Silica Summer Ahead

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AmericanWorkers63015.jpgOSHA dropped the final rule for silica exposure today, a culmination of efforts since 1994 when the agency decided that rulemaking related to silica was a priority. OSHA’s Special Emphasis Program for silica has been in place since 1996. The new rule, effective in late June 2016, full compliance by next year for construction industry employers, and deadlines into 2021 depending on specific factors and other industries like general industry and maritime.

The standard is important in the prevention of lung cancer and other horrible occupational diseases due to silica exposure. It will impact employers who conduct work that produces silica dust, especially in construction, no matter if the project is demo of an existing structure or new construction.

An interesting timeline published by Nation of Change, juxtaposed a construction workers life with the timeline of silica awareness and rulemaking. For this particular worker, the action comes too late.

A glance at OSHA’s Fact Sheet on the new Silica landing page leads me to the following MUST-DO list for employers:

1. Identify tasks that expose personnel to crystalline silica dust – this includes the work of other trades, companies, owners, not just the work that is conducted in-house. All exposures must be accounted for.

2. Conduct exposure monitoring – For tasks identified in Step 1, hire a third party consulting firm or use resources from your local OSHA Consultation Office, insurance carrier or broker risk control staff (does not apply to all carriers and brokers) to conduct detailed exposure monitoring of the work area and individual workers. You MUST know the levels of crystalline silica dust that your personnel could be exposed to for the next steps.

3. Identify ENGINEERING controls that bring the exposure level below the PEL, which is now 50 micrograms per cubic meter of air averaged over an 8-hour “shift.”

4. If Engineering controls are not enough, establish Administrative and PPE controls including worker rotation to limit exposure, medical exams, and training. A written Exposure Control Plan is specified in the new standard and includes designation of a Competent Person to guide the program.

5. Finally, TRAINING must be developed and conducted related to all aspects of the previous 4 Steps.

The full standard text is available now as a pre-publication PDF, the official publication should be live at the same link on 3/25/16 per OSHA sources. The document is over 1,700 pages! This is due to an extensive Executive Summary and Preamble. My advice is to to a Control+F search of the PDF using search terms that apply to your business and specifics of the standard. For example: “written exposure plan” yields 236 mentions in the full document, “masonry” yields 115, and “medical surveillance” yields 380 mentions.

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