Respirable Crystalline Silica: Establish and Implement a Written Exposure Control Plan (ECP)

Respirable Crystalline Silica: Establish and Implement a Written Exposure Control Plan (ECP)

It has almost been one year since OSHA (Occupational Safety and Health Administration) began enforcement of its final rule regarding Crystalline Silica Exposure (June 23, 2018). As stated in an article that ran in Texas Asphalt Pavement Association‘s (TXAPA) publication, Texas Asphalt Magazine, this ruling has implications for general industry, maritime, and construction. Westward Environmental’s Bob Huddleston and Natalie Pless paint a picture of why crystalline silica can be a stealthy health risk if not properly and proactively addressed.

This article is to help employers establish and implement a written control plan that identifies tasks involving silica exposure and methods to ensure workers are protected. Each component of the plan needs to ensure compliance and must follow state and federal regulations.

The standards set a new Permissible Exposure Limit (PEL) of 50 micrograms of respirable crystalline silica per cubic meter of air (50.0μg/m3) as an 8-hour Time-Weighted Average (TWA) and an Action Level (AL) of 25μg/m3 as an 8-hour TWA. Employers must assess the 8-hour TWA exposure for each employee who is or may reasonably be expected to be exposed to respirable crystalline silica and ensure no employee is exposed above the AL. If employee exposures are above, or may under foreseeable conditions be above, the AL the standard requires the employer to establish and implement a written Exposure Control Plan (ECP). Not covered under the standards are tasks and operations where exposures will be below the AL “under any foreseeable conditions.”

An ECP for construction, maritime, or general industry, must contain, at a minimum, the following elements:

  • A description of the tasks in the workplace that involve exposure to respirable silica. The plan must identify all tasks that could possibly result in any exposure to silica. The description should also include any workplace factors that may affect the potential for exposure for each task. For example, it could describe the types or amount of silica contained in any materials used in the task; if weather conditions could affect exposure levels, or the location of each task (indoors, outdoors, etc.), and the type of equipment used to perform the task. The detail used to describe a specific task can be minimal but using a generally broad term to describe a task as “construction” or “demolition” will not be enough detail to pass as a description.
  • Engineering controls, work practices and respiratory protection used to limit employee exposure to respirable crystalline silica for each task. The silica standards include requirements for the use of engineering controls and workplace practices to keep exposure levels at or below the new PEL. Employers may not rely on respirators as the only means of controlling employees’ exposure. Employers must make efforts to keep silica out of the air, and these efforts must be described in the ECP.

For each task that could involve silica exposure, the plan should describe the engineering controls the employer uses to minimize or eliminate silica exposure. Controls may include ventilation and vacuuming systems, isolation, processes for watering down workplace operations, and any other means of keeping silica out of the air. The plan should also include effective work practices for using these control systems, such as instructions for operating the dust controls on a certain piece of equipment used to perform the task, schedules for conducting maintenance checks, and specifications for any required respiratory protection.

  • Housekeeping measures used to limit employee exposure. Housekeeping requirements only apply where cleaning “could contribute to employee exposure to respirable crystalline silica.” In the housekeeping section employers must describe cleaning methods that are acceptable, cleaning methods that are unacceptable, and special instructions that may be necessary to limit exposure to silica while employees perform housekeeping tasks. Specifically, employers should include descriptions of:
  • Cleaning methods the employer permits and prohibits to minimize the generation of airborne silica. Activities, such as dry sweeping, dry brushing and using compressed air, are generally prohibited in areas where they may generate airborne silica. The silica rules require employers to wet sweeping or use filtered vacuuming and other appropriate cleaning methods. The rule does provide some flexibility and the employer may use otherwise prohibited dry methods where no other feasible methods are available;
  • Special instructions for cleaning methods (for example, using local exhaust ventilation if compressed air must be used);
  • Hygiene-related subjects (such as not using compressed air to clean clothing) could also be addressed in this section; and
  • Whether employees must wear a respirator or take any other special precautions while performing a particular housekeeping method.

When there is a change in production, process, control equipment, personnel or work practices, a reassessment of exposures is required. To learn more about silica exposure, visit:

Atlas 14 Update Texas

Atlas 14: Texas Rainfall Frequency Value Updates

In case you missed it, the National Oceanic and Atmospheric Administration (NOAA) released a comprehensive study related to rainfall in Texas and how it impacts flood risks. Known as Atlas 14, the report entails nearly 60 years of new rainfall data consequential to improvements associated with spatial interpolation and mapping, the application of regional frequency analysis, and denser data networks with a greater period of record.

Resource: NOAA


Ultimately, rainfall data from Atlas 14 indicates an increased risk of flooding. Could this new study affect you? If you happen to live or do business near Austin, Houston, or San Antonio, it just might. In light of this new data, city officials have recognized that the increased risk of flooding has a vast impact on varying attributes within their cities, such as: people; property; flood insurance; development; remodeling; pipes; ponds; and flood walls. In accordance with the release of Atlas 14, the city of Austin has taken steps towards redefining their previous definition of the 100-year storm; increasing their rainfall intensity threshold from 10.2 inches to 13+ inches,  which is their current definition of a 500-year storm. In addition, the city of Houston has updated their floodplain maps, and the city of San Antonio has updated their floodplain mapping and guidelines of what is required when developing within the floodplain.


Westward’s engineers, environmental compliance specialists, and ecologists use this data to help clients in infrastructure design and flood risk management. Click on the link for more details or reach out to us to learn more.

Frac Sand in Places Not Called West Texas (Part 2)

Frac Sand in Places Not Called West Texas (Part 2)

As a continuation of an article by Michelle M. Lee, PG, we look at the 29 counties highlighted, five of nine different geologic formations/deposits represented, and the basins in which they are located. Originally published by Infill Thinking

The 29 counties highlighted above represent 10 different geologic formations/deposits, and the (basin) they are located in.  Here is summary of the frac sand locations we have explored/sampled since 2015:

There are certain inherent physical traits that give a formation the potential to be a frac sand source such as silica content, roundness/sphericity, crush, etc., but you know that already.  Let’s briefly discuss our field observations of several of these formations listed above.  Disclaimer: the discussion below is based on our field observations during exploration and some limited testing.  Only an analytical laboratory can determine actual sand quality.

Permian Dune Sand – Permian Basin (all members)

Here is a summary of our exploration effort in this area since February 2017:

Borings Sampled Drilled Acres
995 ~67,258 ft. ~76,795 ft. ~176,358

Based on our observations, we found that the physical characteristics of the sand and grain size, varied very little across the region.  Of the gradation and crush results provided to us, there was also little variation observed across the board.  Here are some overall averages of the deposit:

40/70 ~46% 5k – 7k
70/140 ~50% 7k – 9k

*after washing, not all test results reviewed and averaged

What did vary a lot was the matrix materials the sand was in such as caliche, silt & clay.  This greatly affected the waste factor for the deposit as those matrix materials were washed out.  The deepest boring we drilled had sand, as the first or second most abundant ingredient observed in the sample, to 160 ft. with little to no overburden in many cases.

Permian Basin Dune Sand Samples

Carrizo Sand – Eagle Ford

Borings Sampled Drilled Acres
85 ~7,922 ft. ~8,389 ft. ~8,187

Based on our field observations, this formation appears to contain coarser, angular intervals and more silt than the Permian Dune Sand.  Lots of secondary matrix materials create a higher wash loss.  The coarser intervals were scattered throughout the deposit which reached over 200 ft. in some locations.  The deepest boring we drilled had sand to 213 ft. with little to no overburden.  The formation becomes more consolidated (solid) as you go west and eventually turns into sandstone.

40/70 42% 4k – 5k
70/140 28% 6k – 7k

*after washing, not all test results reviewed and averaged

Carrizo Sand Sample

Red River – Haynesville

Borings Sampled Drilled Acres
127 ~5,557 ft. ~9,411 ft. ~10,125

This formation is a river deposit and is of totally different origin than the previously discussed groups and as such, the sand is different as is the location of the deposit.   Based on our observations, the sand appeared more rounded and spherical than the Carrizo Sand but there are more secondary minerals and gravel in this deposit that can result in an overall lower silica content.  There is an abundance of coarser material at depth.  The deepest sand and gravel interval was to 103 ft. with varying amounts of overburden ranging from 12 ft. to 80 ft.  River deposits can be hit or miss with regard to where the material is located.

40/70 26% 5k – 6k
70/140 23% 6k – 7k

*after washing, not all test results reviewed and averaged

Red River Samples

Paluxy Sand – Barnett

Borings Sampled Drilled Acres
21 ~1,381 ft. ~2,073 ft. ~578

Located in the DFW Metroplex area, this formation appeared to be very fine-grained and had a considerable amount of silt observed in the matrix.  Some intervals also had a little bit of pyrite (iron oxide) in addition to a slight hydrocarbon odor.  The deepest boring drilled into the Paluxy was 176 ft. at a location that had 63 ft. of limestone-marl overburden.

40/70 ~20% 5k
70/140 ~77% 7k – 8k

*after washing, very limited testing

Paluxy Sand Samples

Hickory Sandstone (Brady Brown) – Various

Borings Sampled Drilled Acres
12 ~2,669 ft. ~2,763 ft. ~880

This formation is a solid sandstone and is divided into three members (Upper, Middle & Lower) of which only one (Lower) is economically feasible to recover frac sand from.  Being on the very fringe of the Llano Uplift complicates mining in some locations due to the presence of steeply dipping sandstone beds overlying schist and granite.  The formation is poorly sorted with a good amount of coarse size sand but it is very rounded and spherical.  Blasting and crushing is required.  The deepest depth of the Lower member cored was 411 ft.

40/70 ~27% 3k – 6k
70/140 ~21% 4k – 6k

*after washing, not all test results reviewed and averaged

Hickory Sandstone (Brady Brown) Samples

Frac Sand in Places Not Called West Texas (Part 1)

Frac Sand in Places Not Called West Texas (Part 1)

Frac sand exploration has been a main focus of Westward’s Geology department since 2015. Since that time, almost 1,300 borings have been drilled over 200,000 acres across 6 states in more than 10 different deposits specifically for frac sand. In-basin sand is here to stay. But not all deposits are created equal and not all sand is suitable for fracing. Michelle M. Lee, PG, Senior Geologist, shares Westward’s geologic exploration efforts in this series of articles, as featured in Infill Thinking.

Once unassuming sand dunes were a playground for many and a nuisance for many others. But that changed in early 2017 and in a big way. As operators in the Permian Basin discovered, the sand under their feet was ‘good enough’ to use in lieu of the Northern White Sand (NWS) shipped from 1,300 miles to the north, the ‘In-Basin Frac Sand Frenzy’ was born. Then it shifted into hyperdrive.

Westward Environmental has been exploring, engineering and permitting frac sand locations across the southern half of the US almost exclusively for the last four years. And in that time, we have been fortunate enough to see a deposit or two in other places not called West Texas.

The evolution of in-basin sand has been the catalyst of change for many in seemingly similar ways.  It forced everyone to take something marginal and make it great. Initially it was the shift from coarser 30/50 range to the finer mesh sizes that were creating more value to the end users. Then it was the uber smart completion folks who figured out that maybe we don’t necessarily need a 9k crush to be effective in the frac and that you know what, a 5k – 7k sand will work just fine. Next thing you know folks are drilling 7,500 ft. laterals and pumping sand farther than it had ever been before.  Kind of like “Once upon a time, in a lateral far, far away” the sand has indeed become a star. Recently it was reported that  EOG, Exxon & Chevron are going to experiment with 3-mile laterals, which were totally unheard of just a couple of years ago. But then again, using finer mesh sands was almost unheard of just 5 years ago.

Calculating cost savings from using the sand under your feet instead of shipping it from 1,300 miles away soon became ‘good enough’; especially given that 5k – 9k crush 40/140 sand was all over the ground in one of the world’s most prolific basins. Call it what you want, cost effective or cheap, but there was no denying that fracking was going where it hadn’t been before.

Although 2015 wasn’t our first frac sand project, Westward started off the era of finer mesh frac sand exploration in Emery County, Utah, in 2015.  Followed by another large program in Voca, Texas and then Carrizo Springs, Texas after that and so on. February 13, 2017, was the start of the West Texas frenzy that had us drilling with three different crews simultaneously across Ward & Winkler Counties. We tapped the brakes some in December 2018, but that appears to only be temporary. We are still actively drilling in other areas with continued activity in West Texas. Here is a summary of just our frac sand exploration effort from 2015 to February 2019:

Borings Sampled Drilled Acres
1,292 ~91,039 ft. ~110,117 ft. ~208,693

Although 77% of the borings drilled were in West Texas, we found that the Permian Dune Sand wasn’t the only formation that was ‘good enough’.  So the rush was on to locate other sand deposits with similar physical properties in proximity to other oil and gas basins/plays. So where is the oil & gas?  We are all very familiar with this map by the U.S. Energy Information Administration (USEIA) from June 2016:

We know where the oil and gas is, so where is the frac sand?  In a lot of different places actually.  In 2015 the United States Geological Survey (USGS) produced a report titled “Frac sand in the United States – A geographical and industry overview” by Anna B. Wilson & Mary Ellen Benson.  However, this was published at a time when coarse grained reigned supreme and sandstone formations were potential targets.  Here is the Wilson & Benson USGS map for the same area:

These 2015 published locations are in stark contrast to where we have explored for frac sand since then.  Let’s take the USEIA map from 2016 and add other frac sand locations Westward has explored.  The counties colored in yellow are areas where we have drilled solely for frac sand since 2015:

We start the process of locating potential deposits based on a review of published geology using Geographic information Systems (GIS) as a desktop study in conjunction with our exploration knowledge. Our extensive aggregate experience also has provided our clients vital information regarding sand in general, as sand & gravel, and sandstone formations across a good portion of the southern U.S.

The next blog will be a continuation of this article and will examine the 29 counties highlighted above, the 10 different geologic formations/deposits represented, and the basins in which they are located.

Calculating Mine Property Disclosures

Mine Property Disclosures

Securities and Exchange Commission – Modernization of Property Disclosures for Mining Registrants

On February 25th, 2019 the Securities and Exchange Commission’s amendments to modernize the property disclosure requirements for mining registrants went into effect.  The changes rescind Industry Guide 7 and provide new guidance and definitions for property disclosures.  The stated purpose of these amendments is to:

“provide investors with a more comprehensive understanding of a registrant’s mining properties, which should help them make more informed investment decisions. The amendments also will more closely align the Commission’s disclosure requirements and policies for mining properties with current industry and global regulatory practices and standards.”

Registrants subject to mine property disclosures will have until January 1, 2021 to comply with the new rules.  Additional information including the final rule can be accessed and downloaded via the Federal Register or by following the link below.