Updated OSHA Silica Standard Aims to Keep Workers Safe

January 15, 2017

The Occupational Safety and Health Administration (OSHA) updated its Silica Standards recently, in an effort to curb lung cancer, silicosis, and other chronic pulmonary diseases by limiting employees’ exposure to respirable crystalline silica. The updated rule is comprised of two standards, one for Construction and other for General Industry and Maritime.

OSHA has made these changes because previous Permissible Exposure Limites (PELs) are formulas that many find hard to understand. OSHA believes that the previous levels do not adequately protect workers.

There are three main forms of Silica: Quartz, Cristobalite and Tridymite. Exposures can come from chipping, cutting, sawing, drilling, grinding and crushing of concrete, brick, block, rock and stone. Silica can be found in many industries including: Construction, Foundries, Glass Manufacturing, Paintings and Coatings, etc.

General Industry Employers
The new General Industry PEL is 50 ug/m3 (nearly half of the former levels) and the action level = 25 ug/m3.  Exposure assessments are required if exposures are or may be expected to be at or above actions levels of 25 ug/m3.  

The Performance Option – exposures assessed using any combination of air monitoring data or objective data sufficient to accurately characterized crystalline silica. Objective data includes air monitoring data from industry-wide surveys or calculations based on the composition of a substance. This data must reflect workplace conditions closely resembling or with a higher exposure potential than the process, types of material, control methods, work practices and environmental conditions in the employer’s current operations.

The Scheduled Monitoring Option – sets a schedule for performing initial and periodic personal monitoring.  Monitoring is required if levels are at or above the Action Level.

Additionally, regulated areas are required where exposures can reasonably be expected to exceed the PEL.

A written exposure control plan must be developed and describe the tasks involving exposure to respirable crystalline silica, engineering controls, work practices, and respiratory protection for each task, and housekeeping used to limit exposures.

Respiratory Protection – Any use of respirator must comply with OSHA 1910.134.  Respirators are required for exposures above the PEL including: while installing or implementing controls or work practices, for tasks where controls or work practices are not feasible, when feasible controls cannot reduce exposures to the PEL, while in a regulated area. Respirators are permitted where PEL cannot be achieved with engineering and work practice controls.

Medical Surveillance – Employers must offer medical examinations to employees who will be exposed above the action level for 30 or more days a year. Examinations must be offered every three years to workers who continue to be exposed above the trigger.

Employers are required to comply with the Hazard Communication Standard or Employee Right-To-Know Rules in their areas. Employers must also train workers annually on health hazards, tasks resulting in exposure, workplace protections, and medical surveillance.

Additionally, employers must maintain records under 1910.1020 for air monitoring data, objective data, and medical records. Results must be retained for 30 years after employee’s employment.

Compliance Dates - June 23, 2018 for General Industry & Maritime Employers. Action Level Trigger Medical Surveillance must be complied by June 23, 2020. The PEL is the trigger from June 23, 2018 through June 23, 2020.

Construction Employers
The updated standard is expected to affect the Construction Industry more significantly than General Industry due to the industry exposures. The new Construction Industry PEL is 50 ug/m3. All occupational exposures to respirable crystalline silica are covered, unless employee exposure will remain below 25 ug/m3.

The Construction Silica Standard identifies specific exposure control methods through Table 1.  Eighteen tasks with effective dust control methods and respirator requirements have been identified. If employees are engaged in one of the tasks on the table, as long as you follow the engineering controls and respirator requirements you will be in compliance. No sampling is required as long as you follow the guidance of Table 1.

Respirators – Are required where exposures above the PEL are likely to persist despite full and proper implementation of the specified engineering and work practice controls. Respirators must be used by all employees engaged in the task for the entire duration of the task. Provisions specify how to determine when respirators are required for an employee engaged in more than one task.

A written exposure control plan must be implemented by a competent person. In this plan descriptions of tasks involving exposure to respirable crystalline silica engineering controls, work practices and respiratory protection for each task must be included. Housekeeping must also be addressed.

A competent person must be designated to implement the written exposure control plan. This person also makes frequent and regular inspections of job sites, materials and equipment.

Medical Surveillance – Identical to General Industry Standard.

Compliance Dates - June 23, 2017 for the Construction Industry Employers. Compliance with methods of sample analysis is required by June 23, 2018.

Additional information on OSHA’s silica rule can be found at www.osha.gov/silica.