OSHA’s Respirable Crystalline Silica Rule: Construction

On September 23, 2017, construction employers are expected to comply with all of the requirements of OSHA’s new Respirable Crystalline Silica rule. In short, contractors who engage in activities that create respirable silica dust through tasks such as cutting, grinding or blasting materials like concrete, stone and brick, must limit worker exposure to silica and take other steps to protect workers. The same goes for employers of tradespeople working around such activities.

Under the new silica standard, the key provision for construction employers is to reduce the permissible exposure limit (PEL) for respirable crystalline silica to 50 micrograms per cubic meter (μg/m3) of air, averaged over an 8-hour shift – with an Action Level (AL) of 25 μg/m3. Employers can either use a control method laid out in Table 1 of the construction standard, or they can measure workers’ exposure to silica and independently decide which dust controls work best to limit exposures to the PEL in their workplaces.

So, what to do:
Basically, there are three options when it comes to employers who have a potential exposure. Below is a short description of each:

  1. Table 1 Option – This option requires “for each employee engaged in a task identified on Table 1, the employer shall fully and properly implement the engineering controls, work practices, and respiratory protection specified for the task on Table 1.” Essentially, the table lists what type of equipment/PPE must be used to be compliant – such as HEPA vacuums on saws and other tools. The pro side to this that it’s easy to follow – the con side is that retrofitting or purchasing new tools could be quite expensive.
  2. Performance Option – OSHA says employers can use “any combination of air monitoring data or objective data sufficient to accurately characterize employee exposures to respirable crystalline silica,” but “when using the performance option, the burden is on the employer to demonstrate that the data accurately characterize employee exposure.”
  3. Scheduled Monitoring Option – OSHA says the employer can perform “monitoring to assess the 8-hour TWA exposure for each employee on the basis of one or more personal breathing zone air samples that reflect the exposures of employees on each shift, for each job classification, in each work area. Where several employees perform the same tasks on the same shift and in the same work area, the employer may sample a representative fraction of these employees.” If the data demonstrates that levels are below the action limit, then you are presumably compliant with the standard. If the data is above the AL or PEL, then additional actions and/or sampling is required.

Regardless of which exposure control method is used, all construction employers covered by the standard are required to:

  • Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur.
  • Designate a competent person to implement the written exposure control plan.
  • Restrict housekeeping practices that expose workers to silica where feasible alternatives are available.
  • Offer medical exams, including chest X-rays and lung function tests, every three years for workers who are required by the standard to wear a respirator for 30 or more days per year.
  • Train workers on work operations that result in silica exposure and ways to limit exposure.
  • Keep records of workers’ silica exposure and medical exams.

Visit OSHA’s Silica webpage for more information. For questions and/or more information about this brief, contact your Vista Safety Representative:

Roger M. Paveza, CRIS President
847.951.7544 roger@vistasafetyconsulting.com

Kyle Cochran, CSP Sr. Vice President
812.201.7150 kyle@vistasafetyconsulting.com

Eric A. White, CHST, CRIS Sr. Vice President
708.560.6244 eric@vistasafetyconsulting.com

Muhummad Starks Safety Consultant
720.937.5087 mstarks@vistasafetyconsulting.com

Any information and/or recommendations contained herein have been compiled from sources believed to be reliable and represent the best current opinion on the subject. No warranty, guarantee, or representation is made by Vista Safety Consulting, LLC as to the absolute correctness or sufficiency of any information contained herein. This information is advisory and designed to assist clients with the implementation, management, and control of their own safety program and activities. Vista Safety Consulting, LLC assumes no responsibility for the implementation, correction, or control of any conditions or recommendations identified herein, and is thereby not liable for any health and safety violation(s) and/or injuries on a site.

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