The Impact of OSHA's Crystalline Silica Standards on Manufacturers
OSHA’s Final Rule on Occupational Exposure to Respirable Crystalline Silica
In March 2016, OSHA issued two new standards regarding occupational exposure to respirable crystalline silica (silica)—one for general industry/maritime and one for construction. For decades, occupational health professionals have recognized that employee exposure to airborne dust containing silica can result in adverse health effects.
The Department of Labor first shed light on this epidemic in the early 1930’s and created occupational exposure limits after OSHA was established in 1971. Since then, the exposure limits haven’t changed even though occupational health professionals agree the limits didn’t provide adequate protection for workers. OSHA estimates over 2.3 million workers are exposed to airborne dust containing respirable silica.
Compared to the old standards, there are two significant changes in the new silica standard that impacts industries like manufacturing. First, the old standard only established a Permissible Exposure Limit (PEL) that limits an employee’s exposure, but doesn’t address any other requirements regarding housekeeping, ventilation, personal protective equipment, medical surveillance (if necessary) and training. Secondly, the PEL has been significantly reduced based on current knowledge of the correlations between exposure and adverse health effects.
The new silica standards are “substance-specific standards” for respirable crystalline silica. Like other substance-specific standards (asbestos, lead and others) the standards have detailed requirements for employers. These include:
- Measuring employee exposures
- Creating written exposure control plans (if necessary)
- Implementing procedures for housekeeping, personal protective equipment use, engineering controls and medical surveillance programs (if necessary)
- Training employees
The new standards establish an Action Level (AL) and a Permissible Exposure Limit (PEL) to limit employee exposures to respirable silica. The new AL is 25 micrograms of silica (all three forms – quartz, cristobalite and tridymite) per cubic meter of air (µg/m3). The new PEL is 50 µg/m3. Both the AL and PEL are eight-hour time-weighted averages (TWA). Employers under the General Industry category are required to conduct initial air monitoring to determine employee exposures for comparison to the AL and PEL.
New General Industry/Maritime Standard (29 CFR 1910.1053)
General Industry employers can “take advantage” of Table 1 in the construction standard if tasks that are performed are “indistinguishable” from the tasks described in the Table. If doing this, you must comply with the rest of the construction standard.
A medical surveillance program must be made available to employees who will be exposed to concentrations in excess of the AL for 30 or more days per year.
Regulated areas must be established in General Industry workplaces whenever employee exposures exceed or could reasonably be expected to exceed the PEL. These areas must be clearly demarcated and the entrance posted with signs. Only employees authorized by the employer may enter and work in these areas.
In addition, the new standard requires a written exposure control plan containing the following:
- Description of the tasks involving exposure to respirable crystalline silica
- Description of the engineering controls, work practices and respiratory protection used to limit employee exposure to respirable crystalline silica for each task
- Description of the housekeeping measures used to limit employee exposure to respirable crystalline silica
- Description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed to respirable crystalline silica and their level of exposure, including exposures generated by other employers or sole proprietors
- Reviewed annually to ensure continued effectiveness
When engineering controls cannot adequately limit exposure, employers must have a written respiratory program and procedures for respirator use in compliance with 29 CFR 1910.134.
This rule took effect on June 23, 2018. The information provided in this article is a brief summary of the OSHA final rule on the Occupational Exposure to Respirable Crystalline Silica. Not all requirements specified by the final rule are included in this post.
If you have any questions regarding the final rule and how it applies to manufacturing, please contact an Assurance Safety Advocate.
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