OSHA Begins To Enforce Respirable Crystalline Silica in Construction Standard
OSHA began enforcing the Respirable Crystalline Silica in Construction standard (1926.1153) on September 23, 2017. However, for the first 30 days, OSHA provided compliance assistance instead of enforcement for “good faith” employers attempting to comply with the new construction standard. Effective October 23, 2017, OSHA initiated full enforcement of the standard. A memorandum dated October 17, 2017, titled Interim Enforcement Guidance for the Respirable Crystalline Silica in Construction Standard, 29 CFR 1926.1153 provides interim enforcement guidance while the standard’s companion compliance directive is being finalized.
Employers should review the memorandum to learn how OSHA inspectors will approach silica in construction inspections. If you are concerned about complying with the silica in construction standard, the first step is to determine if you are covered by the standard. The standard provides Table 1 which is critical in determining compliance. You should review tasks, equipment and materials including any safety data sheets (SDSs). Table 1 includes the most common equipment and tasks found in construction work with potential silica exposures. Table 1 includes 3 columns: Equipment/Task; Engineering and Work Practice Control Methods; and Respiratory Protection and Minimum Assigned Protection Factor (APF). If the tasks you are engaged in are listed in Table 1, technically you do not need to conduct air monitoring for an initial assessment. You will need to follow column 2 and 3 for compliance.
The memorandum references Table 1 but also provides two flow charts to help with compliance. Flowchart A pertains to Table 1 and assists with determining specified exposure control methods. Flowchart B pertains to determining alternative exposure control methods. If you conduct an initial assessment and the time weighted average (TWA) exposure level is below the action level (AL) of 25 ug/m3, the standard does not apply. However, other OSHA standards may apply, including hazard communication, personal protective equipment (PPE) and respiratory protection, for example.
Flowchart B: Alternative Exposure Control Methods
For assistance with compliance including initial exposure assessments, written exposure control plans, engineering controls/PPE , training programs, etc. please contact ECOthink Group: firstname.lastname@example.org 646.705.1593. Our certified industrial hygienists (CIHs) are ready to resolve your compliance concerns.