OSHA’s Crystalline Silica Rule is finally here and the impact is going to mean big changes for the construction industry. These changes have been in the works for over 10 years as the original draft was presented in 2003. It is clear that the new rule has meant big changes for the construction industry and in particular for any company created or exposed to silica dust.
The previous rules for silica were originally brought forth in 1971, and little had changed in the way of regulation before now. The change to the new rule is to bring the Permissible Exposure Limit (PEL) into line with what more recent science has determined as safe levels. The previous PEL was established using research which is almost half a century old. Since that time, more modern methods for measuring employee exposure have been implemented, meaning that techniques are now more accurate.
Respirable Crystalline Silica is created when materials containing crystalline silica are disturbed and create the airborne dust which is commonplace on many construction sites. Many consider this dust as being part of the general work activity, but studies have shown it to be more dangerous than previously thought. It is now classified as a human carcinogen by many organizations and agencies, including the National Institute for Occupational Safety and Health (NIOSH). Exposure to concentrations of crystalline silica may result in cases of silicosis, lung cancer, and other respiratory or kidney diseases. With no effective means to treat related diseases, OSHA’s focus is on prevention. The new standard reduces the PEL to 50 micrograms per cubic meter as an 8-hour time weighted average. This is a substantial drop from the previous level for construction, which was about five times that limit.
Measures to prevent exposure are similar to those already in place, starting with dust control techniques such as HEPA vacuum, wet methods, prevention of dry sweeping, requirements for regulated areas, and of course respiratory protection when control methods are not effective. OSHA has produced Table 1, which outlines various techniques that are permitted for dust control and when respirators are required. If the work activity is listed in Table 1, the employer makes a determination of which control method will be used and how long the exposure will be (greater or less than 4 hours). Once that is determined the table will show if respiratory protection is required and at what level. Since it is OSHA, there are also very specific training guidelines to be followed as well. These guidelines are already followed by many companies, but the reduction of the PEL requires affected businesses to re-write and re-assess their programs. Companies who have affected employees must write a silica Exposure Control Plan to outline their management of silica related exposures and make sure employees understand the rule and how to implement the controls in the field.
Obviously, this will have a significant impact on all construction activity and would mean to employees would be required to put additional controls in place to meet the legal requirements for protecting workers. Part of this new rule also requires employers to monitor silica or objectively demonstrate that levels do not exceed 25 micrograms per cubic meter if they are unable to follow the Table 1 protocols or perform work outside of the tasks listed in the table. This level would trigger the necessity for exposure assessment and medical surveillance. The medical surveillance requirements of the new rule are more in-line with OSHA’s asbestos or lead standards, which require an employer to have an in-depth medical evaluation and monitoring of employees required to wear a respirator for 30 or more days per year. This medical exam must take place every three years for effected employees. If companies cannot demonstrate the exposure level is below the action level of 25 micrograms, the company will be required to continue to perform exposure monitoring.
For all companies involved, the changes to the Crystalline Silica Standard will have a large impact on the costs and how they conduct business. It is important that everyone from employees, supervisors, and business managers understand these changes and how it will affect employee safety and bottom line budgets. Changes in regulations are expected, but this new standard will drastically alter the way almost every construction firm operates. If you are not already familiar with the new rule, now is the time to understand it because it will be an area of particular focus for years to come
You can find more on OSHA’s new Silica Rule and how it will affect your business at www.osha.gov/silica
Related Topics: OSHA Silica Rule, Monthly Safety Topics, OSHA Respiratory Crystalline Silica Standard, Safety Articles