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OSHA Silica Standard Compliance Date Approaches

In March 2016, OSHA published the final silica rules for construction and general industry. Both standards contained in the final rule took effect on June 23, 2016. Enforcement of the construction industry standard (29 CFR 1926.1153) begins June 23, 2017 and enforcement of the general industry standard (29 CFR 1910.1053) begins June 23, 2018.

OSHA estimates the new standards will prevent approximately 600 new cases of silicosis each year, which is a debilitating, and incurable lung disease. Exposure to silica is also attributed to other diseases including kidney disease and lung cancer. Although silica cases have been declining in the last decade, it remains a serious health hazard in a variety of industries.

Silica is a common mineral found in the earth’s crust. It is found in many products manufactured from natural sand, aggregate and stone, including concrete. Workers can be exposed to silica when cutting, drilling, crushing and grinding natural stone and concrete products. Exposure also occurs when handling silica sand in various industries including foundries, oil and gas (hydraulic fracturing), and glass making.

Reduced Exposure, Different Requirements for Construction and General Industry

OSHA developed one rule for the general industry and one for the construction industry. Both of the rules are similar and include an Action Level of 25 micrograms per cubic meter of air (µg/m3) and a Permissible Exposure Limit (PEL) of 50 µg/m3 (half of the current General Industry PEL), exposure control plan, engineering controls, respiratory protection, training, medical surveillance, and recordkeeping

The construction industry standard includes Table 1:

(https://www.osha.gov/silica/SilicaConstructionRegText.pdf).

The table lists 18 common dust generating activities, corresponding required engineering controls and respiratory protection. The general industry standard allows the use of Table 1, if the activity is temporary and similar to construction industry processes. If construction companies comply with Table 1, they are not required to conduct an exposure assessment. If a process is not listed in Table 1, or employers cannot implement the controls listed in Table 1, the employer must conduct an exposure assessment to determine silica dust concentrations, or utilize objective data. The use of Table 1 is a new approach that has never been published in an OSHA substance specific standard before, which will ease some of the compliance burden for employers.

 

Control Methods Defined

The control methods listed in Table 1 includes “Use saw equipped with integrated water delivery system that continuously feeds water to the blade” and “Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions”. Employers will be responsible to follow the recommended controls in Table 1 including maintaining and using tools and equipment according to the manufacturer’s instructions.

Respiratory protection is required when using some equipment listed in Table 1, when engineering controls are not feasible, and when engineering controls do not reduce exposures below the PEL. The use of respiratory protection must comply with OSHA’s respiratory protection standard found in 1910.134 including selection, fit testing, medical evaluation and training.

Employers are required to develop and implement an exposure control plan that describes the tasks that involve exposure to respirable silica, description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task, and a description of the housekeeping measures used to limit employee exposure to respirable crystalline silica. Dry sweeping silica containing dust is prohibited unless other methods that minimize dust exposure (wet sweeping, HEPA vacuuming) are not feasible. The exposure control plan must be available for employee review upon the request.

A medical surveillance program is required in the construction industry for employees that wear a respirator for 30 or more days per year, and in general industry when employees are exposed above the Action Level for 30 or more days per year. Employees must receive a medical evaluation within the first 30 days of employment and at least every three years thereafter. The examination will include a medical and work history questionnaire, medical examination with emphasis on respiratory system, chest x-ray, pulmonary function test, tuberculosis test, and any other tests recommended by the health care professional.

Wenck’s certified industrial hygienists can help construction and general industry businesses conduct exposure evaluations and develop written exposure control plans. For further information or assistance, please contact Patrick Kinney, pkinney@wenck.com, phone: D 763.252.6846 | C 612.750.7598

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