Silica-OSHA Final Rule for Crystalline Silica is Effective, September 23, 2017

If you need assistance in interpretation or compliance with the new Silica Regulations discussed in this article call us at 1-800-344-4414 or email us at info@atlenv.com for details and a free estimate.

 

Written by Robert E. Sheriff, MS, CIH, CSP, President

October 2, 2017

 

OSHA Regulations are in effect as of September 23, 2017 for the Construction Industry.  This notice was issued on April 6, 2017.

Separate regulations were issued for Construction (29CFR1926.1153) and General Industry/Maritime (29CFR1910.1053).

The general provisions to both regulations are generally the same:

  1. Permissible Exposure Limit (PEL) over an 8-hour shift is 50 mg/M3 of air.
  2. Action Level of 25 ug/M3.
  3. Requiring employees to monitor all work activities where silica exposure may occur.
  4. Requires employers to use engineering controls to limit worker exposure where sampling indicates a level above the PEL.
  5. Respirators as a supplement to engineering controls where such efforts won’t adequately control exposure.
  6. Develop a written control plan.
  7. Medical exams.
  8. Training.
  9. Final Rule took effect on September 23, 2017.

 

NOTE: Hydraulic Fracking, although part of Construction, has an effective date of June 23, 2018 but engineering controls have a compliance date of June 23, 2021 (5 years!)

Those of us in the occupational health profession have expected these new regulations for some time. There are many activities in Construction and Industry where exposures have not been well controlled. Also, the previous regulation had a formula for calculating the exposure level (the greater the % silica the lower the PEL) which was confusing and difficult to explain.

From experience, the most likely sources of overexposure in Construction are:

  • Sheetrock application especially sanding wallboard compound
  • Dry concrete cutting
  • Sand and gravel operations
  • Concrete mixing—including Redimix
  • Mining including rock, salt, coal, other minerals
  • Construction excavation especially where rock is involved
  • Dry aspects of fracking—all stages
  • Terrazzo flooring sanding

Overexposure potential in General Industry are:

  • Sand and concrete/mortar packaging
  • Stone cutting including marble
  • Marble cutting
  • Brick and block manufacturing
  • Gravestone cutting and lettering
  • Countertop manufacturing
  • Refractory products (bricks and cement)
  • Glass manufacturing
  • Foundries

There are many other commercial activities that handle sand as part of their processes—both in Construction and General Industry. The best approach is to carefully review the Safety Data Sheets (SDS) for all raw materials to determine if silica is present in reportable quantities. If so, it is prudent to have the work activities that use those silica containing raw materials monitored. The proper method of sampling/testing is the use of a portable air sampler worn by the worker for a full work shift. Samples will be analyzed for respirable dust and silica and compared to the 50 ug/M3 PEL.

The final rule can be found on OSHA’s website at www.osha.gov/dsg/topics/silicacrystalline/

Solutions to overexposure are widely varied. The most common approach is to convert a dry process to wet methods, but beware, some wet processes have been shown to still exceed the PEL.

Wet methods by themselves are not always totally effective simply because a very fine mist can also carry the silica particles in such a size range that they can be inhaled.

The first step, of which many organizations have already taken in anticipation of this new regulation, is to monitor the worker’s exposure through personnel sampling/testing.

Atlantic Environmental has the capability of monitoring worker exposure, developing control plans and performing the necessary training, as well as recommending solutions to identified problems.  We have Certified Industrial Hygienists (CIH) with substantial experience in crystalline silica generating activities.

Our primary service areas for Ventilation Testing are: NJ, NY, NYC, PA, CT, DE, (Boston) MA, RI, Wash DC, WI, MD, MI, (Chicago) IL, VA, IN, (Atlanta) GA, AL, NC, SC, TN, (Dallas) TX, OK, DC, AR, we can service most other areas of the U.S. but with some added travel charges.