The Dusty Task Setup SOP

Purpose

Every cut, grind, drill or sand inside an occupied home starts the same way: material identified before a tool touches it, the control taken from the shop plan, the house sealed off, and the mess cleaned without putting it back in the air. Without it the two failures are predictable: the tech breathes the dust because the vacuum filter loaded up halfway through, and the customer breathes it for a week because the furnace fan carried it to every room and the cleanup was a broom.

Scope

Covers: dust-generating work by shop employees in or on a customer's home: drilling, coring, cutting and grinding concrete, block, brick, stone, tile and engineered stone; sanding and cutting drywall and wood.

Does not cover: painted surfaces in a pre-1978 home beyond identifying them in Step 1 (the lead renovation procedure owns them); suspect asbestos material, which this SOP stops at and nobody disturbs; writing the silica plan or the Table 1 detail (owned by the Silica Exposure Control Plan SOP and the Table 1 card); and fabrication at the shop, which is general industry under 29 CFR 1910.1053 with no Table 1, while field work in a home is construction under 29 CFR 1926.1153.

Roles and responsibilities

Procedure

Step 1: Identify the material and the house's age before any tool comes out

Action: name the material you will disturb and record the year the house was built. Look past the surface: drywall over block, paint over plaster. Note any suspect asbestos material in the area even if you are not touching it (9-inch floor tile, textured ceilings, pipe wrap, joint compound in a house built before about 1981).

Acceptance: the ticket names the material and the build year, and every suspect material in the area is noted as either "not disturbed" or "tested, result on file."

Wrong looks like: "wall" as the material. Stop rule: suspect asbestos in the path of the tool, stop and do not disturb it until an accredited inspector has sampled it; a painted surface in a pre-1978 house, presume lead unless an EPA-recognized test or a certified inspector says otherwise, and hand off to the lead procedure.

Hazard: none from looking. Scraping a corner "to see what is under the paint" is a disturbance.

Step 2: Choose the control from the plan and write the line on the ticket

Action: find the task on Table 1 of 29 CFR 1926.1153 through the shop's plan and estimate how long the tool will run today; several lines change at four hours in a shift, and several change indoors.

Acceptance: the ticket carries the Table 1 entry (for example, "handheld drill, shroud plus vacuum, no respirator") and the expected duration in hours; or, for a task not on Table 1, a pointer to its exposure data in the shop's file.

Wrong looks like: "use the vac" with no entry and no time. Stop rule: a task not on Table 1 with no assessment data does not start; call the competent person.

Hazard: none at this step, it is a decision made before arriving.

Step 3: Clear and seal the space

Action: get the customer, children and pets out of the work area. Set the thermostat to off with the fan off, not on "auto," and record the setting you found. Cover every supply and return register in the room. Hang plastic sheeting to enclose the work zone with a flap at the doorway, and lay floor protection.

Acceptance: thermostat setting recorded and the system off; every register in the room covered; nobody inside the containment but the crew.

Wrong looks like: the blower running, or a return grille open inside the containment, which delivers the dust to every bedroom. Stop rule: a fuel-burning appliance inside the planned containment, do not seal it in; move the boundary so the appliance and its combustion air sit outside it, or turn the appliance off per its manufacturer and restore it in Step 9.

Hazard: ladder work at the ceiling (three points of contact, feet off loose drop cloth); never tape plastic over a panel, a gas valve or the only exit.

Step 4: Set up and prove the capture or wet method

Action: for capture, fit the shroud that matches the bit or blade, clamp the hose at both ends, and confirm the vacuum is one Table 1 accepts (filter at least 99 percent efficient, with a filter-cleaning mechanism and, where the entry requires it, a cyclonic pre-separator). For a wet method, connect the water feed and set up to hold the slurry. Before the first hole, inspect the shroud for cracks and prove suction at the material: tool to the wall, vacuum running, a tissue strip pulled flat against the shroud opening.

Acceptance: suction proved at the shroud; or, wet, water reaching the blade continuously and the tool plugged into a GFCI that tripped on its test button and reset.

Wrong looks like: a slack hose, a vacuum pitch that climbs at the wall, water dribbling. Stop rule: no proven suction, no proven GFCI, no work; a portable GFCI cord tested on site is an acceptable fix, an untested one is not.

Hazard: water plus electricity on a wet method: cords off the wet floor, and the GFCI tested at the outlet you are using.

Step 5: Put on what the Table 1 line requires, and only through the program

Action: eye protection always, hearing protection for a rotary hammer or grinder, gloves against alkaline slurry. If the Table 1 line for this task and duration calls for a respirator, it is worn only by a tech in the shop's written program under 29 CFR 1910.134: medically evaluated, fit-tested within the last 12 months on that model, and passing a user seal check now.

Acceptance: the respirator column for this line reads "none," or reads APF 10 and the wearer is in the program and passed the seal check today.

Wrong looks like: a disposable mask on a helper never fitted. Stop rule: a task that needs a respirator and a tech who is not in the program, he does not do the task.

Hazard: a respirator does not replace the capture tool; Table 1 assumes both.

Step 6: Do the work and watch the point of contact

Action: before the first hole or cut, scan for what is inside the material: conduit, pipe, radiant tubing, and in a post-tensioned slab, the tendons, which nobody drills without the slab's drawings or a locate. Then work, pulsing the filter at the maker's interval or whenever suction drops, watching the shroud and a work light's beam.

Acceptance: no dust visible escaping at the shroud or blade, and none rising in the light beam, for the length of the task.

Wrong looks like: gray dust at the shroud lip, haze in the beam. Stop rule: let off immediately, check the vacuum is running, pulse the filter, check the shroud seal and the shroud itself for cracks, and resume only when no dust shows. If you cannot stop it, stop the task and call the competent person.

Hazard: a rotary hammer binding on rebar wrenches the wrist (side handle on, clutch set); grinder kickback (guard on, both hands, no standing in line with the disc).

Step 7: Clean without putting the dust back in the air

Action: HEPA-vacuum every surface inside the containment, top down, then wet-wipe. No dry sweeping, brushing or compressed air: the housekeeping paragraph of 29 CFR 1926.1153 bars them where they could add to exposure, with narrow exceptions (no feasible wet or HEPA method; compressed air only with a capturing ventilation system). Anyone who wore a respirator for the task keeps it on for cleanup.

Acceptance: no visible dust on any horizontal surface, and a white cloth wiped over one square foot of floor at the work face comes up without gray.

Stop rule: gray on the cloth, clean again and re-wipe; dust outside the containment, extend the cleanup to it before Step 8.

Hazard: cleanup re-suspends the fine fraction; it is exposure, not housekeeping.

Step 8: Empty, bag and take down

Action: empty the vacuum or change its bag outdoors, downwind of the house and away from open windows, wearing a respirator under the program. Twist, fold and tape the bag neck. Fold the sheeting dirty side in and bag it.

Acceptance: every bag sealed; sheeting folded inward with no tear; nothing dusty rides in the truck cab.

Wrong looks like: tapping a filter clean on the tailgate. Stop rule: nobody in the program on site, the vacuum goes back sealed for the shop to empty.

Hazard: emptying concentrates the day's dust into one minute of handling, the highest exposure on the job.

Step 9: Restore the house and hand it back

Action: remove the register covers, restore the thermostat setting recorded in Step 3, and restart anything turned off. A fuel-burning appliance turned off in Step 3 is relit per its manufacturer and proved: burners lit, venting drafting, and a combustion check per the shop's CO procedure.

Acceptance: thermostat at the recorded setting and the system running; any appliance turned off is restored and proved.

Stop rule: an appliance that will not relight or fails its combustion check stays off and red-tagged, with the customer told in plain words.

Hazard: a relit appliance with a disturbed flue is a carbon monoxide hazard; the proof in this step is the test, not the restart.

The record this produces

One block on the job record: material and build year; suspect materials and their disposition; the Table 1 line with expected and actual run time in hours; the suction or GFCI proof; PPE and any respirator wearer's program status; every stop rule taken, at which step, and the fix; the wipe result; waste disposition; the restore check. The competent person reads these weekly; a stop rule that keeps recurring is a finding about the equipment, not the tech.

Worked pass: a basement water treatment rack

A 1968 house. Fourteen anchor holes, 3/8 inch by 2-1/2 inches, in an unpainted poured foundation wall for a softener rack.

• Step 1, pass. Material: unpainted poured concrete; built 1968. 9-inch floor tile noted, not disturbed, drop cloths laid loose rather than taped to it.
• Step 2, pass. Table 1, handheld drill, shroud plus vacuum, no respirator. Expected run time under 1 hour.
• Step 3, pass. Gas furnace and water heater 12 feet away, outside an 8 by 6 foot containment. Thermostat found at heat 68, fan auto; set to off. One return grille in the basement, covered.
• Step 4, pass. Shroud matched to the bit and looked over, hose clamped, tissue strip pulled flat.
• Step 5, pass. Glasses and earmuffs. Line reads no respirator. Lead tech, in the program, carries a half mask for Step 8.
• Step 6, fail at hole 9. Scan showed no conduit or pipe in the drilling zone. Holes 1 to 8 ran clean. At hole 9 gray dust showed at the shroud lip. He let off, confirmed the vacuum running, pulsed the filter, and still saw dust on restart. The shroud had a hairline crack at the lip from an earlier drop, missed at Step 4. He swapped in the spare from the truck, proved suction again, and drilled holes 10 to 14 with no dust showing. Nine holes before the swap plus five after is the fourteen on the ticket. Stop rule logged.
• Step 7, pass on the second wipe. First white-cloth wipe at the wall base came up gray; re-vacuumed and re-wiped, clean.
• Step 8, pass. Vacuum emptied in the driveway, downwind, half mask on, bag sealed.
• Step 9, pass. Covers off, thermostat back to heat 68, fan auto; furnace ran a cycle. No appliance had been turned off.

The competent person's fix: spare shrouds ride on every truck, and the Step 4 look is done with the shroud flexed, which opens a hairline crack.

References

• 29 CFR 1926.1153, Respirable Crystalline Silica (construction): Table 1, housekeeping, written exposure control plan and competent person; 29 CFR 1910.1053 for general industry
• 29 CFR 1910.134, Respiratory Protection
• See related: The Silica Exposure Control Plan SOP
• See related: How to Follow Table 1 When You Core or Grind Concrete
• See related: The Hierarchy of Controls on a Service Call