LHSFNA Management Co-Chairman Noel C. Borck

We outlined the key requirements of OSHA’s new silica rule in our previous article, “Getting to Know OSHA’s New Silica Standard.” The standard, which went into effect in June of 2016, prioritizes the use of engineering controls to limit worker exposure to harmful silica dust in the construction industry.

“Many LIUNA signatory contractors have already taken steps toward compliance and found that one of the standard’s strengths is the variety of compliance options available,” says LHSFNA Management Co-Chairman Noel C. Borck. “With enforcement due to begin in June of 2017, now is the time for all LIUNA signatory contractors to review the standard’s requirements and become familiar with their compliance options.”

Using Table 1 for Compliance

The first compliance option is following Table 1, which lists 18 silica-generating tasks along with specific engineering controls and respirator requirements. For more details on what is required for each task, see the Controlling Silica Exposure Using Table 1 chart on our website or order Silica and Table 1: A Field Guide to Compliance using our online Publications Catalogue.

A primary benefit of Table 1 is that employers who follow it fully and completely will be in compliance with the new rule. There is no need to conduct sampling because compliance with the PEL is assumed. The work practices and commercially available equipment with integrated dust controls referenced in Table 1 have been shown to be effective at keeping worker exposures below the PEL. For example, take a look at the lack of dust in this close-up of a handheld masonry saw performing wet cutting.

Performance Option with Objective Data/Scheduled Sampling

Fortunately, employers don’t have to follow Table 1 if it’s not the best solution for their needs. This could occur when contractors already make use of effective job-built controls and work practices or when they perform tasks that are not listed in Table 1.

When employers use the performance option, they are essentially claiming that the combination of controls and personal protective equipment being used does not expose workers above the PEL. In order to use this option, employers must have objective data supporting their claims that workers are not overexposed. An example of objective data is current exposure data or reputable sampling data from other sources. Employers can also choose the scheduled sampling option, which is covered in more detail in our Silica Compliance Flowchart.

The main benefit of these options is that as long as exposures stay below the PEL, contractors can continue to use the effective job-built controls and practices that are already common on many construction jobsites. The video below shows one example where a second worker manually sprays water at the dust source.

To see how effective this method can be, take a look at the same task being performed with no dust controls.

Resources

The LHSFNA has several publications to help LIUNA signatory contractors comply with the new OSHA standard and protect LIUNA members from being overexposed to crystalline silica:

• Silica Health Alert
• Controlling Silica Exposure in Construction
• Silica and Table 1: A Field Guide to Compliance
• What Your Doctor Needs to Know About Silica

To order these or other publications in English or Spanish, use our online Publications Catalogue. For more information, see OSHA’s Small Entity Compliance Guide on the standard or these OSHA Fact Sheets for specific silica-generating tasks. If you need assistance developing a program to control silica exposure on your site, call the Fund’s OSH Division at 202-628-5465.

[Nick Fox]