OSHA’S New Crystalline Silica Standard
What you need to know…
OSHA’s new standards for silica in the workplace significantly reduce the permissible exposure limits (PEL). It’s estimated that tighter regulations on silica dust in the workplace will save over 600 lives and $8 billion in associated costs.
Crystalline Silica Standard 29 CFR 1926.1153 applies to all exposures of respirable crystalline silica, except where exposure will stay below the OSHA action level of 25 ug/m3; 8-hour time-weighted average.
Some examples of materials that are commonly involved under this standard include sand, concrete, mortar, block, terrazzo, natural stone, and thinset/grout/stucco/color hardeners.
|Type of Violation||Previous Maximum Penalty||New (Current) Maximum Penalty*|
|Serious||$7,000 per violation||$12,471 per violation|
|Failure to Abate||$7,000 per day||$12,471 per day|
|Willful or Repeated||$70,000 per violation||$124,709 per violation|
Enforcement Date: September 23, 2017
Steps to Ensure Compliance With the New OSHA PEL Standards
There are two ways to determine exposure levels: 1) air monitoring or 2) through identifying certain activities found on Table 1 of the standard and complying with the dust-control methods listed.
Option 1: Air Monitoring
This method requires that you control silica with your own methods and then measure your employees’ silica exposure through medical testing and other procedures. This can be expensive and complicated. Plus, if you discover that the exposure is at or above OSHA’s requirement, you must find better methods of limiting silica dust exposure.
Option 2: Determine Exposure Through Table 1 (preferred)
OSHA has already done some of the legwork for you and identified procedures you need to put into place to ensure any silica dust levels remain within the PEL (permissible exposure limit).
These measures are typically very easy and inexpensive to implement. Plus, employers’ who follow Table 1 correctly are not required to measure their worker’s exposure to silica and are not subject to the PEL.
Click the links below to see specific dust control methods three common operations performed by concrete operators as outlined by Table 1
Create a Written Exposure Plan
The Written Exposure Control Plan must contain descriptions of the tasks that create silica exposure, the controls, practices, and any respiratory protection used to limit exposures.
There must be housekeeping measures in place, such as no dry sweeping or compressed air, to ensure silica exposure is limited.
When necessary, procedures to restrict access to work areas where silica exposure occurs must be put into place. These procedures should be reviewed annually.
Competent Person Inspections
OSHA expects routine observations of dust-generating tasks to be made by a designated “competent person” at your company. The person is expected to take prompt and quick action with any increase of visible dust.
Given the complexity of different types of jobs and job sites, it is important that this person be familiar with your operations and fully trained and up-to-date on all OSHA silica standards.
Medical surveillance is required to be provided by an employer if an employee is required to wear a respirator for more than 30 days per year.
A baseline examination MUST be completed within 30 days of assignment unless the employee has already completed an examination within the last 3 years. This examination will cover medical and occupational history and include a physical exam with chest X-ray and other diagnostic procedures.
Provide Adequate Staff Training
All employees are required to be trained on the hazards of silica exposure. Copies of the silica standard should be readily available to all employees.
All containers with silica must be labeled and have an SDS in an easily accessible location.
Employee training should include the following:
- Health hazards associated with exposure to silica
- Tasks where employees might be exposed
- Controls in place to protect workers
- Identity of the competent person performing inspections
- Contents of the silica standard
- Purpose and description of the medical surveillance program
View the OSHA Crystalline Silica Dust Rules Workshop held at Jon-Don.
Comply With Recordkeeping Requirements
Employers who fully and properly implement tasks covered in Table 1 are NOT required to take air samples or measure silica exposures.
For tasks that fall outside of Table 1, air monitoring samples must be taken.
These samples should include:
- Date samples taken
- Tasks monitored
- Sampling and analytical methods used
- Number, duration, and results of samples
- Lab used for analysis
- Type of PPE used (including respirators)
- Name, SSN, and job classification of all employees represented by the monitoring AND which ones were actually monitored
The Equipment You Need to Ensure Compliance
In order to be compliant with the new regulations, you must use a dust collector(s) that has the following:
- A minimum of 25 CFM per inch of cutting or grinding blade
- HEPA filtration
- A mechanical means of shaking dust off the filter
In addition, your dust collector must have proper seals and O-rings as well as hoses in good condition. Cracked, crushed, or split hose lines can cause the loss of CFM and hinder performance.
Jon-Don offers an extensive selection of HEPA dust collectors designed to work with concrete surface prep equipment of all sizes.
On most jobs, a high-quality HEPA dust collector will be sufficient to contain dust and ensure that you’re well within the new PEL. However, on jobs where extra air filtration is needed, a HEPA air scrubber can be used to ensure compliance.
Jon-Don also offers a full selection of full and half-face respirators that offer an additional level of protection for your workers.
Every concrete polishing class includes information and discussion about the new OSHA PEL regulations. Not only will you improve your skills in our classrooms and hands-on demo areas, but you’ll also gain a better understanding of current laws to ensure you, your crew, and your business are protected.
Not sure if you’re compliant? Have questions about your equipment? Call 800-556-6366 to speak with a Jon-Don Concrete Specialist and schedule a FREE evaluation.
We’ll come out to your job site to evaluate your equipment and procedures, help you develop a written plan, and ensure you’re compliant.
Remember, the new standards contained in the final rule went into effect on June 23, 2016. Enforcement will begin on June 23, 2017 and contractors have until June 23, 2018 to make sure they are in full compliance to avoid being fined as much as $12,400 for violations.
Don’t wait till it’s too late! Call 800-556-6366 TODAY!