12 Aug Silica-Generating Activities – JSA

Silica-Generating Activities Job Safety Analysis (JSA)

Job / Task

Cutting, sawing, drilling, coring, grinding, chipping, jackhammering, crushing, sweeping, cleanup, or other activities that disturb concrete, masonry, mortar, brick, block, stone, asphalt-containing aggregate, or other materials that may contain crystalline silica.

Purpose

This Job Safety Analysis (JSA), also known as a Job Hazard Analysis (JHA), identifies hazards associated with silica-generating activities and establishes controls to minimize employee exposure to respirable crystalline silica, flying particles, noise, tool hazards, electrical hazards, slips and falls, and other hazards associated with dust-producing construction work.

Personnel Qualifications

Employees performing silica-generating activities shall be trained for the tools, equipment, materials, and exposure-control methods involved. Work shall be performed in accordance with the applicable silica exposure-control requirements, manufacturer instructions, and site-specific procedures.

Employees shall:

• Recognize materials and tasks that may generate respirable crystalline silica.
• Understand the health hazards associated with respirable crystalline silica exposure.
• Use the specified engineering and work-practice controls for the task.
• Inspect water-delivery systems, shrouds, dust collectors, HEPA-filtered vacuums, tools, hoses, and other control equipment before use.
• Use respiratory protection when required by the task, exposure assessment, or silica-control program.
• Maintain controlled access to areas where silica-generating work may expose other employees.
• Use cleanup methods that minimize airborne dust.
• Report damaged or ineffective dust-control equipment immediately.
• Stop work when required controls cannot be maintained.
• Follow the written exposure control plan and instructions of the competent person where applicable.

Required PPE

PPE shall be selected based on the task, equipment, exposure assessment, and work environment and may include:

• Safety glasses with side protection.
• Goggles or face shield worn over safety glasses where flying particles create additional eye or face hazards.
• Hearing protection appropriate to the noise exposure.
• Work gloves appropriate to the tool and material.
• Safety footwear appropriate to construction and material-handling hazards.
• Hard hat where overhead or construction hazards exist.
• High-visibility apparel where traffic or mobile-equipment exposure exists.
• NIOSH-approved respiratory protection when required, used in accordance with the respiratory-protection program.
• Additional task-specific PPE identified by the hazard assessment.

JSA – Job Steps, Hazards, and Controls

Step 1 – Evaluate the Material and Task

Potential Hazards

• Respirable crystalline silica exposure.
• Incorrect control selection.
• Unrecognized task hazards.

Required Controls

• Identify the material to be disturbed and determine whether it contains or may contain crystalline silica.
• Identify the specific task, tool, duration, location, and work conditions.
• Determine whether an OSHA-specified control method will be used or whether exposure assessment is required.
• Review the written exposure control plan and applicable task-specific controls.
• Identify additional hazards such as utilities, traffic, falling debris, noise, and electrical exposure.

Step 2 – Select the Exposure-Control Method

Potential Hazards

• Excessive silica exposure.
• Inadequate dust suppression.

Required Controls

• Use the engineering and work-practice controls required for the task.
• Where applicable, follow OSHA Table 1 requirements for the specific equipment and activity.
• Use integrated water delivery, commercially available shrouds and dust collection, or other approved controls as specified.
• Do not substitute uncontrolled dry methods when required controls are available and applicable.
• Determine respiratory-protection requirements before work begins.

Step 3 – Establish the Work Area

Potential Hazards

• Exposure to nearby employees.
• Dust migration.
• Pedestrian intrusion.

Required Controls

• Restrict unnecessary personnel from the silica-generating work area.
• Use barricades, signs, distance, scheduling, or other controls as appropriate.
• Position work to minimize dust migration into occupied areas, entrances, ventilation intakes, and adjacent work zones.
• Coordinate with other trades and affected personnel.
• Provide adequate lighting and safe access.

Step 4 – Inspect Tools and Dust Controls

Potential Hazards

• Tool failure.
• Dust-control failure.
• Electrical hazards.

Required Controls

• Inspect tools, guards, blades, bits, cords, hoses, water lines, shrouds, and dust-collection equipment before use.
• Verify water-delivery systems provide adequate flow at the point of dust generation.
• Verify dust collectors and HEPA-filtered vacuums are properly assembled and maintained.
• Check hoses and connections for leaks, damage, blockage, or disconnection.
• Remove defective equipment from service.

Step 5 – Set Up Water-Delivery Controls

Potential Hazards

• Silica dust.
• Slips.
• Electrical exposure.

Required Controls

• Use the manufacturer’s recommended water-flow rate and delivery method.
• Apply water continuously at the point where dust is generated when required.
• Position hoses to prevent kinks, damage, and trip hazards.
• Control runoff and standing water to prevent slips and environmental releases.
• Keep water away from electrical hazards unless equipment is designed and protected for wet operation.

Step 6 – Set Up Vacuum Dust Collection

Potential Hazards

• Silica dust.
• Loss of suction.
• Dust release.

Required Controls

• Use a shroud or cowling designed for the tool where required.
• Connect the tool to a dust collector with adequate airflow and filtration for the task.
• Use HEPA filtration where required by the applicable control method or cleanup procedure.
• Inspect filters, collection bags, hoses, and seals before work.
• Maintain suction and replace or service filters and collection media as required.

Step 7 – Don Required Respiratory Protection

Potential Hazards

• Respiratory exposure.
• Improper respirator use.

Required Controls

• Use respiratory protection when required by the silica standard, Table 1, exposure assessment, or written program.
• Use only NIOSH-approved respirators selected for the exposure.
• Employees required to wear respirators shall be medically evaluated, fit tested, and trained as required.
• Perform required user seal checks before entering the exposure area.
• Do not use facial hair or other conditions that interfere with the respirator seal.

Step 8 – Perform Cutting or Sawing

Potential Hazards

• Silica dust.
• Flying particles.
• Blade contact.
• Noise.

Required Controls

• Use the specified water-delivery or dust-collection control continuously.
• Keep guards installed and adjusted according to manufacturer instructions.
• Maintain stable footing and control of the saw.
• Do not force the blade or operate damaged blades.
• Keep other employees outside the immediate cutting and debris zone.

Step 9 – Perform Drilling or Coring

Potential Hazards

• Silica dust.
• Bit binding.
• Flying particles.
• Utility strike.

Required Controls

• Use an integrated water-delivery system or commercially available shroud and dust collector as required.
• Identify embedded or concealed utilities before drilling.
• Maintain the drill perpendicular or properly aligned to reduce binding.
• Use the correct bit and inspect it before use.
• Control slurry and dust generated during drilling or coring.

Step 10 – Perform Grinding

Potential Hazards

• High silica exposure.
• Wheel failure.
• Flying particles.
• Noise.

Required Controls

• Use a grinder equipped with the required shroud and dust-collection system or other specified control.
• Keep the shroud positioned to capture dust at the point of generation.
• Inspect abrasive wheels and guards before use.
• Use the correct wheel for the material and rated tool speed.
• Stop work if visible dust indicates the control system is not functioning effectively.

Step 11 – Perform Jackhammering or Chipping

Potential Hazards

• Silica dust.
• Flying debris.
• Noise.
• Vibration.

Required Controls

• Use continuous water application or an appropriate shroud and dust-collection system as specified for the task.
• Maintain water or suction at the point of impact.
• Keep nearby employees away from dust and flying debris.
• Use hearing protection and control vibration exposure as appropriate.
• Stop operation if the dust-control system fails.

Step 12 – Perform Crushing or Demolition

Potential Hazards

• Heavy silica dust.
• Falling debris.
• Equipment hazards.

Required Controls

• Use water sprays, misting, local exhaust, enclosed equipment, or other controls appropriate to the operation.
• Restrict access to the demolition or crushing zone.
• Apply water in a manner that effectively suppresses dust without creating additional hazards.
• Coordinate dust controls with equipment operators.
• Monitor changing conditions and adjust controls as work progresses.

Step 13 – Work Indoors or in Enclosed Areas

Potential Hazards

• Dust accumulation.
• Elevated exposure.
• Reduced ventilation.

Required Controls

• Use engineering controls that capture or suppress dust at the source.
• Provide additional ventilation where needed without spreading contamination to other areas.
• Isolate the work area from occupied spaces when appropriate.
• Do not allow visible dust to accumulate in enclosed work areas.
• Evaluate respiratory-protection needs based on the task and exposure conditions.

Step 14 – Work Outdoors

Potential Hazards

• Windborne dust.
• Exposure to nearby employees or public.

Required Controls

• Position employees upwind where practical.
• Use required engineering controls even when working outdoors.
• Consider wind direction and speed when establishing the controlled work area.
• Prevent dust from migrating toward occupied areas, roadways, or adjacent work.
• Suspend or modify work when weather conditions make controls ineffective.

Step 15 – Maintain Engineering Controls During Work

Potential Hazards

• Loss of dust control.
• Unexpected silica exposure.

Required Controls

• Continuously observe water flow, vacuum suction, shroud position, and visible dust conditions.
• Stop work if hoses disconnect, water stops, filters clog, shrouds break, or suction is lost.
• Correct deficiencies before resuming work.
• Do not remove guards, shrouds, or control devices to increase production.
• Follow manufacturer maintenance requirements.

Step 16 – Control Slurry

Potential Hazards

• Silica residue.
• Slips and falls.
• Environmental release.

Required Controls

• Contain slurry generated by wet methods.
• Prevent slurry from entering storm drains or other prohibited areas.
• Remove slurry before it dries and becomes airborne dust.
• Use appropriate wet cleanup or collection methods.
• Maintain safe walking and working surfaces.

Step 17 – Clean the Work Area

Potential Hazards

• Re-suspension of silica dust.
• Employee exposure.

Required Controls

• Use wet sweeping, wet methods, or HEPA-filtered vacuuming where feasible.
• Do not use dry sweeping or dry brushing when it could contribute to respirable silica exposure unless wet or HEPA methods are not feasible.
• Do not use compressed air to clean clothing or surfaces when it could contribute to silica exposure unless used with a ventilation system that effectively captures the dust.
• Keep cleanup personnel protected from residual exposure.
• Dispose of collected material without creating airborne dust.

Step 18 – Empty Dust Collectors or Vacuums

Potential Hazards

• Concentrated silica dust.
• Dust release.

Required Controls

• Follow manufacturer procedures for filter and collection-container servicing.
• Wear required PPE and respiratory protection.
• Handle bags, filters, and collection containers carefully to minimize dust release.
• Seal collected dust and debris in suitable containers or bags.
• Perform servicing in a location that minimizes exposure to other employees.

Step 19 – Remove PPE and Respiratory Protection

Potential Hazards

• Cross-contamination.
• Residual silica exposure.

Required Controls

• Leave the active exposure area before removing respiratory protection unless procedures require otherwise.
• Remove dusty PPE in a manner that minimizes re-suspension of dust.
• Do not use compressed air to clean clothing.
• Wash hands and face before eating, drinking, smoking, or leaving the work area.
• Store reusable respirators and PPE in a clean location after required cleaning.

Step 20 – Dispose of Silica-Containing Debris

Potential Hazards

• Dust release.
• Manual handling injuries.

Required Controls

• Place dust, debris, slurry residue, vacuum contents, and disposable materials into suitable containers.
• Keep waste damp or sealed as necessary to prevent airborne dust.
• Do not drop or dump material in a manner that creates visible dust clouds.
• Use mechanical assistance for heavy debris.
• Dispose of material according to site and applicable environmental requirements.

Step 21 – Respond to Control Failure

Potential Hazards

• Uncontrolled silica exposure.
• Dust migration.

Required Controls

• Stop silica-generating work immediately when required controls fail.
• Move away from uncontrolled dust and restrict access.
• Repair or replace failed water, vacuum, shroud, hose, filter, or tool components.
• Clean accumulated dust using approved methods before restarting.
• Report repeated or significant control failures to supervision.

Step 22 – Complete Post-Task Inspection

Potential Hazards

• Residual exposure.
• Uncorrected equipment defects.

Required Controls

• Inspect the work area for residual dust, slurry, debris, and contaminated surfaces.
• Verify cleanup is complete and the area is safe for normal access.
• Inspect tools and dust-control equipment for damage or maintenance needs.
• Restore barricades, ventilation, or adjacent areas as appropriate.
• Document or report exposure-control issues identified during the work.

General Safe Work Requirements

• Silica-generating work shall be planned before the task begins and performed using required engineering and work-practice controls.
• OSHA Table 1 controls shall be followed when used as the exposure-control method for covered construction tasks.
• Where Table 1 is not followed or does not apply, employee exposure shall be assessed and controlled as required by the silica standard.
• Water-delivery and dust-collection systems shall be operated and maintained so they remain effective throughout the task.
• Employees shall not intentionally disable, remove, or bypass required dust controls.
• Access to silica-generating work areas shall be limited as necessary to minimize exposure to other employees.
• Respiratory protection shall be used when required and only in accordance with the respiratory-protection program.
• Dry sweeping, dry brushing, and compressed-air cleaning shall be restricted as required to prevent avoidable airborne silica exposure.
• Silica-containing dust and slurry shall be cleaned and handled in a manner that minimizes re-suspension.
• Employees shall not eat, drink, smoke, or otherwise engage in activities that could increase contamination exposure in dusty work areas.
• Tools, shrouds, hoses, water systems, vacuums, filters, and other control equipment shall be inspected before use and maintained in effective condition.
• Work shall stop immediately when required silica controls fail or cannot be maintained.
• The written exposure control plan shall be available and implemented as required.
• A competent person shall make frequent and regular inspections of job sites, materials, and equipment to implement the written exposure control plan where required.
• Employees shall report visible dust, failed controls, damaged equipment, and other conditions that may increase silica exposure.

Training

Employees exposed to respirable crystalline silica shall receive training appropriate to their tasks and exposures. Training shall include the health hazards associated with respirable crystalline silica; specific work tasks that may result in exposure; engineering controls, work practices, and respiratory protection used to limit exposure; the identity of the competent person where applicable; the purpose and description of the medical surveillance program where applicable; and the contents of the applicable silica standard and written exposure control plan.

References

• OSHA 29 CFR 1926.1153 – Respirable Crystalline Silica.
• OSHA 29 CFR 1926.1153(c), Table 1 – Specified Exposure Control Methods When Working With Materials Containing Crystalline Silica.
• OSHA 29 CFR 1910.134 – Respiratory Protection, where applicable.
• OSHA 29 CFR 1926.95 – Criteria for Personal Protective Equipment.
• Applicable manufacturer instructions, exposure assessments, written exposure control plan, and site-specific procedures.