Post on 23-Sep-2020
OSHA Silica Standard
Your Presenter
Gary Glader, CSP
Horton Safety Consultants
708-845-3662gary.glader@thehortongroup.com
OSHA – Silica in General Industry
Background
• Silica is a necessary element of many
everyday building materials
• Silica is one of the most abundant
minerals in the earth’s crust
• It’s been known since the early 1700’s that
silica is harmful when inhaled
Regulatory History
• No comprehensive standards existed, only
permissible exposure limits (PEL’s)
• Until the new standard was issued, PEL’s
for silica were calculated using percent of
silica content in a formula
Regulatory Justification
• OSHA indicates 295,000 industrial workers
are exposed to silica containing dusts
• OSHA claims 27,000 in ready-mix
concrete operations are exposed
• OSHA also claims 20,000 of the 27,000
are exposed above the new PEL
• Industry sponsored studies indicate
otherwise
Regulatory Justification
• Exposure to silica linked to:
– Silicosis
– Lung cancer
– COPD
– Kidney disease
Compliance Deadlines
• Construction
– September 23, 2017
• General Industry & Maritime
– June 23, 2018
• June 23, 2021 – Engineering controls
• June 23, 2020 – Medical evaluations for employee
whose exposure exceeds AL > 30 days/year
– June 23, 2021 (hydraulic fracking)
OSHA Silica Standard – 1910.1053
Sections of Standard
• Scope & application
• Definitions
• Exposure limits
• Exposure assessment
• Regulated areas
• Methods of compliance
• Respiratory protection
• Housekeeping
• Medical surveillance
• Hazard communication
• Employee training
• Recordkeeping
Exposure Limits
• PEL 50 ug/m3 – 8 hour TWA
• AL 25 ug/m3 – 8 hour TWA
Exposure Assessment
• Options:
– Performance option – asses exposure using
combination of air monitoring or objective data
– Actual exposure monitoring data
• Frequency:
– Quarterly if exposures exceed PEL
– Semi-annually if exposures > AL < PEL
• Must reassess when changes occur
Regulated Areas
• Employers must identify areas where the
PEL is expected to exceed the PEL
• Warning signs must be posted
Methods of Compliance
• Engineering & work practice controls
– A must for employers to evaluate
• Written exposure control plan
– Must contain specific elements
– Must be evaluated annually
Respiratory Protection
• Must have written program (1910.134)
• Must comply with all elements of OSHA’s
respiratory protection program (1910.134)
Housekeeping
• Dry sweeping or brushing of silica
prohibited, unless it is infeasible
• Compressed air cannot be used for
cleaning unless a ventilation system is
used to capture dust
Medical Surveillance
• Required for employees exposed to silica
greater than the PEL 30 days per year
• By June 23, 2020 required for employees
exposed to silica greater than the AL 30
days per year
• Within 30 days of assignment
Medical Surveillance
• Elements of examination
– Medical & work history
– Physical exam with focus on respiratory
– Chest x-ray certified by B reader
– Pulmonary function testing
– Test for tuberculosis
– Any other test deemed appropriate
Hazard Communication
• The communication of hazards associated
with exposure to silica must be included in
the Hazard Communication Program
(1910.1200)
• Appropriate signage, safety data sheets,
and labels must be obtained
Training
• In addition to Hazcom, the following must
be addressed in training:
– Health hazards associated with silica
– Tasks that result in exposure
– Measures the employer implemented to
protect from exposure
– The contents of the OSHA standard
– Purpose and description of medical evaluation
Training
• NOTE! – OSHA requires employees
demonstrate knowledge and
understanding of the previous items
• This will require comprehension testing
Recordkeeping
• All exposure monitoring data
• All objective data used
• Medical surveillance documentation
provided to the employer
Comments
• Recent exposure monitoring data is the
most reliable form of assessment
• The use of objective data to establish an
assessment requires extensive data and
similarities to the work environment
Comments
• Because illnesses such as COPD are tied
to silica exposure, aggravation of pre-
existing conditions in those who smoke
are likely to surface during exams
• In existing employees, this may translate
into workers’ compensation claims under
the disease statute
Comments
• Engineering and work practice controls
that reduce exposures below the PEL and
AL eliminate the requirement for medical
monitoring and respirator use
Exposure Control Methods