New OSHA Silica Dust Standards Make Catching Your Breath Easier

New standards put forth by the Occupational Safety and Health Administration (OSHA) are underway and will soon help provide better protection for workers exposed to crystalline silica in construction, maritime and general industry. Crystalline Silica, a common mineral identified in the earth's crust, can be found in a variety of materials including concrete, sand, stone and mortar. When broken down into very small particles through cutting, sawing, sanding, grinding, or drilling, crystalline silica can pose a very serious health threat to workers who inhale this dust. As it is known, respirable crystalline silica puts workers who inhale these microscopic particles at an increased risk for developing serious silica-related diseases including lung cancer, chronic obstructive pulmonary disease, kidney disease and silicosis, an incurable lung disease that may lead to disability or death. It is estimated that approximately 2.3 million people in the U.S. are exposed to silica at work. By reducing the Permissible Exposure Limit (PEL) to 50 micrograms of respirable crystalline silica per cubic meter of air, OSHA hopes to save over 600 lives and prevent more than 900 new cases of silicosis each year. Averaged over an 8 hour day, the new PEL is half the previous limit for maritime and general industry and five times lower than the previous limit for construction. Under these new rules, the air employees breathe must be regularly sampled and analyzed to ensure that exposure levels do not exceed these limits. However, employers in the construction industry who are fully and properly implementing the engineering controls, work practices, and respiratory protections as specified by OSHA in Table 1  (a flexible compliance option for the construction industry), are not required to comply with the air sample measurement requirements as noted above.

In addition to the lower PEL levels and air sample provisions detailed in these new OSHA regulations, the new standards require both general industry and maritime employers to have a written exposure control plan in place as well as engineering and work practice control procedures.

Written Exposure Control Plans Must Include:

• A description of the tasks that put workers at risk
• A description of the engineering controls, work practices and respiratory protection used to limit exposure for each task
• A description of the housekeeping methods used to limit exposure

In support of the delivery and compliance of these new regulations, OSHA has outlined the following engineering control and work practice recommendations for maintaining the designated PEL levels in affected work environments:

• Implementing engineering controls and safe work practices: Effective engineering controls as described include wetting down work operations, process isolation, or using local exhaust ventilation (such as vacuums) to keep silica-containing dust out of the air and out of workers' lungs. HEPA-filtered vacuuming is an example of a housekeeping method that minimizes employee exposure to respirable crystalline silica. These filters are at least 99.97% efficient in removing mono-dispersed particles of 0.3 micrometers in diameter. Respiratory protection may only be used when engineering controls are insufficient at reducing PEL levels.
• Regulated Area Designation - Employers must designate high-exposure areas where PEL levels may be above the allowable limits.
• Education and Training - Employees must be educated and trained on operational hazards  and proper work practices to minimize silica dust exposure.
• Medical Examinations - Workers exposed to over 25 micrograms per cubic meter, for 30 days each year, must be provided medical surveillance to help identify adverse health effects associated with respirable crystalline silica exposure and take appropriate action when needed.

The roll-out of these new standards will occur over a 4 year time period which began on September 23, 2017 for operations in the construction industry. Subsequently, the following compliance dates should be noted and every effort should be made to ensure that appropriate measures are in place to comply with these regulations by the dates listed below.
Construction Industry: 

• September 23, 2017: Employers are expected to comply with all obligations of the standard (except methods of sample analysis).
• June 23, 2018: Employers are required to comply with methods of sample analysis.

For all operations in general industry and maritime, other than hydraulic fracturing operations in the oil and gas industry:

• June 23, 2018: Employers are required to comply with all obligations of the standard, with the exception of the action level trigger for medical surveillance.
• June 23, 2018: Employers are required to offer medical examinations to employees exposed above the PEL for 30 or more days a year.
• June 23, 2020: Employers are required to offer medical examinations to employees exposed at or above the action level for 30 or more days a year.

For hydraulic fracturing operations in the oil and gas industry:

• June 23, 2018: Employers are required to comply with all obligations of the standard, except for engineering controls and the action level trigger for medical surveillance.
• June 23, 2018: Employers are required to offer medical examinations to employees exposed above the PEL for 30 or more days.
• June 23, 2020: Employers are required to offer medical examinations to employees exposed at or above the action level for 30 or more days a year.
• June 23, 2021: Employers are required to comply with requirements for engineering controls to limit exposures to the new PEL.
• *June 23, 2018 - June 23, 2021*: Employers can continue to have employees wear respirators if their exposures exceed the PEL.

For additional resources and compliance assistance, please visit OSHA's Crystalline Silica Rulemaking page. On-site consultation is available at no charge to small and mid-sized businesses interested in getting a jump-start on these standards.