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Opinion: Impact of silica regs on tire & rubber industry

The presence of airborne silica particles in the factory environment is a key concern for the tire and rubber industry, as inhalation can leave workers at risk of serious and potentially fatal respiratory illnesses.

Anh-Tai Vuong
Written By Anh-Tai Vuong President of DuroVac
Tire Manufacturer
Nov 2019
Erj
Article originally published on European Rubber Journal
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The presence of airborne silica particles in the factory environment is a key concern for the tire and rubber industry, as inhalation can leave workers at risk of serious and potentially fatal respiratory illnesses.

In the EU, regulations for minimising the risk posed by respirable silica have been changed, particularly by the replacement of outdated occupational exposure limits (OEL’s) for airborne silica particles.

According to SafeSilica, EU regulatory bodies set the legal RCS occupational exposure limit to 0.1 mg/m3 in industrial workplaces (also written as 100 μg/m3).

While this level still poses a risk, it’s the lowest reasonable level that can be achieved through engineering controls and reflects a step in the right direction for employee health and safety.

Methods of gathering air quality data are much simpler now and no longer depend on the concentration of silica. The new focus on the respirable fraction of silica makes it easier to identify at-risk areas and implement safety measures.

NEPSI, an EU-funded union, has been defending workers’ rights and ensuring proper silica practice in high-risk occupations. Updated last year, ‘NEPSI 2.0’ aims to improve the quality of implementation and enforcement to ensure more lives are saved.

Within new European guidelines for addressing exposure risks, employers must:

In an attempt to improve adherence, in the UK you can face a fine of up to £20,000 or six-months imprisonment for failing to meet the standard. Crown court sentencing can even lead to an unlimited fine or two years imprisonment for serious violations.

Limiting the dissemination of rubber dust and fumes during the manufacturing process is key and steps should be taken to limit airborne particles, to avoid these stricter penalties.

Mistakes being made

A recent notable case in the UK is that of Terry McGough, who was left fighting for his life after falling ill with silicosis. Criminal safety breaches were found in Stonyhurst College, Clitheroe, which led to a ‘six-figure fine’.

European guidelines are typically more advisory than compulsory, making compliance challenging.

However, EU regulators can take heed of US agency OSHA, which recorded 117 violations within a year of rolling out stricter compliance guidelines – with 80% of them considered “serious” and resulting in hefty fines.

Companies should make compliance with regulations a priority, not just to avoid penalties but to fulfil their responsibility towards employee-safety.

In many cases, the most important steps are those being overlooked by non-compliant companies, including:

- Ensuring you have a written exposure plan – companies often have appropriate measures in place, but cannot provide evidence of actionable steps

- Providing adequate silica mitigation training – making sure employees know appropriate practice e.g. operation of ventilation machinery

- Frequent air monitoring – making sure conditions do not exceed the OEL

Additional steps employers should take to ensure staff safety include investing in the right equipment, so workplaces are cleaned to a high professional standard. Consider industrial vacuums with a HEPA filter, as these remove more than 99.97% of dust particles down to 0.3 microns in size.

In many cases, being trained in silica safety and practice is enough to satisfy regulatory officials.

However, employers must also prepare clear and actionable internal safety plans, adapted to their own workplaces, in the case of potential accidents or an area becoming dangerously contaminated.

Employees should be given regular training in dealing with new risks, such as spills or toxic levels of airborne dust.

Visual aids, particularly in areas of high concentrations of dust, can also be used as reminders of the importance of maintaining these stricter safety standards.