What’s big, orange, and partially round?

If you guessed a pumpkin, you’re right.  It is almost Halloween, of course!

But the answer I was looking for was a Mud Hog, one of the many fabulous creations by EZG Manufacturing.  Read below on how these bad boys can help you out.

MH12- Mud Hog

At a time when everyone is scrambling to meet the requirements of the recently updated OSHA silica regulations, many are still asking what is supposed to happen with the mixing stations.  OSHA conveniently (or not-so-conveniently) left this out of Table 1.  Because of this, there’s no guidance of what is to be done here. 

So, what’s a contractor to do?

• Pause for a minute before agreeing to use respirators (N95 most likely).  There’s a chance the General Contractor will assume this is what should be done but this opens a whole can of worms (and medical exams, fit testing, and paperwork) that you probably don’t want to do unless absolutely necessary (note: that there are some activities within Table 1 that may require it). 
  • See our blog on Voluntary Use of Respirators for more information on this subject.
• Determine how you’re mixing your mortar.  Are you:
  • Using a silo system with pre-mixed mortar
  • Using pre-mixed mortar in smaller, most likely in 80 lb, bags
  • Batching (field mixing) everything
• Check with your supplier or masonry association to see if you’ve got any access to objective data to show you’re under the limit. 
  • If you’re buying pre-mixed mortar, you may be able to get testing that is similar to what you’re doing from your suppliers.  This will likely need to be in the same general region as you are working or the mix design and conditions could be different, causing OSHA to not accept it as objective data.
  • Check with your local or state association to see if there’s any objective testing available for either pre-mixed or batching. 
  • If you can’t get objective data that works for the way you’re mixing, you can perform testing of your own but be careful to follow all steps and requirements for testing, including posting results, allowing employee representatives, etc.
• If you’re over the PEL, you’ll need to determine what respirator your employees need to wear and follow the guidelines of the respiratory protection standards.
• Stay tuned in to MCAA and with your suppliers. 
  • Manufactures, like EZG, are actively working to develop solutions to help contractors keep working, despite these new and challenging requirements.  
  • If you have ideas on creating better ways to handle these issues, partner with your manufacturers or suppliers to develop these solutions, when possible.

Regardless of whether you have the data to show you are under the PEL or not, if you’re making a big cloud of dust at your mixing station, you could still be a target of OSHA and/or the General Contractor’s safety person. 

Why does that matter?

• Both groups can (and probably will) stop work until you can prove otherwise. 
  • If your mixing station shuts down, you’re not going to be laying units for much longer. 
  • It could take you a bit to find the necessary paperwork- so the easier access your crews have to all documentation, the better.
• If OSHA finds one area that they see a lot of dust, they will probably look at every other area that there is potential dust.  Ask yourself the following:
  • How confident are you that your team is following everything in the regulation? 
  • Do you have paperwork for every other potential silica-producing activity? 
  • Is your respiratory protection plan up to date and does your crew know about it?
  • Is your SDS/HAZCOM all up to date and does your crew know about it?
  • Has your crew all been trained on silica and do you have proof?
  • Does your crew know who your competent person?
• If there’s enough dust, OSHA may decide to do their own air monitoring and, even if you have objective data, you may be stuck with the test results that they do.
  • See OSHA’s memo for the Flowcharts they use to determine whether air sampling is necessary or not.

The big question is- how do I reduce the dust at the mixing station? 

By now you might be wondering why I led this story with the Mud Hog.  This is where the EZ Grout products come in- reducing the dust at the mixing station.  There’s a few great options, coupled with work practices, that can help you to prevent the dust that blows around like a big red flag:

• EZ Grout Pan Mixer fed by a silo
• EZ Grout Mud Hog Mixers with a solid grate cover fed by a silo
• EZ Grout Mixers with solid grate cover fed by a silo

Like any other dust control system- whether wet or vacuum- it is dependent upon the person operating it to be trained and use it correctly.  Running the mixer a few rotations with water before they open the grate to check the mix is necessary to avoid dust.  This may seem like common sense, but mud men are used to seeing their mix so there will be a learning curve.

EZG Mud Hogs Grate Covers

Spec Rents is a proud distributor of EZG Manufacturing products, including the above-mentioned mixers.  Like other products we carry, we know that these products stand the test of time. 

Less downtime = more units in the wall. 

Whether it’s less breakdowns or fewer arguments with the General Contractor’s safety guy about a cloud of dust at the mixing station- the above EZG products will make you more productive.  That’s something we all need.  Check out our Silica Solutions product page for more info or contact us if we can help you in any way to navigate this regulation.

Post by:  Elizabeth "Liz" Graves, Sales Manager at Spec Rents, LLC.  Contact Liz at lizg@specrents.com

OSHA Silica Full Enforcement Began Today

Today marked the first day that OSHA is requiring employers to be in full compliance with the new Respirable Crystalline Silica in Construction Standard (29 CFR 1926.1153).  Mason Contractors Association of America (MCAA) is working to track citations related to this rule.  They ask for your help in tracking these so they can address them at a national level.

If you get a citation, please contact the MCAA office at 800-536-2225 and ask to speak with Jeff Buczkiewicz . They will likely ask for a copy of the citation and move forward with any assistance we can provide.  See full article from MCAA:  Silica Rule Full Implementation Begins October 23.

Last week, OSHA issued this memorandum to OSHA Regional Administrators to provide interim enforcement guidance for Compliance Safety and Health Officers (CSHOs) beginning today.  This will expire when the standard's companion compliance directive becomes effective and available. 

A few highlights of the memo include:

• CSHOs will do the following during an inspection/investigation:
  • Collect personal breathing zone samples when tasks listed in Table 1 are not being fully and properly implemented or if required by their flowcharts.  See below Flowcharts A and B that will be used in OSHA's memo.
  • Review the employer's written silica Exposure Control Plan and other relevant programs (e.g., respiratory protection program, hazard communication program, etc.) as part of the investigation.)  Members of MCAA can create a plan/policy by clicking here.
  • Interview affected employees, including the competent person, as part of the overall assessment of the employer's implementation of its Exposure Control Plan.
• OSHA addressed Housekeeping Practices (paragraph f)
  • Sweeping compounds (e.g., non-grit, oil- or waxed-based) are approved as a housekeeping method
  • The use of compressed air for cleaning is allowed where the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air, or where no alternative method is feasible.
  • The employer's exposure control plan must include the description of the housekeeping measures.
• Employees who will be required a respirator for 30 or more days a year applies per employer. Any partial day of respirator use (even if for only one hour or less) is considered one day of respirator use for the purposes of medical surveillance requirements.   
• OSHA revoked their National Emphasis Program on Crystalline Silica which provided guidance to CSHOs for targeting inspections of jobsites with the potential to generate elevated exposures to crystalline silica.

For more information on how you can comply with this new rule please visit our Silica Solutions page or contact us.  We're happy to help you find the solutions you need to stay safe and productive by offering free consultations and a full line of dust collectors and wet saws.

Post by:  Elizabeth "Liz" Graves, Sales Manager at Spec Rents, LLC.  Contact Liz at lizg@specrents.com

Voluntary Respiratory Protection

With the updated silica regulation in effect, there are still a lot of questions out there.  I'm asked all the time, "If my guys are not required to wear a respirator, can they still wear a dust mask if they want to without having to do fit testing and medical testing?"

3M 8210 N95 Respirator

And I never have a straight answer for that.  Here's why:

• Are employees wearing a dust mask or a respirator?  Because there's a difference.

  • A N95, usually referred to as a "two-strap dust mask" is actually a respirator.

  • Usually dust masks have one strap.

  • A dust mask is not NIOSH approved.

• What are the employees doing?  Make sure that what they're doing really doesn't require them to wear one. 

  • If you're following Table 1 and it requires the employee to wear a dust mask, then you had better be requiring them to wear one.  See below. 

  • If you're not following Table 1, do you have the data to show that they are under the PEL and don't need one? 

    • For example, if you're mixing mud, you might be able to get this from your suppliers (I know Amerimix and Spec Mix both have some objective data they can share with you).

    • Or, if you've done your own testing that shows you're under the PEL for specific tasks, this should be sufficient.

• If you're sure they are doing a task that they don't need a mask for but they still want to wear one, they can. But there are a few considerations:

  • They still should know how to use it. For example:

    • If it's a N95, it is a "disposable respirator" that should be disposed of after use or when it becomes damaged or soiled.

    • If it's a N95, you can't clean or disinfect it.

  • The employer must ensure that use of the respirator follows these requirements:

    • It must be clean- not dirty or contaminated (safest option is to give each employee a new one daily or more often if necessary)

    • It will not interfere with employee's ability to work safely (this could mean that it interferes with another piece of PPE or limits their vision).

    • See a letter of interpretation from OSHA about respiratory protection dated November 22, 2011 for more information about voluntary use of respirators. 

  • The employer must provide the information in Appendix D to each voluntary wearer.

    • Download Appendix D in English and Spanish

    • I recommend having employees acknowledge receipt of Appendix D. 

      • The perfect place for this is in your new employee packet. 

      • For those already employed, a "tool box talk" could allow employees a time to complete and sign acknowledgement forms during silica training.

  • Make sure that you have trained your employees the difference between when they are required and not required to wear a respirator. 

  • Make sure they know they are wearing them voluntarily if not required.  

    • OSHA will likely ask any employee wearing a respirator if they have been fit tested and gone through a medical examination, along with whether they know about your respiratory protection program. 

REMEMBER:  There are likely still some tasks in Table 1 that require use of a respirator unless you have objective data or have done testing that shows the task performed is under the limit.  A few common ones for masonry are:

• Using a wet handheld power saw (any blade diameter) 

  • APF 10:  Outside for more than 4 hours

  • APF 10:  Inside, no matter how long

• Using a handheld grinder for mortar removal (i.e. tuckpointing) with dust collection system.  See Back to the Grind:  Using Grinders according to Table 1 for more information about grinders.

  • APF 10: Outside or Inside for 4 or less hours

  • APF 25:  Outside or Inside for 4 or more hours

NOTE:  this is NOT all-inclusivelist

Table 1:  Handheld grinders for mortar removal (i.e., tuckpointing)

Thank you to Brandon Boyd, of Salus Consulting Services, who presented to the Associated Masonry Contractors of Houston last week about the new regulations.  Brandon is a great resource should you need help adjusting to these requirements.  His company focuses on helping companies achieve safe, quality production.  You can contact Brandon at bboyd@salusconsultingservices.com or visit www.salusconsultingservices.com.

If you have questions, or if Spec Rents can help you in any way, please contact us.  Please note that this blog or anything on SpecRents.com should be considered legal advice.

Post by:  Elizabeth "Liz" Graves, Sales Manager at Spec Rents, LLC.  Contact Liz at lizg@specrents.com