New and Final Silica Exposure Regulations

Comprehensive, Risk Management Solutions from Bureau Veritas


Silica Exposure RegulationWho is affected by the OSHA rule?
About 2.3 million workers are exposed to respirable crystalline silica in their workplaces. The majority of these workers, about 1.85 million, are in the construction industry. Exposures occur when workers cut, grind, crush, or drill silica-containing materials such as concrete, masonry, tile, and rock. About 320,000 workers are exposed in general industry operations such as brick, concrete, and pottery manufacturing, as well as operations using sand products, such as foundry work and hydraulic fracturing (fracking) of oil and gas wells. Workers are also exposed to silica during sandblasting in general industry and maritime workplaces. Click here for more information.


What does the rule require?
Bureau Veritas has the capabilities and experience to assist with all requirements of this new rule. Click here to get in touch with a Bureau Veritas representative.  Bureau Veritas can assist clients with each of the following requirements:



Written silica exposure control plan
The final standards require employers to develop a written exposure control plan, and the standard for construction requires a competent person to implement the plan.


Permissible exposure limit
Workers' exposures are limited to a new PEL of 50 micrograms of respirable crystalline silica per cubic meter of air (μg/m3), averaged over an 8-hour day. The new PEL is the same in all industries covered by the rule.  The action level is 25 μg/m3.  The silica exposure regulation standard requires initial monitoring, repeat monitoring, and monitoring following changes.


  • Initial Monitoring: OSHA requires that employers assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level in accordance with either the performance or the scheduled monitoring option.


  • Repeat Monitoring: If initial monitoring indicates that employee silica exposures are below the action level, the consultant may discontinue monitoring for those employees whose exposures are represented by the monitoring.


  • Monitoring Following Changes: The employer shall reassess exposures whenever a change in the production, process, control equipment, personnel, or work practices may reasonably be expected to result in new or additional exposures at or above the action level, or when the employer has any reason to believe that new or additional exposures at or above the action level have occurred.


Bureau Veritas’ team of industrial hygienists, located throughout the United States, can immediately support both the identification of workers that require exposure monitoring and the collection of samples.


Laboratory Methods
Employers must ensure that such a laboratory: 


  • Evaluates all samples using the procedures specified in one of the following analytical methods: OSHA ID-142; NMAM 7500; NMAM 7602; NMAM 7603; MSHA P-2; or MSHA P-7;

  • Is accredited to ANS/ISO/IEC Standard 17025:2005 with respect to crystalline silica analyses by a body that is compliant with ISO/IEC Standard 17011:2004 for implementation of quality assessment programs;

  • Uses the most current National Institute of Standards and Technology (NIST) or NIST traceable standards for instrument calibration or instrument calibration verification;

  • Implements an internal quality control (QC) program that evaluates analytical uncertainty and provides employers with estimates of sampling and analytical error;

  • Characterizes the sample material by identifying polymorphs of respirable crystalline silica present, identifies the presence of any interfering compounds that might affect the analysis, and makes any corrections necessary in order to obtain accurate sample analysis; and

  • Analyzes quantitatively for crystalline silica only after confirming that the sample matrix is free of uncorrectable analytical interferences, corrects for analytical interferences, and uses a method that meets the performance specifications

Specified exposure control methods
For each employee engaged in a tasks identified in the Standard, the employer must  fully and properly implement the engineering controls, work practices, and respiratory protection specified in the OSHA silica regulation standard, unless the employer assesses and limits the exposure of the employee to respirable crystalline silica. Bureau Veritas consultants are expert in the identification, implementation, and effectiveness verification of controls for silica dust.


Housekeeping
The Standard recognizes that the use of compressed air, dry sweeping and dry brushing to clean clothing or surfaces contaminated with crystalline silica could contribute to employee exposure to respirable crystalline silica that exceeds the PEL.  Bureau Veritas can support the development and implementation of specific housekeeping requirements to control worker exposure to silica dust to below the PEL.


Regulated areas
The final standard for general industry and maritime requires regulated areas where exposures exceed the PEL. The posting of warning signs at the entrances to regulated areas is also required.


The final construction standard requires procedures to restrict access to work areas in the written exposure control plan.


The employer must post signs at all entrances to regulated areas that bear the following legend:


DANGER
RESPIRABLE CRYSTALLINE SILICA
MAY CAUSE CANCER
CAUSES DAMAGE TO LUNGS
WEAR RESPIRATORY PROTECTION IN THIS AREA
AUTHORIZED PERSONNEL ONLY


Bureau Veritas will provide specific information about the establishment of regulated areas for your work locations.


Medical surveillance
The silica exposure regulation standard for general industry and maritime requires medical surveillance to be made available to employees exposed at or above the action level for 30 or more days per year, and the construction standard requires medical surveillance to be made available to employees required by the standard to use a respirator for 30 or more days per year.  Bureau Veritas will support you in the identification of workers that must be included in the medical surveillance program.


Hazard Communication and Training

Worker training is required for all workers covered under the standard.  Workers must be trained on work operations that result in silica exposure and ways to limit exposure.  Bureau Veritas can provide both classroom and on-line worker training programs.


Recordkeeping
Air monitoring data, including laboratory reports


“Objective data” (essentially what we call “qualitative exposure assessment data”


To get assistance with the new OSHA silica exposure regulation in your workplace, call Bureau Veritas today at 1-800-357-7020

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