OSHA Provides Additional Respirable Crystalline Silica Resources

ICPI

With OSHA set to increase enforcement of the respirable crystalline silica standard this year, hardscape contractors need to educate themselves and the workers about the regulation and the risks.

Effective September 23, 2017, construction employers are required to comply with all requirements of the standard. OSHA has created a website that provides useful information about silica and the standard (https://www.osha.gov/dsg/topics/silicacrystalline) with additional focused information for the construction industry (https://www.osha.gov/dsg/topics/silicacrystalline/construction.html).

ICPI encourages you to visit this website and review the information to make informed decisions about limiting workers exposure to silica.

The regulation can be summarized as the following seven requirements:

  1. Limiting workers exposure to respirable crystalline silica;
  2. Establishing and implementing a written exposure control plan;
  3. Designate a competent person to implement the written exposure control plan;
  4. Restrict housekeeping practices that expose workers to silica, such as use of compressed air and dry sweeping, where effective, safe alternatives are available;
  5. Offer medical exams—including chest X-rays and lung function tests—every three years for workers who are required by the standard to wear a respirator for 30 or more days per year;
  6. Train workers on the health effects of silica exposure, workplace tasks that can expose them to silica, and ways to limit exposure; and
  7. Keep records of workers’ silica exposure and medical exams.

An employer has two options when addressing the first requirement, to limit workers exposure to respirable crystalline silica.

  1. Implement the Engineering and Work Practice control methods for the 18 different activities described in Table 1 of the standard, or
  2. Utilize Alternative Exposure Control Methods which requires,
    1. Determine the amount of silica that workers are exposed to if it is, or may reasonably be expected to be, at or above the action level of 25 μg/m3 (micrograms of silica per cubic meter of air), averaged over an 8-hour day;
    2. Protect workers from respirable crystalline silica exposures above the permissible exposure level (PEL) of 50 μg/m3, averaged over an 8-hour day;
    3. Use dust controls and safer work methods to protect workers from silica exposures above the PEL; and
    4. Provide respirators to workers when dust controls and safer work methods cannot limit exposures to the PEL.

The easier solution is to implement the Engineering and Work Practice control methods identified in Table 1. OSHA has developed several Fact Sheets and Videos to help employers to implement exposure control plans that meet the requirements of Table 1 activities. Of the tasks/equipment combinations listed in Table 1, the two that are most relevant to the hardscape industry are:

The directions in Table 1 for both Stationary Masonry Saws and Handheld Power Saws require water to be applied to the blade and material being cut to suppress the creation of dust. Unfortunately, using water to cut concrete pavers will create a slurry, which will stain the pavement surface, if not cleaned off immediately. Also, applying water to cut pavers in place with a handheld power saw will apply water to the uncompacted bedding sand, causing it to be displaced and making the initial paver compaction completely ineffective. This will lead to installations that do not meet industry standards.

For now, it appears hardscape contractors will need to utilize the alternative exposure control methods which means monitoring workers exposure to respirable crystalline silica.

The technology that seems the most promising is concrete saws with integrated vacuum systems to collect any dust created including the respirable crystalline silica. ICPI encourages hardscape contractors to investigate these systems to see if they suit your requirements and can be implemented in your construction procedures. ICPI, along with several other construction industries, continue to discuss the inclusion of concrete saws with integrated dust collection systems into a future update of Table 1.