New Silica Standard
Tuesday, October 3rd, 2017
OSHA passed a new standard regulating exposure to silica in 2015. When it was passed the construction industry had an effective date of June 23, 2017. The Trump administration delayed that date by another 90 days moving it to September 23, 2017. OSHA has also communicated a memo to regional directors that they will not issue citations or penalties to contractors who have started the process of implementing compliance to the standard.
OSHA has reduced the 8-hour time-weighted averaged (TWA) Permissible Exposure Limit (PEL) exposure from 250 micrograms per cubic meter (μg/m3) to 50 μg/m3. They also established an Action Level (AL) of 25 μg/m3.
As of September 23, 2017 Contractors who work with concrete, masonry and other construction related activities are:
- Required to have employees trained to the dangers of silica including: health hazards of silica, what activities could result in silica exposure, methods to control silica exposure, contents of the silica standard (29 CFR 1926.1153), provide instruction in accordance with the hazard communication standard on silica, the identity of the designated competent person(s), the purpose and description of the medical surveillance program used by the employer, and a copy of the standard shall be provided at the employer's cost, to the employee.
- The competent person shall be totally familiar with all aspects of the standard.
- The employer shall perform initial 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 in order to meet this requirement. In representative sampling, the employer shall sample the employee(s) who are expected to have the highest exposure to respirable crystalline silica.
- Employers are required to develop an exposure control plan (ECP). The ECP identifies the tasks that an employer will perform on a project where those activities may result in an exposure, engineering and administrative controls used to minimize exposure below the PEL housekeeping methods, respiratory protection, medical surveillance, and it needs to made site-specific. A copy should be made to any employee who requests a copy.
- Table I (29 CFR 1926.1153(c)(1)) has been developed for construction, and if contractors use this method, all engineering and respiratory protection measures must be taken. There are many manufacturers that have developed products to capture silica-laden dust.
- In the event that a task is not listed, then objective data and/or an exposure assessment (the same as initial monitoring) can be used to determine exposure. If TWA concentrations are less than the Action Level (25 μg/m3) than air monitoring can be discontinued.
- For employees exposed to concentrations greater than the PEL of 50 μg/m3 a medical surveillance program shall be implemented.