Rule Requirements
Q: How can silica exposures be controlled to keep exposure at or below the PEL?
- Employers must use engineering controls and work practices as the primary way to keep exposures at or below the PEL.
- Engineering controls include wetting down work operations or using local exhaust ventilation (such as vacuums) to keep silica-containing dust out of the air and out of workers' lungs. Another control method that may work well is enclosing an operation ("process isolation").
- Examples of work practices to control silica exposures include wetting down dust before sweeping it up or using the water flow rate recommended by the manufacturer for a tool with water controls.
- Respirators are only allowed when engineering and work practice controls cannot maintain exposures at or below the PEL.
For construction, the standard includes Table 1, a list of common construction tasks along with exposure control methods and work practices that work well for those tasks and can be used to comply with the requirements of the standard.
Q: Why can't silica-exposed workers just wear respirators all the time?
Respirators are not as protective as engineering controls, and they aren't always as practical either. Unless respirators are selected for each worker, individually fitted and periodically refitted, and regularly maintained, and unless filters and other parts are replaced as necessary, workers will continue to be exposed to silica. In many cases, workers using only respirators would also have to wear more extensive and expensive protection. Even when respirators are selected, fitted, and maintained correctly, they must be worn consistently and correctly by workers to be effective. Respirators can also be uncomfortable, especially in hot weather, and cannot be used by some workers.
Q: What is Table 1: "Specified Exposure Control Methods When Working with Materials Containing Crystalline Silica"?
Table 1 is a flexible compliance option that effectively protects workers from silica exposures. It identifies 18 common construction tasks that generate high exposures to respirable crystalline silica and for each task, specifies engineering controls, work practices, and respiratory protection that effectively protect workers. Employers who fully and properly implement the engineering controls, work practices, and respiratory protection specified for a task on Table 1 are not required to measure respirable crystalline silica exposures to verify that levels are at or below the PEL for workers engaged in the Table 1 task.
OSHA developed Table 1 in response to stakeholders in the construction industry, who indicated the need for guidance and a standard that is different than a standard for general industry. Among the concerns of construction industry stakeholders were the impracticality of exposure monitoring based on short duration of task and constantly changing conditions, such as weather, job sites and materials.
Q: Are the air sampling methods used to detect and measure silica reliable?
Yes, worker exposures to silica at the new PEL and action level can be reliably measured using existing sampling and analytical methods. Moreover, to improve reliability of silica measurements, employers must ensure that their silica samples are analyzed by laboratories that meet the qualifications and use methods specified in Appendix A of the standard.
- OSHA has carefully reviewed the available science and expert testimony contained in the rulemaking record on the ability of modern sampling and analytical methods to reliably measure respirable crystalline silica at the new PEL and action level.
- Published OSHA, NIOSH, and MSHA methods for analyzing respirable crystalline silica are able to measure concentrations at the new PEL and action level with acceptable precision, based on analyses of quality control samples and on studies conducted when those methods were developed in the 1970s.
- There are high-flow dust samplers now available that can collect more airborne dust, and more silica, than other samplers commonly used. Collecting more dust means that laboratories can measure the amount of silica in the dust with greater precision.
Q: What is the purpose of medical surveillance?
The purpose of medical surveillance is, when reasonably possible, to:
- Identify adverse health effects associated with respirable crystalline silica exposure so that appropriate actions can be taken.
- Determine if an employee has any condition, such as a lung disease, that might make him or her more sensitive to respirable crystalline silica exposure.
- Determine the employee's fitness to use respirators.
In response to the information gained through medical surveillance, employees can take actions to improve their health, such as making job choices to reduce exposures, wearing a respirator for extra protection, or making personal lifestyle or health decisions, such as quitting smoking or getting flu shots.
Q: Why are the results of medical surveillance only given to the worker and not the employer?
The employer receives the physician or other licensed health care professional's recommended limitations on respirator use, which is vitally important information that the employer needs to protect the worker because those who are not fit to wear a respirator but wear one can be at risk of sudden incapacitation or death.
Other findings of the medical examination are only given to the employee because many employees and physicians testified that if employers received the results of the examination, many employees would not participate in medical surveillance because they feared discrimination or retaliation.
Employers do not need medical findings because they should base employee protections on exposure levels and how well controls are working. On the other hand, employees need the results of medical examinations to manage their health.
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