The June 23, 2018, deadline for general industry and maritime-sector compliance with requirements in OSHA’s Occupational Exposure to Respirable Crystalline Silica rule (March 25, 2016, FR) is less than 3 months away. Employers with workplaces that contain respirable silica should understand their obligations and meet them in time.
STILLFX / iStock / Getty Images Plus / Getty Images
If respirable crystalline silica is generated in the workplace, the primary initial responsibility is to determine if workers are exposed to concentrations above the rule’s action level, as explained below.
An Omnipresent Substance
Crystalline silica is present in quartz, the second most common element on the Earth’s surface. It is also hard, chemically inert, and has a high melting point, all qualities that make it highly desirable in many industrial uses.
OSHA estimates that about 295,000 workers are exposed to respirable crystalline silica in over 75,000 general industry and maritime workplaces covering about 30 sectors. A short list of activities that generate respirable silica includes cutting, sawing, grinding, drilling, and crushing stone, rock, concrete, brick, block, and mortar; using industrial sand; abrasive blasting with sand; sanding or drilling into concrete walls; grinding mortar; and manufacturing brick, concrete blocks, or ceramic products. Silica is also common in the food and beverage industry.
Crystalline silica has been classified as a human lung carcinogen. Additionally, breathing crystalline silica dust can cause silicosis, which—in severe cases—can be disabling or even fatal. There is no cure for silicosis.
Hazardous When Airborne
But not all silica is crystalline and not all crystalline silica is respirable. Therefore, the first question an employer must ask and answer is, Does the workplace generate crystalline silica that is respirable?
OSHA states a particle of crystalline silica is at least 1/100 the size of a grain of sand found on a beach. Furthermore, just being near crystalline silica is not hazardous; the hazard exists when the work activity sends crystalline silica into the air in the form of dust; thus, the intent of the rule is to lower worker exposures to airborne crystalline silica.
Accordingly, the second question for an employer is, How much respirable crystalline silica is generated in the workplace? Under the rule, an employer must monitor the exposure of employees who are “reasonably expected” to be exposed to respirable crystalline silica at or above the action level of 25 micrograms per cubic meter (µg/m3) of air averaged over an 8-hour day. If exposures are at or above the action level but at or below the rule’s permissible exposure limit (PEL) of 50 µg/m3 of air averaged over an 8-hour day, the employer must repeat the monitoring within 6 months of the most recent monitoring.
OSHA notes that current high-flow dust samplers can collect more airborne dust and more silica than older samplers that are still in use. Collecting more dust means that laboratories can measure the amount of silica in the dust with greater precision.
Required Actions
Under the rule, employers must protect workers when exposure to respirable crystalline silica exceeds or might exceed the PEL over an 8-hour period. Actions employers must take include:
- Limiting workers’ access to areas where they could be exposed above the PEL;
- Using dust controls to protect workers from silica exposures above the PEL;
- Providing respirators to workers when dust controls cannot limit exposures to the PEL;
- Using housekeeping methods that do not create airborne dust, if feasible;
- Establishing and implementing a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers;
- Offering medical examinations to employees exposed above the PEL for 30 or more days a year beginning on June 23, 2018;
- Training workers on work operations that result in silica exposure and ways to limit exposure; and
- Keeping records of exposure measurements, objective data, and medical exams.
Also, employers are required to offer medical examinations to employees exposed at or above the action level for 30 or more days a year beginning on June 23, 2020.
OSHA provides a detailed small entity compliance guide for the respirable crystalline silica standard at https://www.osha.gov/Publications/OSHA3902.pdf. The guide includes a list of engineering and work practice controls that have proven to be effective in reducing exposure.