Page 43 - Occupational Health & Safety, January/February 2019

mary focus areas that inspectors will be looking at when visiting your facility. Please read the actual document for details to what an inspector would be looking for. Only a brief comment is added about each of these categories below:
1) Permissible Exposure Limit (PEL):
The PEL is 0.05 mg/m3 and the action level is half that amount. You are expected to know what job tasks potentially involve expo- sure to this dust and have monitoring results.
2) Exposure Assessment:
This is a section that expects the employer to confirm whether employees might be exposed even above the action level. If you use “objective data,” it will be scrutinized to make sure it is relevant to your work scenario.
3) Regulated Areas:
This pertains to keeping non-essential employees out of the high-risk areas using signage and/or movable stanchions, cones, or barrier tape.
4) Methods of Compliance—engineering and work practice controls:
What are the ways you are keeping the dust under control? Do you have a legitimate reason why specific engineering and/or work practice controls might not be feasible?
5) Written Exposure Control Plan:
Make sure you have all the required elements of your written exposure control plan. A plan is needed if you are above the action level for this dust.
6) Abrasive Blasting:
This only pertains to employers using this equipment, but this activity can create a tremendous amount of dust.
7) Respiratory Protection:
If respirators are still required (over the PEL) after looking at work practices/engineering controls, you obviously need to follow all requirements of a respiratory program.
8) Housekeeping Practices:
Dry sweeping and compressed air are NOT allowed where such activities could contribute to employee exposure to this dust.
9) Medical Surveillance:
Employees must have medical evaluations be made available if exposed above the PEL for 30 days or more per year. In two years, this requirement will be more strict, requiring a medical evaluation if over the AL for 30 days or more per year.
10) Communication of Hazards:
Training is required for employees exposed at or above the AL over an eight-hour day. Respirable crystalline silica has to be part of the Hazard Communication program.
Worker Protections
One aspect that is commonly overlooked when dealing with toxic dust hazards (lead, hexavalent chromium, asbestos) is what the em- ployee is taking home with them—dust on their clothing. You need to consider how you either protect workers with disposable cloth- ing, laundering services at work, or vacuum systems using a HEPA filter. Both clothes and footwear can carry a significant amount of dust that gets deposited in vehicles and your home at the end of a work shift. Nobody should be further exposing their family to this danger. Many employees still use air guns to blow dust off their clothing, a practice that is not allowed by OSHA and can poten-
tially increase your breathing exposure.
When I have done air sampling at various manufacturing loca-
tions, high risks for exposure commonly occur only at brief inter- vals during a work shift. If you can pinpoint those worker activities (such as cleanup at the end of a shift) where respirable dust levels spike, coming up with feasible work control options is much easier to resolve.
While getting familiar with the OSHA standard for a given safety category is important, I especially like the idea of reviewing the “enforcement guidance” posted for a specific standard. It gets to the heart of what OSHA feels are key aspects of how it expects em- ployers to comply and ultimately keeping your workers safe. Find this document on OSHA’s website and understand what to expect if OSHA comes knocking.
Michael Tesmer, CSP, is a Safety Services Manager for Conney Safe- ty Products (a division of Wesco Distribution). He has been providing safety training and consultation services throughout the United States since joining Conney 25 years ago.
REFERENCES
1. cited source: Hilti Silica Dust Webinar FAQ section, Page 4, June 23, 2017
Retrieved from: https://www.hilti.com/content/dam/documents/pdf/w1/ dust-solutions/webinar/Silica-Dust-FAQs_Webinar.pdf
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