On March 25, 2016, OSHA published its final rule on Occupational Exposure to Respirable Crystalline Silica. Since 1971, crystalline silica exposures have been subject to a permissible exposure limit found in 29 CFR 1910.1000, Table Z-3; the new rule establishes a substance-specific standard for crystalline silica. Substance-specific standards include extensive compliance requirements not found in Section 1910.1000.
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Keep reading to find out how the new rule will impact affected employers.
Two New Rules
The new rule is actually two rules: 29 CFR 1910.1053 covers crystalline silica exposures in the maritime and general industries, and 29 CFR 1926.1153 covers construction employers. Because it is a substance-specific standard, it is structured much like OSHA’s other substance-specific standards. Employers whose workers are exposed to crystalline silica at or above the action level will now have to comply with these common substance-specific requirements:
- Conduct an exposure assessment. All covered employers must conduct an exposure assessment for each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level. Employers may conduct personal exposure monitoring (called the “scheduled monitoring option” in the standards), or they may use other air-monitoring data and available information (called the “performance option” in the standards) to characterize worker exposures. There is an exception for employers that utilize the alternative compliance methods described in the construction standards. Affected employees must be notified of the results of exposure assessments within 15 working days.
- Create regulated areas. Employers must restrict access to areas where exposures may exceed the permissible exposure limit (PEL). The maritime/general industry standard requires employers to post warning signs at the entrances to regulated areas. The construction standard requires employers to include procedures for restricting access to regulated areas in the written exposure control plan.
- Implement engineering and work practice controls. OSHA requires employers to reduce exposures below the PEL using engineering and work practice controls whenever feasible before resorting to personal protective equipment (for example, respirators).
- Create a written exposure control plan. Construction employers must also have a competent person to implement the plan.
- Create a respiratory protection program for all workers whose exposures cannot be reduced below the PEL through the use of engineering and work practice controls.
- Perform housekeeping. The new standard restricts the use of dry sweeping and compressed air to clean areas contaminated with silica dust; these methods can only be used when other methods are not feasible.
- Conduct medical surveillance. In maritime/general industry, medical surveillance must be made available to workers who may be exposed to respirable crystalline silica for more than 30 days per year. In construction, medical surveillance must be made available to workers who are required by the standard to use respirators more than 30 days per year.
- Create a hazard communication program to inform workers about the presence of crystalline silica, its hazards, and how to protect themselves.
- Keep records of air monitoring data and medical surveillance data.
Tomorrow we’ll look at some of the major differences in the two standards.