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OSHA Proposed Crystalline Silica Rule for Construction


Dust collection and mitigation has been a big topic overseas and domestically for years. Now, however, OSHA is proposing two new standards to protect workers from exposure to crystalline silica-one. The two rules deal with construction environments as well as general industry and maritime. The dual application lets employers address the issues and provide solutions for the specific conditions found in their workplaces. What remains to be seen is whether the proposed rule becomes law and whether it brings with it unreasonable business costs which could drive up costs to consumers. Since it affects both commercial construction companies as well as smaller residential construction and remodeling companies, the effects of the OSHA Proposed Crystalline Silica rule could be enormous once you take into account compliance costs, insurance, and potential penalties.

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Why the OSHA Proposed Crystalline Silica Rule?

OSHA claims that 1.85 million workers are currently exposed to respirable crystalline silica in construction workplaces. That number is awfully high, but it merely deals with people around those materials, not people who are negatively affected by overexposure. OSHA does give us another number that estimates 640,000 (roughly one third) of these workers may be exposed to silica levels that would exceed the proposed permissible exposure limit (PEL).

When you talk about crystalline silica you’re talking about mixing, grinding/polishing, cutting, and drilling concrete as well as tuckpointing and using demo hammers. You also have to address rock crushing, drywall finishing and using heavy equipment when moving concrete and dirt.

OSHA seems to think the new ruling will save as many as 560 lives and prevent up to 1080 silicosis conditions per year in just the construction market alone. We’re hoping it’s not necessarily an all or nothing approach, but so far, even though new tools are hitting the market which mitigate dust, OSHA may still force the use of apparatus designed to filter dust to the lungs. That could make for having to get used to some pretty bulky head gear.

What is Crystalline Silica?

Respirable crystalline silica is made up of particles that are 100 times smaller than ordinary sand (or less). Crystalline silica is found on beaches and playgrounds—and of course on job sites where concrete, tile, and masonry materials like brick, block, and mortar are being moved, cut, or otherwise manipulated. Workers can respirate crystalline silica when cutting, sawing, grinding, drilling, or even crushing or transporting these materials.

Major Provisions of the Proposed Construction Standard

The OSHA proposed crystalline silica rule standard for construction forces employers to do the following:

  • Measure the amount of silica that workers are exposed to if it may be at or above an action level of 25 μg/m3 (micrograms of silica per cubic meter of air), averaged over an 8-hour day
  • Protect workers from respirable crystalline silica exposures above the PEL of 50 μg/m3, averaged over an 8-hour day
  • Limit workers’ access to areas where they could be exposed above the PEL
  • Use dust controls to protect workers from silica exposures above the PEL
  • Provide respirators to workers when dust controls cannot limit exposures to the PEL
  • Offer medical exams-including chest X-rays and lung function tests-every three years for workers exposed above the PEL for 30 or more days per year
  • Train workers on work operations that result in silica exposure and ways to limit exposure
  • Keep records of workers’ silica exposure and medical exams

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Small Business Construction Alternatives

Fortunately for small businesses and construction companies, the OSHA proposed crystalline silica rule standard allows employers to measure their workers’ exposure to silica and independently decide which dust controls work best in their workplaces. In this way, employers can use control methods indicated in the following table:

Exposure Control Methods for Selected Construction Operations

Operation Engineering and Work Practice Control Methods Required Air-Purifying Respirator ≤4 hrs/day Required Air-Purifying Respirator ≥4 hrs/day
Using Stationary Masonry Saws Use saw equipped with integrated water delivery system.

NOTE: Additional specifications:

  • Change water frequently to avoid silt build-up in water.
  • Prevent wet slurry from accumulating and drying.
  • Operate equipment such that no visible dust is emitted from the process.
  • When working indoors, provide sufficient ventilation to prevent build-up of visible airborne dust.
  • Ensure saw blade is not excessively worn.
None Half-mask
Using Hand- Operated Grinders Use water-fed grinder that continuously feeds water to the cutting surface.

OR

Use grinder equipped with commercially available shroud and dust collection system, operated and maintained to minimize dust emissions. Collector must be equipped with a HEPA filter and must operate at 25 cubic feet per minute (cfm) or greater airflow per inch of blade diameter.

NOTE: Additional specifications (wherever applicable):

  • Prevent wet slurry from accumulating and drying.
  • Operate equipment such that no visible dust is emitted from the process.
  • When working indoors, provide sufficient ventilation to prevent build-up of visible airborne dust.
None

 

Half-mask

 

 

 

 

 

 

 

Half-mask

 

Half-mask

 

 

 

 

 

 

 

Tuckpointing Use grinder equipped with commercially available shroud and dust collection system. Grinder must be operated flush against the working surface and work must be performed against the natural rotation of the blade (i.e., mortar debris must be directed into the exhaust). Use vacuums that provide at least 80 cfm airflow through the shroud and include filters at least 99 percent efficient.NOTE: Additional specifications:

  • Operate equipment such that no visible dust is emitted from the process.
  • When working in enclosed spaces, provide sufficient ventilation to prevent build-up of visible airborne dust.
 Powered air- purifying respirator (PAPR) with loose-fitting helmet or negative pressure full facepiece  Powered air- purifying respirator (PAPR) with loose-fitting helmet or negative pressure full facepiece
Using Jackhammers and Other Impact Drillers Apply a continuous stream or spray of water at the point of impact.

OR

Use tool-mounted shroud and HEPA-filtered dust collection system.

NOTE: Additional specifications:

  • Operate equipment such that no visible dust is emitted from the process.
  • When working indoors, provide sufficient ventilation to prevent build-up of visible airborne dust.
None

 

 

None

 

 

 

 

Half-mask

 

 

Half-mask

 

 

 

 

Using Rotary Hammers or Drills (except overhead) Use drill equipped with hood or cowl and HEPA-filtered dust collector. Eliminate blowing or dry sweeping drilling debris from working surface.

NOTE: Additional specifications:

  • Operate equipment such that no visible dust is emitted from the process.
  • When working indoors, provide sufficient ventilation to prevent build-up of visible airborne dust.
  • Use dust collector in accordance with manufacturer specifications.
 None None
Using Handheld Masonry Saws Use water-fed system that delivers water continuously at the cut point.

  • Used outdoors.
  • Used indoors or within partially sheltered area.

OR

Use saw equipped with local exhaust dust collection system. –

  • Used outdoors.
  • Used indoors or within partially sheltered area.

NOTE: Additional specifications:

  • Prevent wet slurry from accumulating and drying.
  • Operate equipment such that no visible dust is emitted from the process.
  • When working indoors, provide sufficient ventilation to prevent build-up of visible airborne dust.
  • Use dust collector in accordance with manufacturer specifications.
None
Half-maskHalf-mask
Full facepiece 

 

 

Half-mask
Half-maskHalf-mask
Full facepiece 

 

 

 

Using Portable Walk-Behind or Drivable Masonry Saws

Use water-fed system that delivers water continuously at the cut point.

  • Used outdoors.
  • Used indoors or within partially sheltered area.

NOTE: Additional specifications:

  • Prevent wet slurry from accumulating and drying.
  • Operate equipment such that no visible dust is emitted from the process.
  • When working indoors, provide sufficient ventilation to prevent build-up of visible airborne dust.
None
Half-mask
None
Half-mask

Drywall Finishing (with silica- containing material)

Use pole sander or hand sander equipped with a dust collection system. Use dust collector in accordance with manufacturer specifications.

OR

Use wet methods to smooth or sand the drywall seam.

None

 

 

None

 None

 

 

None

Use of Heavy Equipment During Earthmoving

Operate equipment from within an enclosed cab having the following characteristics:

  • Cab is air conditioned and positive pressure is maintained
  • Incoming air is filtered through a prefilter and HEPA filter
  • Cab is maintained as free as practicable from settled dust
  • Door seals and closing mechanisms are working properly.
 None

 

 

 

 

 None

 

 

 

 

While the most common methods of limiting exposure to silica dust on a construction site is to use water, vacuum dust collection systems are also playing a big part in mitigating airborne particles.

Important Dates and Facts

  • March 2016: OSHA is slated to publish its final rule on Workplace Injury and Illness Tracking
  • Rule Details: Requires companies with 20 or more employees submit an OSHA 300A summary of injuries electronically once a year. Companies with over 250 employees must submit quarterly electronic logs.
  • January 2017: OSHA is expected to publish its final Walking Working Surfaces and Personal Fall Protection rule.

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Daniel BlankenbergGlen StarrClint DeBoerDavid PharesSteve M Stanton Recent comment authors
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Daniel Blankenberg
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Rick Warner

Glen Starr
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Really now we can’t even go to the beach! On the bright side, new revenue for oceanside business; spring breakers will have to buy dust masks at least .

Steve M Stanton
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How about using water? With PPE.

David Phares
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So, providing proper PPE won’t be enough anymore. You gotta love OSHA (not).