As a result of the new and revised 2017 OSHA regulation for respirable crystalline silica, OSHA has been trying to clear any questions concerning compliance.

Master Sgt. Donnie Bogan saws cutting lines in concrete

Master Sgt. Donnie Bogan saws cutting lines in concrete, licensed under the terms of the United States Government Work.

The controversial crystalline silica guideline from OSHA took effect on June 23, 2016.  Industrial sectors had between one and five years to fully comply with the new standard.  The building and construction sector’s conformity day was Oct. 23, 2017.

The regulation lowered the Permissible Exposure Limit (PEL) required dust controls as well as safer work techniques and called for employers to offer respirators to employees when other safe job techniques were unable to restrict respirable crystalline dust exposure.

Employers need to evaluate the exposure of each worker that is or may reasonably be anticipated to be subjected to respirable crystalline silica at or above the authorized limit making use of either an efficiency alternative or a set up monitoring option.

According to Bloomberg Environmental, a Virginia construction company was issued five citations for crystalline silica violations totaling $304,130 USD.  The fines could be the largest fines ever under the new silica standard.

Recently, OSHA released a brand-new silica standard Frequently Asked Question (FAQ) to offer some clarification. The new FAQs were created after talking to the general industry and industry stakeholders.

The goal of the new silica standard FAQ is to give further guidance to both companies and employees on the silica standard’s requirements.  The areas highlighted are methods of compliance, exposure assessments, regulated areas, and communication of respirable silica hazards to employees.

Here are three frequently asked questions published in the OSHA General Industry FAQ.

Q: Can employers use data from real-time monitoring and exposure mapping to assess employee exposures under the performance option?

A: Yes. Data generated by real-time monitoring of respirable dust levels (conducted using direct-reading instruments) can be combined with exposure mapping to assess employee exposures under the performance option, provided that the data can be correlated with individual employee exposures and otherwise meet the requirements for objective data. OSHA notes that in order to estimate the level of respirable crystalline silica in the air using real-time monitoring data, employers must also know the percentage of silica in the dust (e.g., from the analysis of a bulk sample or information from a safety data sheet). If an employer does not know the percentage of silica in the dust, it can assume 100% of the respirable dust is silica for purposes of determining worst case exposures from real-time monitoring data under the standard.

Q: If an employer characterizes employee exposures under the performance option using objective data from real-time monitoring and exposure mapping, how often does the employer need to repeat the monitoring and mapping process?

A: The goal of the performance option is to give employers flexibility to accurately characterize employee exposures using whatever combination of air monitoring data or objective data is most appropriate for their circumstances. Therefore, OSHA has not specified exactly how often data should be collected for these purposes. Employers may rely on existing data as long as the data continues to be sufficient to accurately characterize employee exposures. OSHA notes, however, that accurately characterizing employee exposures is an ongoing duty, and employers must reassess exposures whenever a change in the production, process, control equipment, personnel, or work practices may reasonably be expected to result in new or additional exposures at or above the AL, or when the employer has any reason to believe that new or additional exposures at or above the AL have occurred. See 29 C.F.R. § 1910.1053(d)(4)

Q: If personal sampling results show that one employee, who works in a small, non-enclosed area of a large building, is exposed above the PEL, but another employee, who is only a short distance away, is exposed below the PEL, how does the employer decide how far to extend the regulated area?

A: Because there is an exposure above the PEL, the facility must determine which task or operation is creating the overexposure and create a regulated area around that task or operation. In the example provided, the regulated area may include only the first employee’s work station. If the second employee is not exposed above the PEL and is not reasonably expected to be exposed above the PEL, the regulated area does not have to cover that employee’s work area. An employer could choose to use area sampling, real-time monitoring, or exposure mapping to assist in identifying the boundaries of a regulated area.

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For a full copy of the General Industry FAQ please see this link -> https://www.osha.gov/dsg/topics/silicacrystalline/generalindustry_info_silica.html

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