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There are so many different standards that we may overlook, not by choice, but because of a lack of knowledge. Recently, OSHA created a final rule for crystalline silica, a chemical that many workers are exposed to on a daily basis.
Crystalline silica, a basic component of soil, sand, granite, and many other minerals, poses a serious threat to nearly 2 million workers in the U.S. This serious threat is demonstrated by the fatalities and disabling illnesses that continue to occur in sandblasters, rockdrillers, and other abrasive blasting, foundry work, stonecutting, quarry work, tunneling, and more. Many workers are exposed to silica, and breathing it could case silicosis, which causes a likeliness of tuberculosis.
OSHA’s Final Rule About Silica
Take a look at this article, which explains OSHA’s final rule concerning crystalline silica:
“In addition to considerably tightening exposure limits, the new rule outlines methods to control silica exposure, procedures for conducting medical exams for workers with high exposure, training obligations for workers about silica-related hazards, and record keeping requirements related to crystalline silica quantities. Under the new rule, the PEL is now 50 micrograms of respirable crystalline silica per cubic meter of air (μg/m3), averaged over an eight-hour day….
For employers in the construction industry, OSHA is providing what it describes as “flexible alternatives.” Employers may measure workers’ exposure to silica and use whatever methods are effective to ensure that exposure remains under the new PEL of 50 μg/m3; or follow specified exposure control methods outlined for specific tasks, laid out in a table referred to as “Table 1” (osha.gov). Employers that follow Table 1 correctly are not required to measure workers’ exposure to silica and are not subject to the PEL.
As one example of the methods provided for in Table 1, for the task of operating a handheld power saw, an employer can opt to equip workers with saws having integrated water delivery systems (that continuously feed water to the blade and minimize dust emissions), in addition to ensuring that workers are wearing respiratory protection under certain conditions (e.g., when using the saw indoors or in an enclosed area), and operating and maintaining the saw in accordance with the manufacturer’s instructions for minimizing dust emissions.
If a construction employer opts not to follow Table 1, the employer must:
- Measure the amount of respirable crystalline silica to which workers are exposed if it may be at or above an action level of 25 μg/m3, averaged over an eight-hour day;
- Protect workers from respirable crystalline silica exposures above the permissible exposure limit of 50 μg/m3, averaged over an eight-hour day;
- Use dust controls to protect workers from respirable crystalline silica exposures above the PEL; and
- Provide respirators to workers when dust controls cannot limit exposures to the PEL.
Regardless of whether employers in the construction industry choose to measure and comply with the PEL or follow all of the requirements of Table 1, they must additionally do the following:
- Establish and implement a written exposure control plan that identifies tasks involving 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 respirable crystalline silica when 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 respirable crystalline silica exposure and ways to limit exposure; and
- Keep records of workers’ respirable crystalline silica exposure and medical exams.”
Silica: Materials, Threats, and Regulations
Maybe you’ve heard of silica. Maybe you know how to take care of yourself around it. But maybe you didn’t know all of the materials that contain it, or all the health threats caused by it. Understanding these important things will help you to be safer as you work, as you will be more prepared for all the hazards that you are exposed to. Ferguson.com gives a great outline and description of this hazard, including where the toxic dust is found and what it can do to your health.
“Materials Containing It”
The demand for a reduction of silica dust in the construction industry relates to the fact that workers in this field are exposed to a wide variety of products containing silica. Common construction material containing silica includes:
- Concrete, including ready-mix concrete
- Stone products
- Bricks
- Structural clay
- Glass products
- Certain types of paint and coatings
When these products are drilled, crushed, cut or abraded, they release silica dust in the air. This dust is toxic when inhaled in high amounts and can lead to a variety of health complications.
Health threats caused by it
Long-term silica dust inhalation poses a threat to worker safety because of the numerous symptoms and illnesses that it causes, which range from moderate to life-threatening. Health complications and diseases caused by silica dust include:
- Bronchitis
- Lung cancer
- Kidney disease
- Chronic obstructive pulmonary disease, or COPD
- Silicosis
The last disease on the list, silicosis, is an especially serious threat to workers in the construction industry. It is an occupational illness that causes inflammation and nodules of the lung, and can lead to long-term breathing problems. Alarmingly, the Centers for Disease Control, or CDC, estimates that there are potentially 2 million workers in the United States who will potentially be exposed to high levels of silica. This potential threat to work safety is part of the reason why OSHA passed the new rule to minimize silica levels on the job.
Employer responsibilities for limiting inhalation
The specific requirements for minimizing levels of silica dust on jobsites are outlined in OSHA regulation 29 CFR 1926.1153. In general, employers must implement the use of engineering controls in conjunction with jobsite equipment to regulate silica dust to the minimum permissible exposure limit, or PEL. Engineering controls include equipment that uses water or air ventilation to control dust. Engineering controls are required to be used when workers operate equipment that cuts, drills, saws, grinds, mills or crushes over an eight hour shift. Some of the new ventilation standards include:
- Dust extractors:
- Must be equipped with commercially-available shroud
- Must have filter-cleaning mechanism
- Must have at least 99% efficiency with HEPA filter
- Application based specifications:
- HEPA required for hole-cleaning applications
- 25 CFM per inch of wheel for all grinding applications
- Water connection specifications:
- Must have integrated water delivery system on tool
- Must continuously feed water to point of contact
If the engineering controls do not meet the PEL of 50 micrograms of silica dust per cubic meter of air over an 8 hour shift, then employers are also required to provide personal respiratory devices for workers exposed to silica dust.
Additionally, employers must also develop written silica dust exposure plans, offer medical treatment to workers exposed to high levels of silica, and provide training to workers about the risks of silica dust and how to limit exposure.”
OSHA’s New Respirable Crystalline Silica Rule and How To Be Aware
In early 2016, OSHA published and presented the respirable crystalline silica rule. This rule states that contractors who involve themselves with any activity that will cause silica dust, specifically respirable crystalline silica, by using methods such as cutting, blasting, or grinding objects like stone, concrete, etc. When contractors are involving themselves and their workers, they must abide by a stricter standard with how much dust their workers will end up inhaling.
When inhaling silica dust, it puts the person at a high risk of contracting an incurable lung disease called silicosis. Exposure to silica can also cause lung cancer, kidney disease, and even death. By updating these standards, it allows the workers who may become exposed to have ways to limit the amount of exposure to such a deadly mineral.
With this update to the standards there are a few things that may need a stricter enforcement to limit these risks.
- The new Permissible Exposure Limit (PEL) has been changed to 50 micrograms per square meter on an 8-hour time-weighted average, which is 1/5th of what was allowed for construction work.
- There are two standards in this rule which applies to the General Industry and Construction industry.
- For Construction specifically, one way is to control the dust with measures that you implement to measure the amount of silica dust in accordance to who is exposed. If it is above 25 micrograms in an 8-hour period, then new methods are needed to limit the workers’ exposure.
- Another option would be to use dust control methods that are found in the new rule to determine the risk and limit the workers’ exposure.
Knowing how to be safe and getting the proper training in accordance to this new rule can determine what happens later. Make sure that you are getting that training and staying updated in accordance to the standards.
OSHA to Enforce New Crystalline Silica Standards
On Saturday, June 23rd, 2018, the new respirable crystalline silica standards set by OSHA will be in full effect. These new standards have been formed to better protect employees from any possible silica-related diseases. Crystalline silica is found in things such as stone and sand. If the respirable silica is inhaled, it can travel deep into the individual’s lungs causing many different types of diseases such as cancer or silicosis, both of which can lead to death. To decrease the chances of individuals inhaling any crystalline silica, OSHA has established these new standards.
These new standards for silica will enforce maritime and general industries to be more restrictive about permissible exposure limits (PELs) among their employees. The OSHA memorandum states that these standards “establish a new 8-hour time-weighted average (TWA) permissible exposure limit (PEL) of 50 µg/m3, an action level (AL) of 25 µg/m3 and associated ancillary requirements.” The memorandum also states that during the first 30 days of enforcement, if the employer is in good faith and striving to meet the new requirements, OSHA will help in the process. However, if the employer is inspected and found that they are not in the process of meeting the new standards, alignment officers can proceed to monitor the air quality for any violations under the new standards which have been set. If the employer is not aligned to the new standards set for respirable crystalline silica, citations can be issued. However, before they can be issued during the 30-day period, they citations must be reviewed by the National office. Even though they must be reviewed, it is better to be safe rather than sorry.
Be sure to make time to review the new standards and begin making changes now to not only protect your employees but also to avoid any possible fines.
Update! Silica Rule From OSHA, Challenged
“Supporters and opponents of the U.S. Occupational Safety and Health Administration’s silica rule sparred over its medical provisions in competing court filings last week while the rule faces an uncertain future under the Trump administration.
The Occupational Exposure to Respirable Crystalline Silica rule reduces the permissible exposure limit for crystalline silica over an eight-hour shift to 50 micrograms per cubic meter of air for the construction industry, one-fifth of the previous maximum, as well as for general industry and the maritime industry, half of the previous maximum.
A coalition of industry groups is suing to stop the silica rule, with parties on both sides filing briefs on Friday after the U.S. Court of Appeals for the District of Columbia Circuit denied a request for an extension earlier this month to give the Trump administration additional time to evaluate potential ways to resolve the litigation.
Substantial evidence supports OSHA’s conclusion that occupational exposure to silica at the pre-existing permissible exposure limit presents a significant risk to workers and that alignment with the silica standard is both technologically and economically feasible, according to a brief filed by unions on Friday.
“OSHA properly rejected industry’s claim that workers no longer are at risk because the number of death certificates on which silicosis is listed as a cause of death has declined,” the unions said. “Scientific experts explained that, for several reasons, death certificates do not support the conclusion industry attempts to derive from them. In addition, industry’s argument ignores the fact that hospitalizations for silicosis have increased, not decreased. And industry’s argument ignores deaths from other silica-related diseases such as lung cancer.”
While clarifying that the industry groups were not endorsing any aspect of the silica rule, they argued that OSHA correctly determined that inclusion of medical removal protection, which would provide for workers to be removed from the worksite and receive pay and benefits when a licensed medical professional recommends removal, in the rule’s general industry and maritime standards was unwarranted, according to the industry groups’ brief.
“Short-term medical leave is not necessary here because, in addition to the numerous other protective ancillary provisions, ‘workers compensation is the appropriate recourse if permanent removal is required’ and because ‘union petitioners have not offered any evidence of medical removal protection costs or otherwise demonstrated that would be economically feasible,’” the industry groups said.
The unions have challenged OSHA’s trigger for medical surveillance in the silica rule’s construction standard, which requires medical surveillance be made available to employees who are required to wear a respirator for 30 or more days a year. But the industry groups argued that OSHA properly rejected the suggestion to tie medical surveillance to exposure over the permissible exposure limit in the rule’s construction standard.
“OSHA correctly determined that such an approach made no sense due to its adoption of ‘Table 1’ in the construction standard,” the industry groups said. “Furthermore, given the significant expected use of respirators in the construction industry as a result of Table 1 and OSHA’s approach to alignment, it is not at all clear that a different trigger would result in numerous construction employees receiving medical surveillance that would not receive it under the final rule as issued.”
The silica rule provides guidance commonly referred to as Table 1 outlining exposure control methods for selected construction operations, with employers who follow these methods not required to measure workers’ exposure and not subject to the permissible exposure limit.”
Make sure that your training and knowledge of standards is always up-to-date and aligned with OSHA. To view training for all things construction, click on the links below: