Safety Tidbit 2.44 - Silica Exposure Assessment

Safety Tidbit 2.44 – Silica Exposure Assessment

Reference: OSHA’s Final Rule to Protect Workers from Exposure to Respirable Crystalline Silica

The silica standard has not been rescinded (yet). Actually, I don’t think it will be. However, only time will tell.  I have been conducting some classes on how to complete the Exposure Control Plan required by new standard. Mostly, my talks have been to folks in the construction trades (e.g., masons, hardscapers, etc.) but next week, I have been asked to give the same basic presentation to ready-mix folks and others that will be governed by OSHA’s General Industry standards. Which begged the question: How does my presentation change?  Really, not too much.

OSHA’s 1926.1153 states, in paragraph (c)

“for each employee engaged in a task identified on Table 1, the employer shall fully and properly implement the engineering controls, work practices, and respiratory protection specified for the task on Table 1, unless the employer assesses and limits the exposure of the employee to respirable crystalline silica in accordance with paragraph (d) of this section.”

Paragraph (d)(2) states:

“The employer shall assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action …”

In the General Industry Standard, paragraph (a)(3) states:

“This section does not apply if the employer complies with 29CFR1926.1153 and (i) the task performed is indistinguishable from a construction task listed on Table 1 of paragraph (c) of 29CFR1926.1153.”

Meaning if a task, identified by a company that typically falls under the general industry standard, is the same as a task performed in construction and the employer follows OSHA’s requirements in Table 1 for that task, they are in compliance with the standard.  For instance, a pre-cast concrete manufacturer making drainage culverts to be installed during road repairs, must grind the forms using handheld grinders.  This sounds remarkable like item (xii) on Table 1, Handheld grinders for uses other than mortar removal. The company may opt to follow the requirements on Table 1. 

However, if the company performs the task differently than the table, say, they go inside the pre-cast culvert to grind, or their task is not among those listed in the table then they must follow the General Industry standard’s requirements of 1910.1153(d)(2):

“The employer shall assess the 8-hour TWA exposure for each employee on the basis of any combination of air monitoring data or objective data sufficient to accurately characterize employee exposures to respirable crystalline silica.”

Or, in other words, air monitoring must be performed.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have a burning safety or health question please let me know.