OSHA'S New Silica Rule
Do your employees use masonry saws, jackhammers, rotary hammers, hammer drills, handheld or vehicle mounted drills, grinders, or milling machines? Do they finish drywall, operate earthmoving equipment, or perform demolition of masonry structures? If so, your company is likely effected by OSHA's new silica rule.
In case you don't know, silica is a natural mineral commonly found in concrete, asphalt, brick, clay, stone, and soil that can cause cancer and other illnesses when inhaled or ingested. The danger of silica exposure has been known longer than you probably realize. The U.S. Department of Labor published a video in 1938 about the hazards of silica exposure.
OSHA's first crack at establishing a silica rule for the construction industry came in 1974 when they published 29 CFR 1926.55. This standard basically prohibited employees from being exposed to various hazardous substances above limits that were set in 1970. The limit for silica at that time was set at 250 mg/m3.
In 1996 OSHA began discussing the need to revise this standard and in 2013 they published a "Notice of Proposed Rulemaking". After a lot of research and debate they finally published a new standard on March 25 (29 CFR 1926.1153). While some feel this is a much needed step toward protecting American workers, many associations have filed formal appeals due to their concern about the ability of some companies to meet the new requirements. Regardless, this rule is set to become effective on June 23 as of now. However, OSHA has delayed the enforcement of this rule until June 23, 2017 in order to give companies time to plan and implement new engineering controls.
Here is a brief overview
of this new standard:
Scope: This standard does not apply to companies whose employees are exposed to 25 mg/m3 of silica or less (averaged over an eight-hour shift). Some tasks that are likely to involve silica exposure under this amount are mixing mortar in a well ventilated area, pouring concrete, and removing concrete formwork.Control Measures: If employees perform tasks that are likely to involve exposure above the "Action Level" of 25 mg/m3 (averaged over an eight-hour shift), then the employer must either implement the pre-approved engineering controls listed in Table 1 of the new standard, or conduct air sampling. If a task involves a fair amount of silica exposure but the task is not listed in Table 1 of the new standard, then sampling must be done. If air sampling is performed and the exposure level is found to be 50 mg/m3 or more (averaged over an eight-hour shift) then respirators must be worn and air monitoring must be repeated at least every three-months thereafter.
Exposure Control Plan: Regardless of which option a company goes with, if their employees perform tasks that are above the "Action Limit" of 25 mg/m3 (averaged over an eight-hour shift), they must develop and implement a written "Silica Exposure Control Plan". This plan must identify all effected tasks, control measures, a Competent Person responsible for implementation, and more.
Employee Training: All employees who are exposed above the Action Level must be trained on the hazards of silica, all affected tasks, control measures, description of the medical surveillance program, identity of the Competent Person, and how to obtain a copy of the plan.
Restricting Access: Areas where high concentrations of silica may be present must be restricted in order to prevent individuals who are unprotected from entering the area.
Housekeeping: Housekeeping practices that may increase exposure levels shall be avoided when alternative methods are feasible. For example, using water or vacuums to clean would be preferred over using compressed air or dry sweeping/brushing.
Medical Surveillance: Any employee who is required to wear a respirator for 30 or more days per year due to silica exposure must be entered into a medical surveillance program. This program shall consist of a chest x-ray and lung function test that shall be conducted within 30-days from assignment. These tests are required to occur prior to initial use and at least once every three years.
Recordkeeping: All documentation associated with air sampling, exposure incidents, and medical exams for silica shall be maintained on file.
For more detailed information on this
standard, visit osha.org or rms-safety.com.