Sarkis G. Ampian
Published: 1992
Total Pages: 36
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In 1987, the International Agency for Research Against Cancer conducted a review of the health literature and concluded that crystalline silica was a probable human carcinogen. As a result of this finding, OSHA was required to regulate crystalline silica under its Hazard Communication Standard (HCS). The standard requires that all materials handled by OSHA-regulated facilities be labeled according to the requirements of HCS and that workers receive proper training on the handling of the material if the crystalline silica content equals or exceeds 0.1 weight percent (0.1%). MSHA currently is considering enacting its own HCS. This will be similar to OSHA's HCS. If the standard is enacted, most mineral producers will have to determine the respirable monitor filter and bulk crystalline silica contents of their ores and products so that workers and/or customers will know whether they are in compliance with the 0.1% HCS and/ or the OSHA permissible exposure level (PEL) of 50 micro-g for an 8-hour workday for respirable crystalline silica as determined from monitor samples. Two major concerns with the HCS are the widespread occurrence of crystalline silica in nature and the suitability of current technology for routinely determining crystalline silica concentrations at the 0.1% HCS level. Most ores are extracted from silica-bearing deposits, and silica is a common constituent of rocks and soils. OSHA's HCS will have the greatest impact on the producers of crushed stone, diatomite, dimension stone, gravel, industrial sand, perlite, pumice, pyrophyllite, sand, and talc because these materials frequently are shipped directly from the mill to the customer. MSHA's HCS would affect nearly all mineral producers. Those producers that have crystalline silica present in concentrations near the 0.1% cutoff point will have the most difficulty with the analysis. Crystalline silica can be quantified at the 0.1% level by X-ray difractometry in simple systems containing one, two, and possibly three minerals if (l) none of the accessory minerals has X-ray diffraction reflections that coincide or overlap with those of crystalline silica and (2) the standard has a particle size distribution and crystallinity similar to those of the sample. In some instances, it may not be possible to determine the crystalline silica content of a sample with any degree of certainty using the recommended regulatory protocol. In all cases, it is recommended that a qualified mineralogist identify the minerals in a sample prior to any regulatory analysis. Additionally, the uncertainty as to whether some silica polymorphs should be classified as crystalline or noncrystalline and the suitability of metastable high-temperature standards, such as cristobalite and tridymite, for regulatory analysis at ambient temperatures should be addressed further. This overview is written both to highlight these problems and to serve as a guide for analysts, regulators, and industry personnel who are involved in the crystalline silica issue. It also covers some of the difficulties and/or shortcomings in quantifying crystalline silica, such as the ubiquitous mineral quartz, in the workplace.