OSHAs Respirable Crystalline Silica Standard for Construction: - PowerPoint PPT Presentation

OSHA’s Respirable Crystalline Silica Standard for Construction: Implementation Update ACPA Annual Meeting November 29, 2018

• Final Rule published on March 25, 2016 • OSHA began enforcing the standard for construction on September 23, 2017

Construction Standard (a) Scope (b) Definitions (c) Specified exposure control methods OR (d) Alternative exposure control methods (1) PEL (2) Exposure Assessment (3) Methods of Compliance (e) Respiratory protection (f) Housekeeping (g) Written exposure control plan (h) Medical surveillance (i) Communication of silica hazards (j) Recordkeeping (k) Dates

Federal OSHA Enforcement (as of 11/26/2018) • Citations issued for 557 violations of the silica standard for construction • Current penalties total over $842,000 • Most commonly cited provisions: o Specified exposure control methods (131) o Exposure assessment (130) o Written exposure control plan (91) o Communication of hazards (50)

Example of a Table 1 Entry Required Respiratory Equipment Engineering and Work Practice Protection and Minimum APF / Task Control Methods ≤ 4 > 4 hr/shift hr/shift Walk-behind Use saw equipped with integrated saws water delivery system that continuously feeds water to the blade. Operate and maintain tool in accordance with manufacturer's instructions to minimize dust emissions. None None - When used outdoors. APF 10 APF 10 - When used indoors or in an enclosed area.

Alternative Exposure Control Methods – Exposure Assessment • Assess exposures if they may reasonably be at or above the action level of 25 µg/m 3 • Two options for exposure assessments: o The performance option or o The scheduled monitoring option

Construction – Written Exposure Control Plan • The plan must describe: o Tasks with exposures o Engineering controls, work practices, and respiratory protection for each task o Housekeeping measures used to limit exposure o Procedures used to restrict access, when necessary to limit exposures

Communication of Hazards • Comply with hazard communication standard (HCS) (29 CFR 1910.1200); address: o Cancer o Lung effects o Immune system effects o Kidney effects • Train workers on: o Health hazards o Tasks with exposure o Workplace protections o ID of competent person o Silica standard o Medical surveillance

Table 1 RFI • OSHA will publish a Request for Information (RFI) in the Federal Register • Evaluating possible revisions to Table 1 • Will include questions on specific dust control methods and tasks • OSHA is particularly interested in evidence on the effectiveness of dust control methods • OSHA will evaluate the information received • If evidence supports changes, OSHA will publish proposed revisions for public comment

Guidance and Outreach • Silica Webpage: www.osha.gov/silica o Small Entity Compliance Guide o FAQs o Fact sheets o Videos o Training PowerPoint o Interim enforcement guidance

Questions?