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The Occupational Safety and Health Administration is requiring businesses to step up their safety programs for workers exposed to respirable silica. The new, stricter regulations officially took effect on September 23.
OSHA recognizes that there are thousands of small businesses in construction and other industries that don't have full-time compliance professionals on staff. They've therefore released two guides for small entities designed to help them quickly bring themselves into compliance with the new regulations.
They are the "Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime" (OSHA 3911 - 2017), and a comparable guide specific to the construction industry, (OSHA 3902 - 2017).
Why the change?
Crystalline silica - the key compound in sand, mortar, cement and stone - is a known carcinogen. Exposure over long periods of time can lead to silicosis, a severe respiratory condition caused by irritation and scarring of lung tissue that kills about 100 people per year.
The new rules significantly lower the allowable crystalline silica exposure limit for workers to 50 micrograms per cubic meter (µg/m3) of air over an 8-hour shift. That's down from the previous exposure limit of 100 µg/m3 for general industry workers, and 250 µg/m3 for construction workers.
The new rules do more than simply reduce the allowable exposure to crystalline silica. They also require employers to actively measure aerial silica levels at the worksite and monitor them over time.
OSHA projects that the new rules will save about 600 lives per year and prevent up to 900 cases of silicosis.
Small construction firms and Table 1
Small construction enterprises should focus their attention on Table 1 in the Silica in Construction Standard. As long as the employer is fully and properly carrying out the recommended controls, practices and protection measures, OSHA will not require small companies to conduct regular exposure tests or adhere to the 50 µg/m3 standard. Documenting compliance with Table 1 is generally considered sufficient.
If employers don't comply with Table 1, enforcement officers in those companies will have to take regular exposure measurements. Inspectors will take personal breathing zone samples on day one of all inspections. Employers will be required to provide air monitoring records and all other measurements relied upon to determine silica exposure levels.
While Table 1 is designed to be a big help for smaller employers for whom regular particle exposure measurements would constitute a hardship, the details of the enforcement of the new standard remain to be seen.
At any rate, all employers whose employees encounter inhalable silica exposure should prepare the following documents:
Initial guidance from OSHA also indicates that dry sweeping and dry brushing clean-up methods are not in compliance unless wet methods, sweeping compounds and HEPA vacuums are not feasible.
Employers that have worksites at which the inhalable silica exposure level surpasses the action level and that rely on dry-sweep methods should be prepared to show why safer methods are not feasible, or why they are relying on respiratory protection gear instead of improving work methods and engineering practices.