The new OSHA standard for crystalline silica in construction takes effect in June of 2017. This article provides important information for employers and employees in the construction industry about the provisions of the new standard, and the required control measures necessary to minimize workers' exposures. We can assist your company or organization with the employer obligation to comply with the standard and protect employees from silica exposures.
DOES YOUR WORK INVOLVE ANY OF THE FOLLOWING CONSTRUCTION ACTIVITIES?
IF SO, WORKERS MIGHT BE EXPOSED TO AIRBORNE CRYSTALLINE SILICA DUST AND ARE AT RISK OF LUNG DAMAGE
A NEW OSHA STANDARD HAS BEEN ISSUED TO
REGULATE SILICA EXPOSURE IN CONSTRUCTION
On March 25, 2016, the Occupational Safety and Health Administration (OSHA) issued its final rule on exposure to crystalline silica in the workplace. The new rule includes a standard, Respirable Crystalline Silica (29 CFR 1926.1153), that will require employers in the construction industry to ensure that their employees are not overexposed to airborne dust that contains crystalline silica. Construction employers must comply with all requirements of the standard by June 23, 2017. So, employers should review the standard's requirements and develop a plan of action for meeting this deadline.
The inhalation of extremely fine (respirable) particles of crystalline silica dust can cause a serious, sometimes fatal, lung disease called silicosis. Inhaled dust can cause fibrosis (scar tissue formation) in the lungs that reduces the lungs' ability to extract oxygen from the air. Crystalline silica exposure has also been linked to other diseases such as tuberculosis, kidney disease, and lung cancer.
The three types of silicosis:
Chronic silicosis begins with few, if any, symptoms. Once present, these symptoms can include shortness of breath, severe cough, wheezing, and chest tightness, and sometimes include fever, weight loss, and night sweats. Symptoms can become worse over time, leading to death. Once silicosis develops, it continues to progress whether further silica exposure occurs or not.
No cure for silicosis exists, but the disease is preventable.
Normal Lungs Silicosis
CONTROL OF SILICA DUST EXPOSURE
To control worker exposures to silica, measures must be taken to:
PROVISIONS OF THE NEW OSHA STANDARD
The key provisions of the new OSHA Respirable Crystalline Silica Standard are as follows:
1) Reduce the PEL for respirable crystalline silica to 50 micrograms per cubic meter (50 μg/m3) of air, averaged over an 8-hour shift.
2) Require employers to use engineering controls (such as water or ventilation) to limit worker exposure or provide respirators when engineering controls cannot limit exposure.
3) Limit worker access to high-exposure areas.
4) Develop a written exposure control plan.
5) Train workers on silica risks and measures to control exposures.
6) Provide medical exams to monitor the respiratory health of highly exposed workers.
HOW TO COMPLY WITH THE STANDARD
Employers must take the following actions to determine their obligations to meet the various requirements of the OSHA standard:
If the work is covered by the standard, an employer has two options for controlling employee exposure to respirable crystalline silica:
Option 1: Specified exposure control methods
Option 2: Alternative exposure control methods
Employers who choose Option 1 (specified exposure control methods) must:
Employers who follow Option 2 (alternative exposure control methods) must:
All Employers covered by the standard must:
Controlling exposures to airborne crystalline silica dust is the primary method of protecting workers from developing adverse health effects associated with silica. If exposures cannot be controlled by eliminating or replacing the hazard, such as is typically the case with silica in construction, engineering controls should be used as the preferred control solution. Other solutions include administrative controls and personal protective equipment (e.g., respirators), but are less preferred than engineering controls.
Engineering controls are favored over administrative and personal protective equipment for controlling worker exposures because they are designed to isolate the worker from the source of dust generation or remove the hazard at the source, before it can pose a hazard to the worker. Well-designed engineering controls can be highly effective in protecting workers and will typically be independent of worker interactions to provide this high level of protection. The initial cost of engineering controls can be higher than the cost of administrative controls or PPE but, over the longer term, operating costs are frequently lower and, in some instances, can provide a cost savings in other areas of the process.
Two types of engineering controls are available to reduce dust exposures associated with working on silica-containing materials. The first type of control uses water to suppress the dust, and the second type uses local exhaust ventilation and dust collector to remove and capture dust at its source.
The following table presents a list of silica dust-generating and the associated engineering controls, as specified in Table 1 of the new OSHA standard, 29 CFR 1926.1153, Respirable Crystalline Silica. Although not shown on the table below, Table 1 of the OSHA standard also specifies requirements for respiratory protection based on task type and duration.
Dust collection system with close capture hood or shroud around drill bit with a low-flow water spray to wet the dust at the discharge point from the dust collector
Operate from within an enclosed cab and use water for dust suppression on drill bit
Tool with water delivery system that supplies a continuous stream or spray of water at the point of impact
Tool equipped with commercially available shroud and dust collection system
Grinder equipped with commercially available shroud and dust collection system
Machine equipped with integrated water delivery system that continuously feeds water to the cutting surface
Machine equipped with dust collection system recommended by the manufacturer
Apply water and/or dust suppressants as necessary to minimize dust emissions
operate equipment from within an enclosed cab
FULL AND PROPER IMPLEMENTATION OF ENGINEERING CONTROL MEASURES
Table 1 of the OSHA standard includes additional factors and specifications that must be satisfied in order for full and proper implementation of the respective engineering control. "Full and proper implementation" means that controls are in place, are properly operated and maintained, and employees understand how to use them. The presence of visible dust generally indicates that controls are not fully and properly implemented.
An effective respirator program as adapted from A Guide to Respiratory Protection for the Asbestos Abatement Industry, (U.S.EPA/NIOSH publication, EPA-560- OPTS86-001 September 1986) should include:
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