Page 42 - Occupational Health & Safety, January/February 2019

RESPIRATORY PROTECTION
Respirable Crystalline Silica in General Industry
Understanding the OSHA enforcement guidance will help you. It gets to the heart of what OSHA feels are key aspects of how it expects employers to comply.
BY MICHAEL TESMER
For most OSHA standards, OSHA uses a “Compliance Directive” to help guide Com- pliance Safety and Health Officers (CSHOs) when inspecting a given workplace. How-
ever, OSHA’s 13-page interim enforcement guid- ance document, effective June 23, 2018, is to be used while the standard’s companion compliance directive is proceeding through the review process (which could literally take years). It should be a sim- ilar, but more detailed document to assist CSHOs during their inspections.
While we already know this standard has been dramatically impactful to many construction com- panies all over the United States, there are still plenty of manufacturing facilities that are affected by this standard, either in a small or a big way. If you are not sure if this standard applies to you, I suggest you think about the different work activities at your facility:
■ Look at the safety data sheets for your manu- facturing process. Is there the potential for crystalline silica to become airborne?
■ Are any of the production or maintenance workers actively cutting, drilling, or grinding into concrete/cement, brick, tile, asphalt, or stone type ag- gregates on a semi-regular basis?
It wouldn’t hurt to talk to the plant manager (or other key production or maintenance supervisors) about any situations that they might be aware of re- lated to this topic. What gets really tricky is when maintenance workers are drilling a couple of holes into a concrete wall to feed some conduit for a new drill press going into a room (example). Are you re- quired to have a written exposure control plan for these “one-off ” scenarios? What constitutes an infre- quent scenario that would avoid being covered by this standard? Luckily, OSHA put out a FAQ for the con- struction industry that addresses this very topic, and it would apply to general industry tasks performed by maintenance workers. (Note: it is the second of 53 FAQs found on this list: https://www.osha.gov/dsg/top- ics/silicacrystalline/construction_info_silica.html)
Respirators and Controls
Once you determine that your employees could be affected by this standard, you have to realize that air monitoring for the respirable crystalline silica will be inevitable, needed to help gauge where you are with employee exposure. This entire standard is based on keeping this specific dust below the Permissible Ex- posure Limit (PEL) and preferably even the Action Level (AL).
As you might already know, simply giving your employees a respirator is not going to solve this com- pliance problem. (In fact, you will be cited by OSHA if your only course of action is to hand out respirators!) Ultimately, OSHA is expecting you to look at feasible engineering controls to deal with airborne exposure. This might involve ventilation systems, vacuums, and/ or water spray options. If you know there is crystal- line silica in a product you work with, knowing the percentage of crystalline silica is important. As an ex- ample, most concrete in the United States contains 5 to 40 percent silica.1
The higher the concentration of silica in concrete (or whatever substance you use that contains silica) simply implies you are at more risk for overexposure if the dust becomes airborne. We have seen examples where simply sweeping a concrete floor can affect the amount of respirable silica dust in the air, even if the employer did not use a product containing silica in their operation.
Ten Focus Areas for OSHA Inspections
Getting back to OSHA interim enforcement guidance (easy to find on the OSHA website), there are 10 pri-
36 Occupational Health & Safety | JANUARY/FEBRUARY 2019
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