Federal OSHA recently issued a final rule covering silica which took effect June 23, 2016. The rule is intended to significantly reduce debilitating respiratory diseases related to occupational exposure to respirable crystalline silica. The new rule mandates controlling exposure to respirable crystalline silica to below 50 micrograms per cubic meter of air (μg/m3). This new permissible exposure limit (PEL) is 50% lower in the general industry and some 20% lower in the construction industry as compared with the previous PELs. By reducing the PEL so significantly, OSHA estimates that over 600 lives per year will be saved and that over 900 new cases of silicosis per year will be prevented (US Department of Labor 2016).
Do You Need to Comply?
The National Institute of Occupation Safety and Health (NIOSH) estimates that at least 1.7 million workers are exposed to crystalline silica in the US. Industries covered by the newly adopted standards include:
To adequately and effectively address the wide breadth of industries faced with new compliance challenges, two standards were created. One addresses the unique challenges of the construction industry and the other was developed for the general industry and shipyards. It is important to note that the standards have different implementation dates. The construction industry must comply with the standard by June 23, 2017 and the general industry must comply by June 23, 2018 (with few exceptions). Hydraulic fracturing operations are covered under the general industry standard and have a slightly different compliance schedule based on developing technology. The compliance schedule is shown below.
General Industry (excluding hydraulic fracturing)
General Industry-Hydraulic fracturing
Individual states have six months to adopt the federal OSHA standard or to promulgate rules which are, at least, as stringent as the federal standards.
Reducing occupational exposure to respirable silica will be achieved by implementing, amongst other things, administrative controls, engineering controls, monitoring and surveillance and the use of personal protection. The use of respiratory protection as a front-line defense against exposure is not allowed by OSHA. Administrative and engineering controls must first be implemented before using respiratory protection as a compliance method.
The significant reduction in the PEL related to the construction industry sparked concern regarding the practicality of compliance. Acting on input from the construction industry during the required public comment period during the development of the rule, OSHA has published Table 1 which provides details for the construction industry on high risk activities, expected exposure and recommended engineering controls to protect workers from excessive exposure. Table 1 can be used as a quick reference guide for the construction industry to achieve compliance.
Administrative controls include developing a written exposure control plan, implementing exposure control methods, limit access to high exposure areas, provide training to its employees focused on reducing exposure to silica dust, conduct medical surveillance and measuring employee’s exposure to silica dust to document the efficacy of the engineering controls (for construction industry this will start June 23, 2018).
OSHA requires employers to take action. Alta’s Building Science team provides expertise in health and safety and helps businesses with workplace compliance. We can help you with all aspects of this new requirement. Alta experts will assess workplace compliance, determine exposure levels of employees, identify the protective measures to implement, monitor air quality, and develop a compliance strategy for your business.
For questions on silica or any health and safety issue, contact David Schack, Vice President of Building Sciences at David.Schack@altaenviron.com or 888-608-3010.