3M OSHA Silica Regulation Compliance

Do You Know How to Comply with the OSHA Silica Regulation?

Have you taken the necessary steps to comply with the new OSHA silica standard?

ST. PAUL, Minn.—  3M has resources developed by safety professionals and certified industrial hygienists to help you on the journey to comply with new US OSHA 29 CFR 1926.1153 regulation.

You should be well on your way to doing a variety of actions to help you comply, such as:

  • Identifying a silica competent person and ensuring they are trained appropriately
  • Developing a written exposure control plan
  • Implementing the exposure control plan
  • Conducting frequent and regular inspections of the job site and modifying the plan as conditions change, including what personal protective equipment (PPE) is needed and what training is required to ensure people use the PPE properly
  • Calling in qualified persons to support the competent person with complex or unique situations
  • Reviewing the plan at the end of the project for lessons learned and incorporating them into future plan

But you may also be asking yourself, how will the OSHA silica rule protect workers’ health?

According to OSHA, this new rule requires that employers use engineering controls − such as ventilation and wet methods for cutting and sawing crystalline silica-containing materials − to help reduce workers’ exposure to respirable silica dust. OSHA notes that such measures will help to reduce cases of silicosis, lung cancer, other respiratory diseases and kidney disease.

How Can Silica Exposures be Controlled to Keep Exposure at or Below the PEL?

Employers must use work practices and engineering controls as the primary ways keep exposures at or below the Permissible Exposure Limit (PEL). Engineering controls include wetting down work operations or using local exhaust ventilation (such as vacuums) to keep silica-containing dust out of the air and out of workers’ lungs. Another control method that may work well is enclosing an operation (“process isolation”).

More importantly, respirators are only allowed when engineering and work practice controls cannot maintain exposures at or below the PEL.

Specifically, for construction the standard includes Table 1, a list of common construction tasks along with exposure control methods and work practices that can be used to comply with the requirements of the standard.

Why can’t silica-exposed workers just wear respirators all the time?

Respirators, per U.S. OSHA regulation, can only be used if engineering and work practice controls are either infeasible or cannot control the worker’s exposure below the permissible limit. Respirator use requires that the respirator be properly selected and worn at all times in order to get the expected protection. OSHA also requires various other aspects be fulfilled in a complete respiratory program, such as fit testing, medical evaluation, training and maintenance of the respirator.

What is the Purpose of Silica Medical Surveillance?

According to OSHA, the purpose of the silica medical surveillance is to:

  • Identify adverse health effects associated with respirable crystalline silica exposure so that appropriate actions can be taken
  • Determine if an employee has any condition, such as a lung disease, that might make him or her more sensitive to respirable crystalline silica exposure
  • Determine the employee’s fitness to use respiratory PPE

In response to the information gained through medical surveillance, employees can take actions to improve their health, such as making job choices to reduce exposures, wearing a respirator for extra protection, or making personal lifestyle or health decisions, such as quitting smoking.

When must employers comply with the standard for General/Industry and Maritime?

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

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

For hydraulic fracturing operations in the oil and gas industry:

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

Still need help complying with the OSHA silica standard? Contact our technical specialists today; we offer education, products and training to help you provide a safe and compliant work environment.