Osha Silica Requirements

[Hard Rock Support]

Osha Silica Guidelines

[Mark Meriaux]

Thanks Hard Rock Tool for your commitment to safety and raising awareness about this new standard!

There are two OSHA standards:

• One for jobsites (Construction)
• One for shops (General Industry)

The good news is that the OSHA minimum action levels in fabrication shops ARE ACHIEVABLE with simple and inexpensive housekeeping practices. The MIA+BSI will be releasing additional education and record keeping tools to help with compliance with the General Industry standard before it becomes enforceable on June 23, 2018. If you already run an all-wet shop, you might think you are compliant with silica exposure levels, but the only way to know for sure (and prove it to OSHA) is to have air monitoring done.

Some general gontractors are requiring controls that may be more stringent than OSHA requirements (to protect themselves and you). These may require some substantial investments in HEPA vacuums or other engineering controls to work on their jobsites. A good site to prepare for the Construction Standard is: www.silica-safe.org

[RB Design]

Thanks Hard Rock Tool for your commitment to safety and raising awareness about this new standard!

There are two OSHA standards:

• One for jobsites (Construction)
• One for shops (General Industry)

The good news is that the OSHA minimum action levels in fabrication shops ARE ACHIEVABLE with simple and inexpensive housekeeping practices. The MIA+BSI will be releasing additional education and record keeping tools to help with compliance with the General Industry standard before it becomes enforceable on June 23, 2018. If you already run an all-wet shop, you might think you are compliant with silica exposure levels, but the only way to know for sure (and prove it to OSHA) is to have air monitoring done.

Some general gontractors are requiring controls that may be more stringent than OSHA requirements (to protect themselves and you). These may require some substantial investments in HEPA vacuums or other engineering controls to work on their jobsites. A good site to prepare for the Construction Standard is: www.silica-safe.org
[

Hey Mark, we are being required to come up with a program for complying with OSHA as it relates to silica. Have you gone down this route already and done testing and developed the program? We are a wet shop with a dry grinding dust booth.

[Mark Meriaux]

Hey Mark, we are being required to come up with a program for complying with OSHA as it relates to silica. Have you gone down this route already and done testing and developed the program? We are a wet shop with a dry grinding dust booth.

The new General Industry Standard (which governs fixed production facilities) isn't enforceable until June 23, 2018. Right now the current standard and levels are still enforceable. We (MIA+BSI) are working on an Exposure Control Plan (ECP) that can be used by shops to take care of most of the training and record keeping requirements of the new standard.

The only way to know if your employees are within the new levels is to have testing done.
The most affordable way to get tested are:

• Though your local OSHA On-Site Consultation Program - this is voluntary (i.e. you must request for them to come out) and they will help you define steps to get your shop 100% OSHA compliant. Most offices offer air and noise monitoring and they will also do a complete top-to-bottom walk thru of your entire facility. This is a separate office from the enforcement folks and you are already paying their salaries with your taxes, so use it! The closer we get to the new standard enforcement date, I expect that many offices will have a waiting list for testing. Go ahead and ask for it now to allow you ample time to make changes and re-test before the new standard is in effect.
• Your insurance carrier may provide safety consultation services and/or air and noise testing. Call your agent to see if this is available to you.
• Contact a private Industrial Hygienist Firm to come out and do testing. This can be costly, so be prepared if you choose this route.

Should you decide to keep operating with a dry grinding area, simply providing respirators won't be adequate. You will need to also implement a respirator use and training program. This is what OSHA enforcement will ask for if they see guys wearing respirators. An easier route may be to ditch the dry grinding altogether and adopt a 100% all-wet facility. The shops that I've spoken with who have test results below the new standard are 100% all-wet facilities.

[Dave.Scott]

To tag on Mark's post.
We just went through a silica air test and are a wet shop. We passed with ease.
The Person doing the test said that if we had a dry grind booth we would also need a clean area for the employee to change their clothing or get vacuumed off.

[RB Design]

Our dry grinding area has dust collection as well as the guys wearing respirators. I know, it looks dusty! Mark, when will you have the your ECP program ready? Would this program take the place of the other options, ie. OSHA coming out to do testing, or would it be applicable after the initial OSHA visit and testing?

[Mark Meriaux]

Our dry grinding area has dust collection as well as the guys wearing respirators. I know, it looks dusty! Mark, when will you have the your ECP program ready? Would this program take the place of the other options, ie. OSHA coming out to do testing, or would it be applicable after the initial OSHA visit and testing?

Ray,
The ECP will help satisfy one of the requirements of the new standard (training and record keeping). Here's OSHA's info page for compliance with the General Industry standard: https://www.osha.gov/dsg/topics/silicac ... itime.html
You'll need to be compliant with ALL of the bullet points on that page.
General Industry and Maritime Fact Sheet is a helpful document that outlines your responsibilities as an employer.

An ECP will not supplant testing or use of engineering controls. Your dust wall is considered an engineering control, and your ECP should include clearly define the use and maintenance of it (and your other engineering controls). Respirators fall under another OSHA standard that requires additional training, record keeping, and medical rules for compliance. As David mentioned, you will be responsible to provide an area for your employees to wash, remove, or dispose of contaminated clothing or gear. In the future (additional "steps" in the standard), you will be required to provide baseline and regular medical testing (chest X-rays and lung function exams) for workers who use respirators on a regular basis.

Testing does two things:
1) It helps you identify any "problem" areas or bad habits taking place in your shop. You can focus engineering controls and housekeeping efforts on the specific affected areas (like your dry room).
2) It satisfies one of the requirements for OSHA record keeping under the new standard. If you are able to have a specific tasks or work areas test below the Action Level, then those work areas or tasks will not require additional engineering controls. You will need to have testing performed annually, or any time there is a significant change in the work areas (i.e. new process or equipment) in your shop.

I expect our ECP to be released some time around TISE.