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Respirable Crystalline Silica Safety

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Respirable Crystalline Silica Safety

Nearly two-and-a-half years after publishing a rule proposal to reduce the permissible exposure limit for silica, the Occupational Safety and Health Administration (OSHA) released the final rule on March 24, 2016.  The previous rule, released in 1971, only required employers to limit an employee’s exposure to silica within a permissible exposure limit; however, the new rule requires a pro-active approach from employers to ensure that employees are not exposed to silica in excess of the greatly reduced permissible exposure limit, as well as offering medical examinations to employees who are considered “highly exposed.”

This new rule is comprised of two standards, one for Construction and one for General Industry and Maritime. Industries will have one to five years to comply with the requirements of the standards based on the following schedule:

Construction – September 23, 2017, one year after the effective date.

General Industry and Maritime – June 23, 2018, two years after the effective date.

Hydraulic Fracturing – June 23, 2018, two years after the effective date for all provisions except Engineering Controls, which have a compliance date of June 23, 2021.

Are You Ready?

Compliance dates are approaching quickly. Take our brief self-assessment to verify your readiness.

What You Need To Know

The New Rule:

OSHA’s new rule reduces the Permissible Exposure Limit (PEL) to 50 ug/m³ (micrograms per cubic meter) and sets an actionable level of 25 ug/m³. Additionally, OSHA has increased the regulation from a half-page to a 30 page, extensive document.

Along with the new regulation comes increased fees for citations. What was once a $7,000 maximum for serious citations has become a $12, 675 maximum, with rates adjusting for inflation every year.

OSHA area offices are prepared for implementation and will be seeking companies to fine with a standard packet of four citations: Silica Control, Written Silica Plan, Medical Surveillance, and Training.

These four citations total penalties up to $50,700 and constitute eligibility for a press release shaming the company.  

Employers are Required To:

  • Develop a written exposure control plan
  • Train workers on silica risks and how to limit exposures
  • Use engineering controls (such as water or ventilation) to limit worker exposure to the PEL
  • Provide respirators when engineering controls cannot adequately limit exposure
  • Limite worker access to high exposure areas
  • Offer medical exams to highly exposed workers

Full Webinar on Silica

Join our President, Steve Yates, and Director of Operations, Drew Page, as they break down the specifications of OSHA’s Final Rule on Silica. This one-hour webinar includes:

  • An introduction to the standard
  • Discussion of Exposure Control Methods
  • Necessary medical examinations
  • Steps for compliance

Ready to Watch Webinar?

Need Assistance With Silica Safety?

We’re Here to Help You Plan for Silica Exposures

Our Experienced Safety Professionals Will:

  • Visit your facility for a Walk Around Inspection
  • Help you develop a Strategy for Compliance
  • Develop an Air Monitoring Plan
  • Help you identify New Engineering Controls to limit exposures
  • Determine necessary Exposure Control Plans

Let us guide you through this difficult process. Contact us today to start preparing for the new Silica Standard!

Either fill out this contact form or call us at 630.759.9908.

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FAQs

I understand the enforcement date for construction has been pushed to September. Do you anticipate another delay in enforcement?

After speaking with the Directorate of Construction Enforcement in Washington D.C., we do not anticipate any further delay in enforcement from OSHA. You can expect enforcement to begin at the dates specified for your industry.

Will OSHA offer a 'trial period' after enforcement deadline before issuing citations?

We must remember that OSHA is foremost an enforcement agency. They have provided ample time for employers to study, understand and implement the standard and are ready to get to work. Once the enforcement date is upon us, OSHA’s role is simply to enforce the rule by issuing citations. We have been made aware that the area offices are poised to issue a standard ‘package’ of four serious citations for $50,700, which is over the limit to issue a press release!

How many workers do you need to measure for silica exposure per crew?

25% – Industrial Hygiene Sampling best practice indicates at least 25% of the crew. For example, if you have 100 employees and 10 of them are exposed to a silica generating activity, you would test three of those employees!

If my task is on Table 1, do we need to maintain record exposure monitoring?

No, tasks that are listed on Table 1 do not require exposure monitoring if the OSHA recommended exposure controls are followed. Therefore, there would be no exposure monitoring data to maintain.

If my task is on table 1, is it adequate to simply apply the control that OSHA recommends if there is still a visible dust cloud?

NO, the standard requires that you apply whatever controls are available to eliminate or minimize a visible dust cloud. For example, increasing water flow to eliminate fugitive dust would be required.

Do we have to keep logs of which employee wore a respirator on which day?

Not unless you have an employee who infrequently (less than 30 days per year) wears a respirator. You might want to keep a log to have proof that their use did not exceed 30 days annually.

Are Precast Concrete Product Manufacturers required to include a Safety Data Sheet with their product when it is shipped?

YES, absolutely. The product contains silica and therefore a Safety Data Sheet (SDS) with the appropriate warnings must be provided. Members of the Precast/Prestressed Concrete Institute (PCI), can find an SDS for their product on the PCI Member website.