Silica Dust. It’s Just Dust! I’m not seeing the Issue!
Sam Hawkins Sr. [CSP, ASP, CHST]
Let's Not Meet By Accident!? |OSHA & DOT Compliance Solutions| |Truck Crash Expert Witness|
Since OSHA’s final rule on Occupational Exposure to Crystalline Silica was published in March 2016, I have received many questions on the new provisions to the Standard(s). Surprisingly, most of the questions have not been what can we do to comply with these changes and protect our workers. Instead they have been more along the lines of what is the big deal and why are they making these changes.
Let me first say those questions didn’t come from companies who did not care about their employees. They were companies who were comfortable operating under the previous regulations and needed some clarification on the purpose and effectiveness of the changes. Once explained, they understood and moved toward full compliance. With compliance in these new provisions set to commence on June 23, 2017 for construction (enforcement delayed until September 2017), I thought it would be a good idea to shed a little light on this topic.
Worker deaths in the 1930s gave us some of the first insights on the hazards of respirable crystalline silica (silica). Armed with this information, OSHA set limits on worker exposure to silica dating back to 1971. According to OSHA, “A full review of scientific evidence, industry consensus standards, and extensive stakeholder input provide the basis for the final rule, which was proposed in September 2013. The rule-making process allowed OSHA to solicit input in various forms for nearly a full year. The agency held 14 days of public hearings, during which more than 200 stakeholders presented testimony, and accepted over 2,000 comments, amounting to about 34,000 pages of material. In response to this extensive public engagement, OSHA made substantial changes, including enhanced employer flexibility in choosing how to reduce levels of respirable crystalline silica, while maintaining or improving worker protection.”
Nearly 2 million construction workers experience workplace exposure to respirable crystalline silica. These workers include those who are involved in drilling, cutting, crushing, or grinding silica-containing materials such as concrete and stone. This is not just a construction operations issue. In general industry operations, over 300,000 workers are also exposed to respirable crystalline silica. Those workers involved in operations such as brick manufacturing, foundries, and hydraulic fracturing (fracking).
The intent of these changes is to reduce chances of lung cancer, silicosis, chronic obstructive pulmonary disease and kidney disease by limiting the exposure to respirable crystalline silica of America’s workforce. OSHA anticipates these rule changes will save over 600 lives and prevent more than 900 new cases of silica exposure annually.
Key Provisions under the Construction Standard
- The standard requires employers to limit worker exposures to respirable crystalline silica and to take other steps to protect workers.
- The standard provides flexible alternatives. Employers can either use a control method laid out in Table 1 (can be found on OSHA’s website) 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.
- 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.
Key Provisions under the General Industry Standard and Maritime Standard
- The standard for general industry and maritime requires employers to:
- Measure the amount of silica that workers are exposed to if it may be at or above an action level of 25 μg/m3 (micrograms of silica per cubic meter of air), averaged over an 8-hour day;
- Protect workers from respirable crystalline silica exposures above the permissible exposure limit of 50 μg/m3, averaged over an 8-hour day;
- Limit workers’ access to areas where they could be exposed above the PEL;
- Use dust controls to protect workers from silica exposures above the PEL;
- Provide respirators to workers when dust controls cannot limit exposures to the PEL;
- Restrict housekeeping practices that expose workers to silica where feasible alternatives are available;
- Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers;
- Offer medical exams — including chest X-rays and lung function tests — every three years for workers exposed at or above the action level for 30 or more days per year;
- Train workers on work operations that result in silica exposure and ways to limit exposure; and
- Keep records of workers’ silica exposure and medical exams.
This is not a full break down of the standard(s) changes. It is intended to help employers and workers understand the hazards associated with exposure to respirable crystalline silica, the reason for the revisions, and the requirements under this final rule.
Additional information on OSHA’s silica rule can be found at www.osha.gov/silica. OSHA provides information on this regulation, tables to assist in compliance, and a variety of programs to help employers comply with the final rule.
I hope this helps at least one company and/or worker get a better understanding of OSHA’s final rule on Occupational Exposure to Crystalline Silica.
“Let’s Not Meet By Accident!”
Remote EHS Professional | Navy Veteran | World Construction
7 年Good Article Sam.