On September 23, 2017, OSHA began enforcement of the new Respirable Crystalline Silica standard, 29 CFR1926.1153, for the Construction industry.
Isolatek International anticipates that the Applicators of our products may have questions regarding their obligation to meet OSHA’s new regulations.
The information provided is a summary of OSHA’s guidance and is intended to assist our Applicators on how the new standard pertains to the fireproofing industry. This information is not a substitute for the OSHA documents. Accordingly, for more detailed information, a better understanding of the requirements of the standard and to ensure that you are meeting those requirements, please refer to OSHA’s guidance documents, including OSHA’s Small Entity Compliance Guide for Construction, https://www.osha.gov/Publications/OSHA3902.pdf
Construction Standard Overview
When employees are working with materials containing crystalline silica and/or performing tasks on a jobsite where silica dust is present, the standard requires employers to limit worker exposures to respirable crystalline silica and take other steps to protect workers. The new standard reduces the permissible exposure limit (PEL) for respirable crystalline silica from 100 to 50 micrograms per cubic meter of air, as an 8-hour time-weighted average (TWA) in their workplaces.
The first step in compliance is determining if the silica standard applies to your employees. If silica dust is present on the jobsite, monitoring may be required to determine if an employee’s exposure will be at or above the action level of 25μg/m3, as an 8-hour TWA under any foreseeable condition. The construction standard does not apply where exposures will remain below the action level.
If respirable crystalline silica is at or above the action level, employers must take steps and implement dust controls to protect workers from silica exposures above the PEL. The standard provides flexible alternatives, useful for construction employers.
Specified Exposure Control Method (Table 1):
Table 1 matches common construction tasks with dust control methods, so employers know exactly what they need to do to limit worker exposures to silica. Employers who fully and properly implement the controls in Table 1 do not have to assess employees’ silica exposure levels or keep employee exposures at or below the permissible exposure limit (PEL).
Alternative Exposure Control Method:
Fireproofing applicators typically perform tasks outside the scope of those outlined in Table 1, and will find the Alternative Exposure Control Method more helpful in meeting the requirements of the standard.
Under the Alternative Exposure Control Method, employers must determine the levels of respirable crystalline silica employees are exposed to, and limit the exposure to the PEL of 50μg/m3, as an 8-hour TWA.
Employers can independently decide which engineering and dust controls work best to protect workers from silica exposures above the PEL, and provide respirators when controls cannot limit exposures to the PEL.
Additional Requirements of the Construction Standard
- Regardless of which exposure control method is used (Table 1 or the Alternative Exposure Control Method), all construction employers covered by the standard are required to:
- Provide respiratory protection when required.
See https://www.osha.gov/SLTC/etools/respiratory/index.html for instruction on the proper selection of respiratory protection and the development of change schedules for gas/vapor cartridges as well as helps you comply with the OSHA respirator standard.
- Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur.
Please visit http://www.silica-safe.org/plan/overview for a tool designed to help contractors and others responsible for job-site safety develop a written exposure control plan to protect workers engaged in work that produces respirable silica dust.
- Designate a competent person to implement the written exposure control plan.
- Restrict housekeeping practices that expose employees to respirable crystalline silica where 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 silica exposure and ways to limit exposure.
- Keep records of exposure measurements, objective data, and medical exams.
OSHA Silica Website
OSHA’s On-site Consultation Program offers free and confidential safety and occupational health advice to small and medium-sized businesses in all states across the country, with priority given to high-hazard worksites. On-site Consultation services are separate from enforcement and do not result in penalties or citations. Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice on compliance with OSHA standards, and assist in establishing injury and illness prevention programs.
Visit https://www.osha.gov/dcsp/smallbusiness/consult.html for additional information.
There are twenty-eight OSHA-approved State Plans operating state-wide occupational safety and health programs. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA’s and may have different or more stringent requirements.
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