Attention: Contractor Business Owners. OSHA estimates that about two million construction workers are exposed to respirable crystalline silica in more than 600,000 workplaces.
Silicosis, lung cancer, other respiratory diseases, and kidney disease
have been linked to exposure to respirable crystalline silica.
Construction employers must comply with all the requirements of the Crystalline Silica Rule by June 23, 2017, except requirements for laboratory evaluation of exposure samples, which begin on June 23, 2018. It should be noted that the rule is being challenged in the courts, and it is possible it will be quite different after these legal processes.
Regardless, it is critical that you get a copy of the “Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for Construction” on this topic. You can get this guide at the following link:
The exposures occur when working with concrete, masonry, tile, rocks, etc. Examples of the jobs/tasks that create an excessive dust exposure are sawing, core sawing, drilling, core drilling, using jackhammers and chippers, grinding, floor grinding, sandblasting, etc. Your control program will need to identify each specific task that so specific controls can be implemented for each operation/task/job.
Basic Controls – Reducing the silica exposure is the key to your control program. Common dust control methods, such as wetting down work operations to keep silica-containing dust from getting into the air, enclosing an operation (process isolation), or using a vacuum to collect dust at the point where it is created before workers can inhale it are the main controls you will want to use.
The guide book and standard address two ways to comply:
- Specific exposure control methods
- Alternative exposure control methods – More is required and includes air level testing of the individual worker to determine their exposure.
Regardless of the control method you use, all construction employers covered by the standard are required to develop additional controls, such as:
- Written Exposure Control Plan – What tasks with silica exposures are performed and what methods are used to protect the workers, including procedures to restrict the work area where high exposures may occur;
- Competent Person – Designate a competent person to implement the written exposure control plan;
- Housekeeping – Restrict housekeeping practices that expose workers to silica where feasible alternatives are available;
- Training – The employees need to be trained on operations that result in a silica exposure and ways to limit the exposure; and
- Records – You need to keep records of the workers’ silica exposures and their medical exams.
Above are the priority items that need to be addressed. Below are several additional points to understand for compliance:
- Respirator Protection – When respirators are required, a formal respirator protection program is also required;
- Housekeeping – Proper control is with wet sweeping and HEPA-filtered vacuuming. Do not allow dry brushing or dry sweeping. Also, do not allow cleaning of surfaces or clothing with compressed air (unless compressed air is used with a local exhaust ventilation system);
- Written Exposure Control Plan – There is a nice sample on page 46 of the guide book that you can use to set up the format of your plan;
- Competent Person - The employer must designate a competent person to frequently and regularly inspect job sites, materials, and equipment to implement the written exposure control plan. A competent person is someone who can identify existing and foreseeable respirable crystalline silica hazards, is authorized to promptly eliminate or minimize silica hazards, and has the knowledge and ability to implement the written exposure control plan;
- PLHCP – Physician or Other Licensed Health Care Provider – This is a term repeated in the guide in the medical monitoring section;
- Medical Monitoring – There are very specific requirements on what you need to do, what you need to provide to the PLHCP, what information they give to the employee, and what information they provide to the employer. That is why it is critical to use a PLHCP with an industrial/occupational medical background who is familiar with this standard and the respirator standard. In addition, pages 52, 53, and 54 have samples of the Written Medical Report for Employee, Written Medical Opinion for Employer, and Authorization for Crystalline Silica Opinion to Employer that you should know about; and
- Communication of Hazard – As with other potential occupational health hazards, the silica rules also require that this be included in your hazard communication program.
When working routinely with concrete/masonry in the above examples, there will almost always be a dust exposure you need to control, and you will need to comply with this standard. However, concrete work also involves some tasks that do not present silica dust exposures. These include:
- Mixing concrete for post holes;
- Pouring concrete footers, slab foundations, and foundation walls; and
- Removing concrete formwork.
Some employees in the construction sector perform tasks involving occasional, brief exposures to respirable crystalline silica that are incidental to their primary work. These workers include carpenters, plumbers, and electricians who occasionally drill holes in concrete or masonry or perform other tasks that involve exposure to respirable crystalline silica. Where employees perform tasks that involve exposure to respirable crystalline silica for a very short period of time, exposures for many of these tasks will be low. If workers are exposed for less than 15 minutes during an 8-hour day, this standard would not apply. However, it is important to note this exception is only for situations where exposures are not likely to present significant risk to workers.
From a practical Loss Control perspective, having better controls to eliminate or significantly reduce the silica dust exposure is needed. Either wet methods or using equipment with a commercially available dust collection system are controls contractors need to use.