Page 36 - Occupational Health & Safety, October 2019

CONSTRUCTION
The Worker Exposure Plan
Understanding 1926.1153 Respirable Crystalline Silica for Construction.
BY KENT CRYTZER
In 2017, OSHA revised the silica standard which was written with typical OSHA health hazard controls such as assessing your employee’s poten- tial exposure, having your hazard communication
in place and ensuring an effective respirator program is being enforced.
OSHA added a few unique twists to the silica standard that will assist the construction industry with compliance measures, such as the Specified Ex- posure Control Methods, more commonly known as “Table 1.” Table 1 consist of 18 common tasks using various types of tools or equipment found at construction sites.1 If an employer chooses to follow this table, he or she is not required to conduct expo- sure assessments.
The objective of this article is to discuss developing a worker exposure control plan that can help to meet industry compliance. The plan is required to consist of the following elements:
• company name
• the person completing the plan
• tasks and activities that involve exposures to
crystalline silica
• engineering controls, work practices, and re-
spiratory protection per identified task
• housekeeping measures
• how to restrict access to work areas
• identification of the competent person Employers should first create a list of activities that
may generate silica exposure. This list should consist of the specific equipment used to determine the ac- tivities and the type of respiratory protection needed to protect employees from silica exposure.
Then, the standard permits construction employ- ers to select from two methods of compliance to con- trol exposures to respirable crystalline silica. This can be completed through one of two options, scheduled monitoring or performance.
Scheduled monitoring requires air monitoring at the beginning stage of the task. Depending on the re- sults of this initial monitoring, an employer can antic- ipate the frequency of monitoring. If the initial moni- toring indicates that employee exposures are below the action level of 25 Ug/m3 then no further monitor- ing is required. If the monitoring indicates at or above the action level but below the PEL of 50 ug/m3, the employer must repeat monitoring every six months.
If monitoring reveals employee exposures are above the PEL, the employer must repeat monitoring within three months of the most recent monitoring. When two, non-initial results are taken consecutively, at least seven days apart but within six months of each
other, and both are below the action level, employers may stop monitoring.
If there are any changes in the work process, the employer must reassess exposures. The downside for most employers is that this option creates a heavy bur- den of monitoring. The second challenge of this op- tion is attempting to sample the sporadic task within the time requirements of the standard.
The second option for an employer to use and as- sist with their non-Table 1 activity is the performance option. This option allows the employer to use any combination of air monitoring data or objective data sufficient to accurately characterize employee expo- sures to respirable crystalline silica. When an employ- er utilizes an objective data record, the record must include the following information:
• the silica-containing material in question
• the source of the objective data
• the testing protocol and the result of testing
• a description of the process, task, or activity
• data relevant to the process, task, activity,
material, or exposures
• objective data should be available to employees Once the employer has obtained objective data,
then the program will describe respiratory protection used to limit employee exposure along with house- keeping procedures.
Under the standard, employers must not allow dry sweeping or dry brushing “where such activity could contribute to employee exposure to respirable crystal- line silica unless wet sweeping, HEPA-filtered vacu- uming or other methods that minimize the likelihood of exposure are not feasible.” In addition, employers must not allow compressed air to be used to clean clothing or surfaces where such activity could con- tribute to employee exposure to respirable crystalline silica unless: The compressed air is used in conjunc- tion with a ventilation system that effectively captures the dust cloud created by the compressed air, or no alternative method is feasible.2
The housekeeping requirements in the standard only apply where cleaning “could contribute to em- ployee exposure to respirable crystalline silica.” Em- ployers in limited situations where cleaning methods such as wet sweeping or HEPA-filtered vacuuming would not be effective or would create a hazard in the workplace are not required to use these cleaning methods. The example that OSHA shares in the small entity guide is using sweeping compound as a wet method practice.
The next required section will be procedures used to restrict access to the work areas from sil-
32 Occupational Health & Safety | OCTOBER 2019
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