Safety Tidbit #42 – Exposure Control Plan something new??

Safety Tidbit #42 – Exposure Control Plan something new??

Silica - One of the oldest occupational hazards finally have its own standard and on June 23, 2016. Ultimately, the Construction Industry has one year to completely implement all provision of the standard and General Industry establishments have two years.

As an industrial hygienist, I think the coolest thing about OSHA’s new Respirable Crystalline Silica standard is the requirement for a written exposure control plan. OSHA doesn’t make much fanfare about it and as with most things in the government, this is not a new concept. Several health standards (e.g., asbestos, inorganic arsenic and lead, cadmium, benzene, ethylene oxide, to name a few) all have a written compliance program requirement. So what makes the exposure control plan in the silica standard special? Well, I’ll tell you, it doesn’t wait until the employer has determined if the worker is exposed above the PEL before it gets written down. Also, the exposure control plan is designed to identify the potential of the hazard and consists of the following minimum elements:

1.     A description of the tasks in the workplace that involve exposure to respirable crystalline silica

2.     A description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task

3.     A description of the housekeeping measures used to limit employee exposure to respirable crystalline silica

However, in my humble opinion, I would add to the plan the following:

4.     Results of air monitoring conducted to assess airborne concentrations,

5.     Course outline and roster for training of employees as to the hazards of crystalline silica,

6.     Frequency of medical surveillance (respiratory protection or silica),

7.     The availability of the exposure control plan, and

8.     An annual review and update of the exposure control plan.

I have been promoting this process for most of my career to all of my clients for any health hazard they have in their workplace (e.g., asbestos, lead, cadmium, etc.).  I tell them it’s a great to have all of the information in one place.  So, if they are ever audited or inspected everything is together. Also, if it’s written down the logic they used to assess the hazard can be reproduced and expanded on as operations change or the company grows.  Using OSHA’s 2002 Job Hazard Analysis Publication 3071 can help you create your Exposure Control Plan. 

Use the process for all of your health hazards.  I think this is just good business. But what do I know I’m just an industrial hygienist. Also, I think we may hear more about this requirement as enforcement dates draw near.

Thanks for reading.  ~Bryan