Page 24 - Occupational Health & Safety, September 2018

INDUSTRIAL HYGIENE
what can be accomplished using respirators alone.
There are several reasons respirators aren’t as protective or as
practical as engineering controls. First, they need to be selected and fitted for each individual. There is no acceptable one-size- fits-all approach. For example, a 2016 article in Safety+Health magazine addressed the challenges of fitting respirators for men who have facial hair, particularly during cultural events like Mo- vember (aka No Shave November).5 And while there have been great strides in protective equipment for women, many women are still injured on the job because their PPE isn’t available in an appropriate size.6
Respirators also need to be maintained correctly—they won’t work if the HEPA filter is clogged. And they need to be worn properly and consistently, which, unfortunately, they aren’t be- cause, as OSHA notes, they can be uncomfortable (especially in high-temperature areas).
For these reasons and more, respirators simply aren’t enough. The only way to ensure that employee exposure is kept below the PEL is by implementing the required engineering and work prac- tice controls to reduce employee exposure to silica dust. This in- cludes proper housekeeping using a HEPA-filtered vacuum cleaner.
“OSHA will be lenient.”
The Trump administration’s focus on deregulation has had an impact on new worker safety laws. We’ve seen multiple delays to standards already adopted as well as standards-in-progress being
dropped from the regulatory agenda. This has led some employers to take a more relaxed view toward compliance in the hope that OSHA will be more lenient.
However, those hopes have not come to fruition. In 2017, the number of OSHA inspections increased for the first time in five years. This was despite the fact that there were fewer OSHA inspectors.7
On the silica front, general industry employers can look to what has happened in the construction industry, where a silica dust stan- dard became enforceable last September. A Bloomberg analysis of the first six months of the standard’s enforcement found a total of 116 citations.8
Here are the top three reasons companies were cited:
■ Failing to measure silica exposure levels (35 violations)
■ Failing to follow the procedures on Table 1, as well as the
required engineering and work control methods and respiratory protection (31 violations)
■ Lack of a written exposure control plan (20 violations)
Overall, 80 percent of the violations were considered serious, which means they posed an immediate threat to workers.
It’s likely that the number of citations issued for silica dust vi- olations will increase with time. First, during the first 30 days of enforcement for the construction industry, a “good faith” provi- sion was in place, meaning that inspectors didn’t issue citations to employers demonstrating an effort to comply (a good faith provi- sion is also in place for general industry). In addition, September through April isn’t exactly peak construction season. And, finally,
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