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PACNY's Annual Conference will return to Turning Stone Resort March 2023

OSHA's New Respirable Crystalline Silica Standard

2/2/2017

2 Comments

 
The new Silica standard, 29 CFR 1926.1153,  was effective as of June 23, 2016 and OSHA is scheduled to begin enforcement on June 23, 2017.

The standard applies to all occupational exposures to respirable crystalline silica in construction work, except where employee exposure will remain below the Action Limit. The Action Limit (AL) is  25 μg/m3 as an 8 hour TWA and the Permissible Exposure Limit (PEL) as 50 μg/m3 as an 8 hour TWA.

It is estimated that 2.3 million Americans are exposed to respirable crystalline silica in the workplace, and of those, 2 million are in construction. The primary health effect is Silicosis, a debilitating disease caused from the scarring of the lungs. Additionally, Silica is a known human carcinogen, and exposure has been linked to lung cancer, kidney disease, COPD, Industrial bronchitis, and several autoimmune disorders.

Front and center is the idea of Hierarchy of Controls. This standard reiterates this idea by indicating that the control of dust is the primary method to reduce employee exposure and that the use of PPE would be secondary to that.

Reducing exposure through tried and true methods are indicated within the standard.
  1. Utilizing wet methods
  2. Utilizing isolation or enclosure
  3. Utilizing a dust collection system

In a somewhat novel approach OSHA identifies the work practice and engineering controls and required respiratory protection for 18 common tasks. This really simplifies things for the construction industry. As as long as the task is listed in Table 1 and all the provisions are followed, then the employer does not have to perform personal exposure monitoring.

However, for tasks not listed in Table 1 or when the provisions of Table 1 are not followed as written, then exposure assessments would need to be created based on air monitoring or objective data or a combination thereof.

All tasks whether they are included in Table 1 or not will require the creation of a written Exposure Control Plan. The plan must indicate engineering controls, work practices, respiratory protection, housekeeping procedures, and the methods that will be used to restrict access to activities creating respirable crystalline silica exposure, to include exposure generated by others.

Additionally the standard has requirements for training, recordkeeping and a medical surveillance requirement for employees that must use a respirator for 30 or more days per year.


More detailed information can be found on OSHA's Silica page www.osha.gov/silica/index.html

Additionally, OSHA recently published a Small Entity Compliance Guide that is a vaulable compliance resource. You can view it here www.osha.gov/Publications/OSHA3902.pdf


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