In November, OSHA released a new Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for Construction. Earlier in March, OSHA issued a final rule lowering the permissible exposure limit to 50 micrograms of respirable crystalline silica per cubic meter of air during an eight-hour period for all industries.
The new OSHA guide is divided into sections that correspond to the major provisions (paragraphs) of the silica standard for construction. Each section describes the provision and gives additional details to help employers better understand the requirements of the standard. The first step for a construction employer is to determine if the standard applies to its work. If its work is covered by the standard, an employer has two options for limiting employee exposure to respirable crystalline silica: (1) specified exposure control methods; or (2) alternative exposure control methods.
Specified Exposure Controls. Employers who choose the specified exposure controls option must fully and properly implement protections for the tasks or equipment listed in Table 1 of the standard. Employers who fully and properly implement the controls in Table 1 do not have to assess employees’ silica exposure levels or keep employee exposures at or below the permissible exposure limit (PEL).
Alternative Exposure Controls. Employers who follow alternative exposure control methods must: (1) Determine the levels of respirable crystalline silica that employees are exposed to; (2) limit employee exposures to a PEL of 50 micrograms per cubic meter of air (50 μg/m3 ) as an 8-hour time-weighted average (TWA); (3) use engineering and work practice controls, to the extent feasible, to limit employee exposures to the PEL, and supplement the controls with respiratory protection when necessary; and (4) keep records of employee exposure to respirable crystalline silica.
All employers covered by the standard must:
- Provide respiratory protection when required;
- Restrict housekeeping practices that expose employees to respirable crystalline silica where feasible alternatives are available;
- Establish and implement a written exposure control plan, including designating a competent person;
- Offer medical exams to employees who will be required to wear a respirator under the standard for 30 or more days a year;
- Communicate hazards and train employees; and
- Keep records of medical examinations.