New and Final OSHA Rules on Crystalline Silica Dust
Who is affected by the rule?
About 2.3 million workers are exposed to respirable crystalline silica dust in their workplaces. The majority of these workers, about 1.85 million, are in the construction industry. Exposures occur when workers cut, grind, crush, or drill silica-containing materials such as concrete, masonry, tile, and rock. About 320,000 workers are exposed in general industry operations such as brick, concrete, and pottery manufacturing as well as operations using sand products, such as foundries, and hydraulic fracturing (fracking) of oil and gas wells. Workers are also exposed during sandblasting in general industry and ship repair operations in the maritime industry.
The Windsor Consulting Group, Inc. has the capabilities and experience to assist customers with all of the requirements of the new OSHA rule. Our Certified Industrial Hygienists (CIHs) can assist clients with each of the following requirements:
Written Exposure Control Plan
The final standard requires affected employers in general industry and maritime industry to develop a written exposure control plan while employers in the construction industry also requires a competent person to implement the site plan.
Permissible Exposure Limit (PEL)
Workers' exposure are limited by the new PEL of 50 micrograms of respirable crystalline silica dust per cubic meter of air (ug/m3) averaged over an 8-hour workday. The new PEL is the same for all industries covered by the rule. The action level is 25 ug/m3 for an 8-hour workday. Certain provisions of the OSHA rule are triggered by exceeding the action level and the PEL. The OSHA standard requires initial air monitoring of at-risk workers, which may be followed by repeat or periodic air monitoring and monitoring following changes in the number of affected workers or changes in the process, equipment or machinery, which may affect the workers' exposure to crystalline silica dust.
Our team of CIHs is located throughout the United States so we can immediately support our customers need for service along with identifying at-risk workers that require exposure monitoring and the collection of air samples
Specific Exposure Controls
For each employee engaged in tasks applicable to the OSHA rule, the employer must fully and properly implement a hierarchy of controls starting with engineering solutions, administrative controls, and the selection and use of personal protective equipment including respirators. Employers will not only need to construct a written policy, program, and standard operating procedures for silica but there are other regulatory obligations that may require the employer to develop similar policies, programs, and procedures for other compliance requirements such as personal protective equipment, hazard communication, and hand and portable power tool use. Our consultants are expert in the identification, implementation, and verification of effective controls to reduce the risk within acceptable limits for silica.
Housekeeping
The OSHA rule recognizes that the use of compressed air, dry sweeping, and dry brushing to clean clothing or work surfaces contaminated with crystalline silica dust should not be done. These work tasks can contribute to employee exposure that may exceed the OSHA PEL. The Windsor Consulting Group, Inc. can support our customers to develop and aid in the implementation of specific housekeeping measures to control and reduce the occupational exposure below the OSHA PEL.
Regulated Areas
The OSHA rule for general industry and the maritime industry requires establishing regulated areas where exposures can exceed the OSHA PEL. Each regulated area must post warning signs at the entrances to these control work areas. The OSHA rule for construction requires procedures to restrict access to work areas in the written exposure control plan. Employers must post signs at all entrances, which read the following legend"
DANGER
RESPIRABLE CRYSTALLINE SILICA DUST
MAY CAUSE CANCER
CAUSES DAMAGE TO LUNGS
WEAR RESPIRATORY PROTECTION IN THIS AREA
AUTHORIZED PERSONNEL ONLY
Laboratory Methods
The selected laboratory to analyze the air samples collected on at-risk workers must be evaluated by one of the following methods: OSHA ID-142, NMAM 7500, NMAM 7602, NMAM 7603, MSHA P-2, or MSHA P-7. The lab must be accredited to ANS/ISO/IEC Standard 17025-2005 with respect to crystalline silica by a body that is compliant with ISO/IEC Standard 17011-2004 for quality assessment.
Medical Surveillance
The OSHA rule for general industry and the maritime industry requires medical surveillance to be made available to any worker exposed to crystalline silica dust at or above the action level for more than 30 days a year, and construction industry standard requires medical surveillance to persons who are exposed to crystalline silica dust above the action level and/or is required to wear a respirator for more than 30 days a year. The Windsor Consulting Group, Inc. will support its customers in the identification of at-risk personnel who may be included in a medical surveillance program.
Hazard Communication and Training
Worker training is essential to understand the OSHA rule and the health effects from exposure to crystalline silica dust. Workers must be trained on work operations that result in crystalline silica dust exposures and the ways to control the exposure. The Windsor Consulting Group, Inc.can provide face-to-face classroom training to meet the OSHA requirements.
Recordkeeping
Air monitoring data, including lab reports of "objective data" must be keep on file and readily available to all affected workers under the OSHA rule.
For more information about the OSHA rule and how The Windsor Consulting Group, Inc. can help employers comply with the regulatory obligations, you can contact us at +1 732.221.5687 anytime or email us your request for proposal at windsgroup@aol.com.
