OSHA Silica Standard

The US Occupational Safety and Health Administration (OSHA) Respirable Crystalline Silica Standard, commonly known as the OSHA Silica Standard, which was recently changed, generally requires employers to limit workers’ exposure to respirable crystalline silica and to take other steps to protect workers.  Specifically, it limits the permissible exposure limit (PEL) for respirable crystalline silica to 50 micrograms per cubic meter of air (µg/m3) averaged over an 8-hour day.  To satisfy or achieve compliance with it, companies can either use the control methods set forth in Table 1 of the standard or they can determine workers' exposure to respirable crystalline silica and independently decide which controls and methods work best to limit exposure to the PEL in their workplaces and implement the same.

If my company does not fully implement the control methods set forth in Table 1 of the standard, what does my company need to do:

•Determine the amount of silica that workers are exposed to if it is, or may reasonably be expected to be, at or above the action level of 25 µg/m3 averaged over an 8-hour day;

•Protect workers from silica exposures above the PEL of 50 μg/m3 averaged over an 8-hour day;

•Use dust controls and safer work methods to protect workers from silica exposures above the PEL; and

•Provide respirators to workers when dust controls and safer work methods cannot limit silica exposures to the PEL.

In addition to the exposure control methods implemented, what else is required of my company:

Regardless of which exposure control methods are implemented, all companies covered by the standard are required to:

·Written Exposure Control Plan: establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur;

·Designation: designate a competent person to implement the written exposure control plan;

·Housekeeping Practices: restrict housekeeping practices that expose workers to silica, such as use of compressed air without a ventilation system to capture the dust and dry sweeping, when and where effective (i.e., safe) alternatives are available;

·Medical Exams: offer medical exams, including chest X-rays and lung function tests, every three years for workers who are required by the standard to wear a respirator for 30 or more days per year;

·Training: train workers on the health effects of silica exposure, workplace tasks that can expose them to silica, and ways to limit exposure; and

·Recordkeeping: keep records of workers’ silica exposure and medical exams.

How can my company satisfy and achieve compliance with the standard:

·Review OSHA’s latest regulations and resources concerning the same (e.g., fact sheets, frequently asked questions, etc.)

·Evaluate where your company is falling short of compliance and develop solutions to achieve compliance as soon as possible.  For example, companies often time have appropriate measures in place, but cannot provide evidence of the same (e.g., providing a written control exposure plan which result in them being fined;

·Invest in appropriate equipment to ensure workplaces are cleaned to a high professional standard.  For example, vacuums with a HEPA filter, as such vacuums remove more than 99.97 percent of dust particles down to 0.3 microns in size;

·Conduct regular training on silica standards and practices (e.g., ventilating rooms, enforcing breaks, etc.) and post visual aids in areas of high dust concentration; and

· Seek legal advice and assistance.  We recommend contacting Michael Decker, Butzel Long Construction Attorney, at (248) 379-6602 or decker@butzel.com.