Quick, can you explain OSHA’s field inspection and enforcement procedures for respirable crystalline silica? We wouldn’t blame you if you can’t; the official inspection guidance from the agency is over 120 pages long!
That said, OSHA does have a standard for silica exposure that you must adhere to, so this article will help you answer the following critical questions about OSHA silica compliance:
Respirable crystalline silica is effectively dust created by the cutting, grinding, crushing, or drilling of most types of stone, rock, concrete, brick, or mortar. Industrial sand used in fracking can also emit silica dust.
The particles emitted from these activities are multiple times smaller than grains of sand – so they’re not always visible. It’s estimated that almost 2.5 million people are exposed to silica in their jobs.
OSHA has actually developed two separate crystalline silica standards: one specific to construction and another for general industry and maritime. In large part, these standards are the same. For both, the permissible exposure limit (PEL) is an 8-hour time-weighted average of 50 micrograms per cubic meter (50 μg/m³).
The primary difference between the two standards is the inclusion of OSHA Silica Table 1 in the construction standard. Table 1 provides specified control methods for a list of construction tasks. When employers properly implement the controls and protection procedures outlined in the table, they are considered compliant and not required to measure individual workers’ exposure. That said, let’s explore full compliance with the OSHA silica standard.
In addition to adhering to the established PEL, the OSHA silica standard requires an exposure control plan. This plan, which must be administered by a person with knowledge, authority, and ability to eliminate or minimize silica dust hazards, should:
The person charged with implementing the exposure control plan is also responsible for regularly inspecting worksites and equipment.
There are generally two approaches to silica air testing: gravimetric and real-time monitoring. Gravimetric testing is more comprehensive and requires particles to be collected and shipped to a lab for analysis (which can take weeks). Real-time monitoring uses equipment to measure current readings and alert to unhealthy exposures.
The critical thing to take away from this is that OSHA requires gravimetric testing to confirm compliance.
However, the routine exercise of gravimetric testing can be costly, which is why a tactful approach to utilizing both gravimetric and real-time testing can ensure your sites are always compliant and protecting workers. For example, establish benchmark exposure levels with gravimetric testing, then use real-time testing to confirm conditions haven’t changed.
You can also benefit from using real-time testing anytime job site conditions change. The data can inform if the benchmark levels have changed and provide an opportunity to adjust conditions so you’re confident subsequent gravimetric tests will meet OSHA’s PEL.
OSHA requires careful records from your air tests, including:
These records must be accessible at all times to OSHA personnel, all employees, and any employees’ representatives.
Before even considering the actual testing itself, think about the necessary supervisor to oversee the control plan. Do you have a qualified person on staff? Qualifications can actually change depending on the specific task and required equipment, which leaves many companies needing multiple qualified personnel. Sometimes, it requires a different person for each shift and every job site.
With a safety provider, you get one person dedicated to this supervisory position – no need to potentially burden several of your staff members with additional duties. Furthermore, you can rest assured this third-party supervisor is adequately trained and certified to carry out the requirements of the standard.
As for the testing itself, expertise with the equipment and guidance is necessary to understand where to place the equipment and how to utilize it properly. A professional safety consultant can ensure your monitoring is accurate, effective, and meets regulatory requirements.
Utilizing an outsourced expert in silica air monitoring reduces your liability by sharing the responsibility of compliance. Additionally, the third party is independent and not influenced by company behaviors that could compromise compliance.
The cost of ensuring compliance is almost always less than the cost of failing to comply, which is why outsourcing to experts like SITEX makes respirable crystalline silica easy and reliable.
SITEX saves lives. For over 35 years we’ve delivered safety services, environmental services, industrial hygiene expertise, rescue solutions and training, and rental equipment to ensure compliance, reduce risk, protect workers, and promote safety in every industry. We invest in highly trained personnel and technology so you don’t have to.
