OSHA Silica Standard

Your Presenter

Gary Glader, CSP

Horton Safety Consultants

708-845-3662gary.glader@thehortongroup.com

OSHA – Silica in General Industry

Background

• Silica is a necessary element of many

everyday building materials

• Silica is one of the most abundant

minerals in the earth’s crust

• It’s been known since the early 1700’s that

silica is harmful when inhaled

Regulatory History

• No comprehensive standards existed, only

permissible exposure limits (PEL’s)

• Until the new standard was issued, PEL’s

for silica were calculated using percent of

silica content in a formula

Regulatory Justification

• OSHA indicates 295,000 industrial workers

are exposed to silica containing dusts

• OSHA claims 27,000 in ready-mix

concrete operations are exposed

• OSHA also claims 20,000 of the 27,000

are exposed above the new PEL

• Industry sponsored studies indicate

otherwise

Regulatory Justification

• Exposure to silica linked to:

– Silicosis

– Lung cancer

– COPD

– Kidney disease

Compliance Deadlines

• Construction

– September 23, 2017

• General Industry & Maritime

– June 23, 2018

• June 23, 2021 – Engineering controls

• June 23, 2020 – Medical evaluations for employee

whose exposure exceeds AL > 30 days/year

– June 23, 2021 (hydraulic fracking)

OSHA Silica Standard – 1910.1053

Sections of Standard

• Scope & application

• Definitions

• Exposure limits

• Exposure assessment

• Regulated areas

• Methods of compliance

• Respiratory protection

• Housekeeping

• Medical surveillance

• Hazard communication

• Employee training

• Recordkeeping

Exposure Limits

• PEL 50 ug/m3 – 8 hour TWA

• AL 25 ug/m3 – 8 hour TWA

Exposure Assessment

• Options:

– Performance option – asses exposure using

combination of air monitoring or objective data

– Actual exposure monitoring data

• Frequency:

– Quarterly if exposures exceed PEL

– Semi-annually if exposures > AL < PEL

• Must reassess when changes occur

Regulated Areas

• Employers must identify areas where the

PEL is expected to exceed the PEL

• Warning signs must be posted

Methods of Compliance

• Engineering & work practice controls

– A must for employers to evaluate

• Written exposure control plan

– Must contain specific elements

– Must be evaluated annually

Respiratory Protection

• Must have written program (1910.134)

• Must comply with all elements of OSHA’s

respiratory protection program (1910.134)

Housekeeping

• Dry sweeping or brushing of silica

prohibited, unless it is infeasible

• Compressed air cannot be used for

cleaning unless a ventilation system is

used to capture dust

Medical Surveillance

• Required for employees exposed to silica

greater than the PEL 30 days per year

• By June 23, 2020 required for employees

exposed to silica greater than the AL 30

days per year

• Within 30 days of assignment

Medical Surveillance

• Elements of examination

– Medical & work history

– Physical exam with focus on respiratory

– Chest x-ray certified by B reader

– Pulmonary function testing

– Test for tuberculosis

– Any other test deemed appropriate

Hazard Communication

• The communication of hazards associated

with exposure to silica must be included in

the Hazard Communication Program

(1910.1200)

• Appropriate signage, safety data sheets,

and labels must be obtained

Training

• In addition to Hazcom, the following must

be addressed in training:

– Health hazards associated with silica

– Tasks that result in exposure

– Measures the employer implemented to

protect from exposure

– The contents of the OSHA standard

– Purpose and description of medical evaluation

Training

• NOTE! – OSHA requires employees

demonstrate knowledge and

understanding of the previous items

• This will require comprehension testing

Recordkeeping

• All exposure monitoring data

• All objective data used

• Medical surveillance documentation

provided to the employer

Comments

• Recent exposure monitoring data is the

most reliable form of assessment

• The use of objective data to establish an

assessment requires extensive data and

similarities to the work environment

Comments

• Because illnesses such as COPD are tied

to silica exposure, aggravation of pre-

existing conditions in those who smoke

are likely to surface during exams

• In existing employees, this may translate

into workers’ compensation claims under

the disease statute

Comments

• Engineering and work practice controls

that reduce exposures below the PEL and

AL eliminate the requirement for medical

monitoring and respirator use

Exposure Control Methods