Respirable Silica - Are You Ready for the New Rules?
As of September 23, 2017, contractors must be in compliance with the new OHSA regulation that greatly reduces the amount of silica dust a worker can be subjected to during an eight-hour work day. However, OSHA enforcement officers are holding off on issuing citations for 30 days
IF the contractor is showing a good-faith effort to limit exposure, even though it might not be within the allowable exposure limits. If the contractor has completely ignored the rule, citations will be issued.
There are numerous ways that citations can be written in relation to this rule. First, the most obvious citation is the cutting, grinding, chipping, sanding, breaking-up, etc. of any product that contains silica without preventing the worker from inhaling dust created by these actions. If the worker can be kept from inhaling dust that does not reach the concentration of 50 micrograms/cubic meter in an eight-hour work day, then the worker is in compliance. However, this leaves us with the question of whether or not that exposure level has been reached.
OSHA's "Table 1"
in the rules describes if or how a worker must be protected from inhaling silica dust when performing various activities. Any activity outside Table 1 must be presumed to expose a worker above the permissible exposure limit (PEL) until testing is done to determine that it does not.
Other areas in the rules from which citations can be written include employee training on the hazards of inhaling silica dust and where those hazards could be encountered in the workplace, as well as how to avoid and protect themselves from exposure. An employer must prepare a written "exposure control plan" that details all of this. The employer also must keep records of testing results of the exposures and of medical records pertaining to those workers who will be wearing respirators, which limit the amount of dust inhaled, for 30 or more days per year.
If your company has not prepared to limit the amount of silica dust your employees may inhale, you should immediately contact one of our
or OSHA Consultation to avoid any citations due to lack of compliance.