By Elizabeth Grossman
Since the White House Office of Management and Budget’s (OMB) Office of Information and Regulatory Affairs (OIRA) began reviewing the Labor Department’s proposed rule to reduce by one-half the permissible workplace exposure to respirable crystalline silica more than two year ago, the US has seen a dramatic increase in industrial sand mining, a major route of workers’ exposure to silica dust. As Celeste Monforton reported for The Pump Handle on March 20th, OIRA’s review of the Occupational Safety and Health Administration’s (OSHA) draft proposed rule crystalline silica exposure has now been going on for more than 800 days. During this time – since 2010 – the amount of industrial sand production in the US has increased more than 50 percent. Industrial sand production is but one of the ways workers can be exposed to the silica dust that can put them at increased risk of developing lung cancer and other lung diseases, including silicosis. Exposures often occur in stonecutting, sandblasting and foundry work, in construction and – spurred by recent growth in natural gas extraction – among workers producing, transporting and using industrial sand in hydraulic fracturing (fracking) operations.
According to the most recent US Geological Survey (USGS) estimates, US industrial sand production jumped an estimated 37% between 2010 and 2011 and another 14% between 2011 and 2012, with approximately 57% of this sand destined in 2011 for US hydraulic fracturing operations. USGS estimates that in 2011, sales of frac sand increased by 77% compared to those in 2010. USGS calls the production and sale of hydraulic fracturing sand the past several years’ “most important driving force in the industrial sand and gravel industry.” USGS put the value of industrial sand production in 2012 at $2.2 billion. While the USGS reporting excludes data from China and several other countries, the US is considered the world’s leading producer and consumer of industrial sand.
Nearly 90% of this industrial sand and gravel came from 72 operations, each of which produced at least 220,000 tons. The top ten producers, USGS reports, are the Unimin Corporation, U.S. Silica, Fairmount Minerals Ltd.; Frac Tech Services International, LLC; Premier Silica, LLC; Badger Mining Corp.; Pattison Sand Co., LLC; Preferred Rocks of Genoa, LLC; Sand Products Corp.; and Cadre Material Products, LLC. These companies are apparently responsible for about 72% of all US industrial sand production. A number of these companies are members of the National Industrial Sand Association (NISA) that, along with Unimin and U.S. Silica, have been lobbying the White House, most recently on March 18, 2013, urging the Administration not to approve OSHA’s proposed more stringent silica exposure standard. Among their arguments is that increasing the protective standard would be too expensive. An analysis by the American Chemistry Council (ACC) puts this cost at upwards of $5 billion annually. Public health experts estimate that 1.7 million US workers are exposed to silica on the job each year, that 7,300 new cases of occupational silicosis are diagnosed annually and that about 200 American workers die each year from silicosis.
ACC and NISA say that exposures can be reduced without lowering the allowed exposure level by implementing dust prevention, exposure and medical assessments, and “employee involvement.” Yet given the current rapid expansion in places where industrial sand is being produced, transported and used, it’s difficult to get a complete picture of where oversight might be needed to ensure proper worker protections.
Individual states leading current industrial sand production in 2012 were – in descending order as reported by USGS – Texas, Illinois, Wisconsin, Minnesota, Arkansas, Missouri, Michigan, and Oklahoma – which together represented 73 % of all US production. Nearly 60% of all frac sand produced in the US currently comes from the Midwest, thanks to what’s called the St. Peter Sandstone formation, and it’s here that industrial sand mining has been particularly active in recent years. A notable footnote to these statistics is the fact that of the 36 states listed as industrial sand producers in 2010 and 2011 (the most recent years for which USGS figures are available), 14 withheld production volume information “to avoid disclosing company proprietary data” in 2010 and 2011. An additional three withheld this information in 2011. States withholding information to protect confidential business information include Iowa, Arkansas, Idaho, Minnesota, Nebraska, Pennsylvania, and West Virginia. Some of the top ten producing industrial sand companies have operations in these states.
More hours, more exposure
All of this adds up to a large increase in the number of hours worked at these sand mining operations. At some facilities, annual hours worked, as reported by the Mine Health and Safety Administration (MSHA), increased markedly between 2010 and 2012. MSHA also reports that more than 700 new industrial sand and gravel mines went into operation in 2010 and 2011 (total 2012 figures are not yet available), a number that dwarfs any other new US mining operations. And as USGS reports, the vast majority of this category of mining is now devoted to industrial sand rather than gravel.
While USGS writes that “Except for temporarily disturbing the immediate area while operations are active, sand and gravel mining usually has limited environmental impact,” it goes on to note that the “increase in frac sand production and sales had a profound effect on the transportation of industrial sand and gravel to sites of first use.” This observation may be important in terms of potential occupational exposure to respirable silica dust, as USGS estimates that in 2011, “of all industrial sand and gravel produced, 65% was transported by truck from the plant to the site of first sale or use, up from 25%” from the amount shipped by truck in 2010. Exactly where this industrial sand goes is less clear. USGS reports that because “some producers did not provide this information, their data were estimated or assigned to the “Destination unknown” category. In 2011, 53% of industrial sand and gravel shipped by producers was assigned to that category.
Meanwhile, nearly a year after the presentation by National Institute of Occupational Health and Safety (NIOSH) researchers that reported on elevated levels of respirable silica exposure at hydraulic fracturing operations where frac sand was in use, a peer-reviewed article based on this information has been published in the Journal of Occupational and Environmental Hygiene. It adds some technical data to the information presented by NIOSH researchers at last April’s Institute of Medicine meeting that was reported on by NIOSH in its science blog, but does not change any conclusions or recommendations – or those of the OSHA/NIOSH Hazard Alert that was issued in June 2012.
Since NIOSH reported on its initial silica dust site studies, no new such studies have been conducted and no additional companies have volunteered to host or participate in such studies, said NIOSH spokesperson Fred Blosser. “We continue to explore opportunities for research and outreach,” Blosser told The Pump Handle. The FOIA request I submitted to NIOSH in June 2012 requesting details on the companies and locations participating in the silica dust studies is still pending.
Reflecting on growing concern about the rapid expansion of industrial sand operations in its 2011 report on silica, USGS writes:
The industrial sand and gravel industry continued to be concerned with safety and health regulations and environmental restrictions in 2012. Local shortages of industrial sand and gravel were expected to continue to increase owing to local zoning regulations and land development alternatives, including ongoing development and permitting of operations producing hydraulic fracturing sand. Operations that use hydraulic fracturing sand to produce hydrocarbons may also undergo increased scrutiny. These situations are expected to cause future sand and gravel operations to be located farther from high-population centers.
The bottom line on all of these statistics appears to be that while US industrial sand production has skyrocketed – increasing about 50% in the past two years – the businesses that produce this material and that use the most of it maintain that it is too costly to improve protection for workers who may be exposed to respirable silica dust, a known lung carcinogen. At the same time there appears to be little progress in expanding information available to workers or the public on where industrial sand is being used in fracking operations, exactly how much of this sand is being produced and where – and how many workers this may put at risk of breathing this dangerous dust.