OSHA’s New Silica Regulation and What it Means to Surface Fabrication Shops
By Shannon Decamp

On March 24 the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced a final rule to improve protections for more than 2 million workers exposed to respirable silica dust. The rule, which was effective June 23, is designed to curb lung cancer, silicosis, chronic obstructive pulmonary disease and kidney disease in America’s workers by limiting their exposure to respirable crystalline silica.

Why Do We Need New Silica Standards?

Many have asked why the silica standards are being changed. According to OSHA, there are several reasons:

■ The permissible exposure limits (PELs) for silica were more than 40 years old, and based on research they did not reflect the current understanding of health effects and preventive measures.

■ Strong evidence shows that the current exposure limits do not adequately protect worker health.

■ The technology for most employers to provide adequate protection is widely available and affordable.

While many have argued that these regulation changes are unnecessary, the fact is they are now the regulations that stand.

Why Is Silica a Concern for Workers in Surface Fabrication Shops?

Stone and quartz surfacing countertops contain high amounts of the natural mineral silica. Though countertops and other finished stone products do not present a health hazard themselves, the tasks involved in manufacturing, finishing and installing these products can release hazardous levels of very small, crystalline silica dust particles into the air that workers breathe.

Which Work Operations Pose Hazards?

Workers operating powered hand tools, such as saws, grinders and high-speed polishers, have some of the highest silica dust exposures in the countertop manufacturing, finishing and installation industries. These exposures can occur in shop environments as well as on jobsites where finishing work may be completed. Workers involved in manufacturing engineered stone may also be exposed to silica dust when opening bags of ground quartz, moving or mixing bulk raw materials, cleaning and scraping mixers, or cleaning dust collector bag houses. Anyone in the area where silica dust is present may be at risk.

How Much Silica Is in Countertop Material?

Depending on the type of hard surfacing material in question, countertops may contain more than 90 percent silica. The highest silica levels are associated with engineered quartz surfacing countertops. Silica content is generally lower in natural stone products. Figure 1 shows typical silica/quartz content of common natural and engineered stones.

How Does the New Rule Protect Workers?

The final rule is designed to improve worker protection by:

■ Reducing the permissible exposure limit for crystalline silica to 50 µg/m³ of air, averaged over an eight-hour shift. This level is roughly 50 percent of the previous PEL for general industry, and about 20 percent of the previous PEL for construction.

■ Requiring employers to use engineering controls, such as water and ventilation, and work practices, such as isolation of tasks, to limit worker exposure.

■ Requiring employers to limit access to high exposure areas, provide training, provide respiratory protections when controls are not enough to limit exposure, and provide written exposure control plans.

■ Requiring employers to provide medical examinations for highly exposed workers.

■ Providing greater certainty and ease of compliance to construction employers by including a table of specified controls they can follow to be in compliance. If employers follow those specifications, they can be sure that they are providing their workers with the required level of protection. Employers may provide alternative methods of protection as long as they make sure that their methods effectively reduce their workers’ exposure to silica dust.

What Does the New Rule Require of Employers?

Here is an overview of the eight main actions employers must take to comply with the new rule:

1. Establish a written Exposure Control Plan for protecting employees from the hazards of silica.

2. Test (monitor) the amount of respirable silica that is present in the workplace environment (in proximity to the place where it is being used).

■ If initial monitoring indicates that employee exposures are below the action level, the employer may discontinue monitoring for those employees whose exposures are represented by such monitoring.

■ Where monitoring indicates that employee exposures are at or above the action level but at or below the PEL, the employer must repeat monitoring within six months of the most recent monitoring until the exposure is brought down below the action level.

■ If test results indicate that silica is present in the workplace environment in excess of the PEL, special precautions must be taken to protect employees from exposure. Monitoring must be repeated every three months until the exposure is brought down below the PEL.

3. Inform employees of the results of workplace testing.

4. Establish regulated areas and post appropriate signs based upon the results of the exposure testing.

5. Provide engineering controls, safe work practices and proper protective equipment to protect employees from exposure.

6. Train employees about dealing with exposure to silica, the use of protective equipment and the policies established by the employer to address the risks.

7. Provide medical examinations to highly exposed workers.

8. Maintain records related to: air monitoring, objective data, medical examinations, employee training and any injuries or illnesses related to exposure to silica in the workplace.

When Must Employers Comply?

The final rule is written as two standards, one for construction and one for general industry and maritime. The rule provides flexibility to help employers — especially small businesses — protect workers from silica exposure, with staggered compliance dates to ensure sufficient time to meet the requirements.

Employers covered by the construction standard have until June 23, 2017, to comply with most requirements. Employers covered by the general industry and maritime standard have until June 23, 2018, to comply with most requirements.

What Can Be Done at Countertop Work Sites to Protect Workers?

Employers must determine which jobs and activities expose workers to silica and take actions to control overexposure and protect workers. If air monitoring shows levels of crystalline silica above OSHA’s PEL, employers are required to take action to reduce worker exposures to below the PEL using a combination of engineering controls, work practices, protective equipment, worker training and other measures.

Engineering Controls

Engineering controls, such as water sprays and/or local exhaust ventilation (LEV) and safe work practices provide the best protection for workers and must be implemented first, before respiratory protection is used. NIOSH and OSHA have identified the following control options for countertop manufacturing, fabricating, finishing and installation operations:

■ Use water spraying systems and remotecontrolled tools at the impact site where a saw or grinder generates dust.

■ Large bridge or gantry-like saws usually use water sprays and can be remotecontrolled for limiting dust exposure.

■ Hand-held angle grinders can be modified to deliver water to the point of contact with the stone.

■ Wet-edge milling machines or stone routers can replace dry grinders in shops. They provide a clean edge profile with a diamond wheel.

■ Use hand tools (e.g., drills, masonry saws, grinders) equipped with a shroud and a vacuum with a high-efficiency particulate air (HEPA) filter when wet methods are not practical.

■ Install LEV systems at fixed locations to capture dust at its point of origin.

■ Use a combination of both water and ventilation controls, if necessary.

■ Wet methods for dust control may not be practical on or near finished cabinets, walls and floors, so other suppression methods (e.g., LEV) should be used during these operations.

Safe Work Practices

■ Use wet sweeping or HEPA-filtered vacuuming to clean up dust as soon as possible. Do not use compressed air or dry sweep.

■ Replace water and air filters as needed to control dust.

■ Adjust water flow as necessary to control dust, following manufacturers’ recommendations for water flow rates.

■ Pre-wash stone and e-stone slabs before cutting.

■ Implement regular and thorough housekeeping procedures for water slurry and settled dust.

■ Provide HEPA-filtered vacuums for cleaning worker clothes, and water for hand, face and hair cleaning.

■ Do as much work as possible under controlled shop conditions instead of on-site, or perform work outdoors or in well-ventilated areas to reduce respirable crystalline silica dust exposure.

Identify and Isolate Remaining Dustgenerating Operations

Where air monitoring identifies high exposure areas:

■ Isolate the silica dust-producing operation(s) using enclosures or walls. Enclosures are more effective when used with LEV.

■ Alternatively, enclose the person, if possible, by putting him or her in a protective control booth.

■ In some cases it may be necessary to isolate certain tasks in separate areas. This may be needed more frequently for engineered stone because of its high silica content.

When Are Respirators Required?

When engineering and work practice controls do not limit silica exposures to OSHA’s PEL, employers must provide workers with respirators. Whenever respirators are required, the employer must have a respiratory protection program that meets the requirements of OSHA’s Respiratory Protection Standard (29 CFR 1910.134). This program must include proper respirator selection, fit testing, medical evaluations and training.

What Training Is Needed?

OSHA’s Hazard Communication Standard requires that employers provide their workers with training and information about all hazardous chemicals in the workplace, including silica. The Hazard Communication Standard requires employers to do the following:

■ Prepare and implement a written hazard communication program.

■ Provide training and information on the hazards of silica and other chemicals used in the workplace.

■ Provide workers access to Safety Data Sheets (SDSs) on silica and other hazardous chemicals they are exposed to during countertop manufacturing, fabricating, finishing and installation.

■ Ensure that each container of hazardous chemicals is labeled appropriately.

Medical Monitoring for Workers Exposed to Silica

Employers must provide medical surveillance for each employee who will be occupationally exposed to respirable crystalline silica at or above the action level for 30 or more days per year. All medical examinations and procedures must be performed by a Physical or other Licensed Healthcare Professional (PLHCP) that is familiar with the health effects of silica. Medical examinations must be made available at least every three years or more frequently if recommended by the PLHCP. A physical examination with special emphasis on the respiratory system must include, at a minimum:

■ A medical exam that focuses on the respiratory system;

■ A medical and work history with emphasis on past, present and anticipated exposure to respirable crystalline silica, dust and other agents affecting the respiratory system;

■ A history of respiratory system dysfunction, including signs and symptoms of respiratory disease (e.g., shortness of breath, cough, wheezing); history of tuberculosis; and smoking status and history;

■ A chest X-ray, evaluated by a qualified professional;

■ A pulmonary function test;

■ Testing for latent tuberculosis infection; and

■ Any other tests deemed appropriate by the PLHCP.

It is important to keep in mind that, as with all new regulations, silica will be a focus area for OSHA. It is best to get a head start on compliance immediately, not only to protect your business, but, most importantly, to protect your most important asset — your employees.

About the Author

Shannon DeCamp is Client Services Manager for TechneTrain, Inc. TechneTrain has safety training programs and reference manuals specifically designed for the surface fabrication industry, and will soon release a turnkey employee training program for the new silica regulation. These products are available from ISFA at discounted prices. For further information regarding OSHA Compliance requirements for the surface fabrication industry, visit www.technetrainonline.com, or contact TechneTrain, Inc. at (800) 852-8314.