rubà © K., Quinlan T., Janssen Y.M.W.,( 2011), Possible Mechanisms of Crystalline Silica-Induced Lung Disease, Applied Occupational and Environmental Hygiene, 10:1115-1117. 7. Hewett P., Morey S.Z., Holen B. M., Logan P. W., Olsen G. W., (2012), Cohort Mortality Study of Roofing Granule Mine and Mill Workers. Part I: Estimation of Historical Crystalline Silica Exposures, Journal of Occupational and Environmental Hygiene, 9: 199-210. 8. Miles W. J., (2010), Issues and Controversy: The Measurement of Crystalline Silica; Review Papers on Analytical Methods , American Industrial Hygiene Association Journal, 60:396–402. 9. www.osha.gov/silica/nprm.pdf. 10. National Institute for Occupational Safety and Health (NIOSH), (1974), NIOSH Criteria for a Recommended Standard: Occupational Exposure to Crystalline Silica. HEW (NIOSH) Pub. No.75–120. U.S. Department of Health, Education, and Welfare, NIOSH. 11. International Agency for Research on Cancer (IARC), (1997), Silica, Some Silicates, Coal Dust and Para-aramid Fibrils. IARC Monographs, Vol. 68. Lyon, France: IARC. 12. ACGIH, (2006), Silica, Crystalline: ÃŽ ±-Quartz and Cristobalite. Chemical Substances, 7th Edition Documentation. Cincinnati, Ohio: ACGIH. 13. U.S. Dept. of Labor, OSHA, Directorate of Standards and Guidance, Office of Regulatory Analysis, based on ERG (2007and 2013).

Jack Kevorkian Essay -- essays research papers fc

After talks with her husband, sons, minister, and local doctors; Janet Adkins decided she didn ¹t want to undergo the sustained mental deterioration that Alzheimer ¹s Disease caused (Uhlman 111). She began to realize she had the disease when she started forgetting songs and failed to recognize notes as she played the piano (Filene 188).  ³She read in Newsweek about Dr. Jack Kevorkian and his Å’Mercitron ¹ machine, then saw him on the Å’Donahue ¹ Television show ² (Filene 188). With her husband ¹s consent but objections by sons and doctors, she telephoned him to arrange to kill herself (Filene 188). She still had a life expectancy of at least ten years with the illness, but she wished to die. She wanted to die before the disease robbed her of her competence (Larson 229). Kevorkian later killed Adkins and faced the consequences boldly (Hendin,  ³Suicide in America ² 247). The background, process, and effects of Dr. Kevorkian ¹s questionable first patient, Jane t Adkins, have a very detailed story in them. Janet Adkins led a very productive life up to and even after she had been diagnosed with Alzheimer ¹s, but she couldn ¹t handle losing control of her brain (Filene 188). She was 54 years old and lived in a wealthy Oregon suburb with her stock broker husband, Ron. She was also the mother of three sons, taught English and piano, went hang gliding, trekked in Nepal, climbed Mount Hood, and generally behaved with a lot of energy (Gutmann 20). She and her husband were longtime Hemlock society members, which advocates Euthanasia in some cases (Betzold 22).  ³Doctors at a Portland hospital told her that eventually she would be dependent on her husband for feeding and bathing ² (Gutmann 21). She did not want to take her own life in case she messed it up, and her own doctors wouldn ¹t help her (Hendin ,  ³Seduced by Death ² 132). Though she was still able to carry on clear conversations and demolish her son at tennis; her husband explained that if she was going to go, she ¹d probably want to go to soon rather than to late (Gutmann 21). After hearing about Kevorkian, Ron Adkins contacted him to employ his services (Wolfson 56). Her husband complained to Dr. Kevorkian that he had to remind her of the times of her tennis lessons, and that she kept leaving her purse in the house. After the brief conversation, Kevorkian agreed to meet with her (Gutmann 20).  ³Dr. Kevorkian was a ret... ...termining how ill she was. Also the method of which he carried out the suicide raised questions (Hendin,  ³Seduced by Death ² 130). Among supporters of Euthanasia he became something of an antiestablishment here (Larson 230). This was the first of over a hundred assisted suicides that he would perform (Uhlman 111). Works Cited Betzold, Michael.  ³The Selling of Doctor Death. ² New Republic 26 May 1997: 22-28. Fessenden, Ford.  ³Matters of Life and Death. ² Newsday 10 June 1995: 7. Filene, Peter. In the Arms of Others. Chicago: Ivan R. Dee, 1998. Gutmann, Stephanie.  ³Death and the Maiden. ² New Republic 24 June 1996: 20-22. Hamel, Robert. Must We Suffer Our Way to Death. Texas: Southern Methodist Press, 1996. Hendin, Herbert. Seduced by Death. New York: W.W. Norton and Company, 1997. Hendin, Herbert. Suicide in America. New York: W.W. Norton and Company, 1995. Larson, Edward. A Different Death. Illinois: Intervarsity Press, 1998. Uhlman, Michael. Last Rights. Washington D.C.: Ethics and Public Policy Center, 1998. Wolfson, Adam.  ³Killing of the Dying. ² The Public Interest Spring 1998: 56.

Noli Me Tangere, El Filibusterismo Essay

Both novels, the Noli Me Tangere (Touch Me Not) and the El Filibusterismo, (The Filibuster) inspired by the patriotic ideals of national hero, Dr. Jose Rizal, depict the abuses suffered by the native indios at the hands of Spanish tyrants. The Noli paints us an ugly, yet clear picture of the so-called â€Å"social cancer† that deteriorates the society. The first of those two masterfully-crafted works, the Noli lays the most liberal, realistic and fearless view of the country’s well-being during the 300-year Spanish regime. It illustrates the rotten system of governance, the illicit ways of the church and the unfavorable trade of the privilege class. The Noli also relates how the government, the church and the privilege class manipulate the people. The government deprives the youth of education and how they use the people’s ignorance to their advantage. The treacherous friars by means of God and faith controlled the people, making them dummies of all sorts. On the other hand, the privilege class used their elite status to get ahead of everybody, by hook or by crook — employing the â€Å"me first† attitude. In the Noli, the weak and disposed seemingly lose hope resulting to unfortunate deaths (as the case Pilisopo Tasyo) and sometimes insanity. (as the case of Sisa) Hence the oppressed formed a brotherhood that hopes to liberate the country by use of force. To no avail, due to disorganization and lack of arms, each and every attempt at resistance failed. In Noli, the character of Juan Crisostomo Ibarra was introduced, an intelligent and promising young man who has high hopes of changing the course of the country.

Why Franklin Valued Learning - Free Essay Example

Sample details Pages: 2 Words: 612 Downloads: 7 Date added: 2019/06/10 Category History Essay Level High school Tags: Benjamin Franklin Essay Did you like this example? Franklin valued learning and was constantly striving to gain knowledge and improve himself. He would do certain things to improve his writing and his reputation. Franklin would always want to gain knowledge and improve. This autobiography showed how he wanted to improve and showed how he had improved. Franklin helped people, improved his group writings and did things to help the community. I had chosen the second option to write about this story because it felt most suitable for me. In Franklins group, junto he would use his partners work to edit and make it his own, an example of this from his autobiography. The rules that I drew up required that every member, in his turn, should produce one or more queries on any point of morals, politics, or natural philosophy, to be discussed by the company (45). Franklin would take the prints from some of the group members, and print it as his own, then would use them to improve his work and knowledge. Franklin would then post his paper to the public, showing how he had improved. Franklin would not be a bad person and steal his groups writings, he would use them to help improve his own. Franklin would help his group improve as well, he would help them with their papers, inventions and many other things. He had loved doing this to help the community and just to entertain children. Don’t waste time! Our writers will create an original "Why Franklin Valued Learning" essay for you Create order Throughout the book, franklin would use virtues to help him get through tough times and use to use them everyday for good outcome. 1. Temperance eat not to dullness, drink not to elevation. 2. Silence speak not but what may benefit others or yourself; avoid trifling conversation (64 65). This quote proves my point with franklin using these every day. For temperance, he uses this virtue to control his temper. For silence, he shows how to avoid bad conversations and to keep his mouth shut. These virtues had helped franklin all throughout his life, meaning that if something were to happen, he would try and avoid the situation and keep his mouth shut to not get in trouble. Franklin would help others in need to help his reputation grow. He would take advantage of this to make others look at him differently, to see how much of a great person he is. This man continued to live in this decaying place, and to declaim some strain, refusing for many years to buy a house there (45). This quote shows how franklin found this homeless man and had visited him and gave him food and water. He would do this to help the man, and gain reputation with others. Franklin would always want to help his reputation grow, but at the same time he would really want to help the people in need. Franklin would not only do this for his reputation, but to help the people in need to help them live a better life. Ever since he had left his family, he wouldnt want anything bad to happen to the families in his city, this is why he had made so many inventions to help the community survive. My thesis statement and supporting evidence proves that franklin would always want to improve with his knowledge and improve his reputation. The supporting evidence in this paper shows how he would help people to improve his reputation, he would use his group partners writings to improve his own and he would invent things such as power, furniture and clothes. Franklin had left his family due to a drinking problem, but this had inspired him to do things for the better. This is what made franklin write, invent things and help people in the community.