Safety Tidbit 4.08 - Silica Enforcement

Safety Tidbit 4.08 – Silica Enforcement

 

Reference:      Interim Enforcement Guidance June 25, 2018

I was working on a homework project for my IH students. The topic is silica. I have been presenting on Silica to the Mid-Atlantic Masonry Association since OSHA passed its new Respirable Crystalline Silica standard. My emphasis has been to teach the mason, hardscapers, ready-mix operators, and precast/architectural plant owners how to formulate their exposure control plan for the operations.

I start each class asking how many of them currently have workers in respiratory protection and the follow-on question who likes to wear a respirator all day?  Usually I quite a few hands of companies that are using respirators, but no one ever says they like to wear a respirator (even for short periods of time). I use this as a hook because if they perform the risk assessment in their plant and create a good exposure control plan they will find that they don’t need to use respirators after some very reasonable process modifications.

Creating an exposure control plan uses the hierarchy of controls but also requires the employer to review all their potential exposure to silica. The hierarchy of control is the process of the eliminating a hazard by using a decreasing less effective protective measures. First, try to eliminate the hazard all together.  Second, substituting the hazardous substance for something less hazardous. Third, engineering out the hazard, traditionally, by using ventilation or wetting the dust, Fourth, administratively controlling the hazard through work practices. And lastly, having the worker wear personal protective equipment (PPE) or in our case respirators to protect themselves.

By systematically profiling the workplace, the employer learns where their worst exposures can occur and take steps to reduce the emissions. I have employers that are worried about controlling exposures to tasks that occur infrequently and for short durations (less than 10 minutes) and miss the bigger exposure that affects more workers.

I never really thought that an employer, giving respirators to workers, was really protecting the workers. More, they were giving the employee the means to protect themselves. Personal protective equipment protects only as well as it is put on and that means the worker is the ultimate decider of the effectiveness of the respirator since they are ones putting it on.

So how does this relate to OSHA enforcement and the silica standard? I was reviewing the new enforcement document for silica that OSHA published during the summer. In the document, the first item a compliance officer is to ask the employer for during an inspection is the see their Exposure Control Plan. So, all that we teach about hazard recognition, evaluation and control is the basis of the Exposure Control Plan. The biggest difference for the silica is that it’s required for any potential exposure versus in the Lead Standard it’s required after exposures reach the permissible exposure limit.

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

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