Safety News

dust extSince 1938, the U.S. Department of Labor has provided guidance on health hazards related to exposure to crystalline silica.  They directed employers to voluntarily implement engineering and administrative controls, supplemented with PPE to reduce airborne concentrations.

In 1971, OSHA formally adopts a standard to limit respirable exposures to 250 micrograms / meter3.  This  remained unchanged until March, 2016 when OSHA proposed amending the standard to require that construction employers:

  • Perform an exposure assessment using either a unique task based table (Table 1) OR using air monitoring equipment
  • Establish and implement a written exposure control plan
  • Designate a competent person to implement the control plan
  • Limit respirable exposures to less than 50 micrograms / meter3 (the PEL)
  • Offer medical exams once every 3 years to workers who are required to wear a respirator 30+ days a year
  • Train employees on silica hazards and exposure control methods
  • Keep records of air monitoring and employee medical exams when applicable

The revised standard was to originally have an effective date of 6/23/17, but was delayed until 9/23/17.  It is in effect now, but only where Federal OSHA has jurisdiction. 

Last week, OSHA released an enforcement directive indicating a 30 day citation grace period to good faith employers, in which they would act in a consultive capacity to aid in compliance efforts.

Employers under Oregon OSHA can expect to have the same requirements however, full compliance is not mandatory until 7/1/18.  Washington LnI has yet to formally propose their version of the standard, but it looks like they are working towards an effective date sometime in the first quarter of 2018.

While the bullet list above looks like a lot of work, the large majority of our electrical construction tasks which create silica dust fall under Table 1 compliance direction.  The table specifies that the use of tools with HEPA vacuum features and / or water delivery systems to reduce dust accumulation will not expose workers above the PEL. 

Those workers will need basic training on silica health hazards and proper use of the tool.  Your competent persons, those who oversee the work, will need additional training on the standard and how to complete an exposure control plan.  Lastly, if workers are not exposed above the PEL, they are not required to wear respirators (voluntary use is ok) and as such will not need medical examinations.

I have many resources to aid in employee training and a simple to use, online exposure control plan.  An updated silica module for your safety manual is also available.  Please contact me for more information.