Practice Good (Industrial) Hygiene – New OSHA Silica Standards

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Silica is common in many materials found on construction and other sites including soil, sand, concrete, masonry, rock, and landscaping materials. The dust that is created by disturbing these materials can contain respirable crystalline silica (RCS) particles. As of the date of this article, everyone is likely aware of the new OSHA RCS standards. The standard that applies to the Construction Industry, 1926.1153, has been enforced at the federal level since September of 2017 and by the Virginia Department of Labor and Industry since June of 2017. The silica standard for the General Industry, 1910.1053 will become fully enforceable in June 2018.

Will You Be in Compliance?

The requirements of the silica standards are complex and multi-faceted.  Couple that with the increased fine fee schedule from OSHA within the last couple of years and compliance becomes increasingly more desirable. One aspect of the requirements for both the construction and general industry is training of employees – ALL EMPLOYEES. OSHA states that the training requirement is “performance-based”. This means that if you find yourself the subject of an OSHA inspection, compliance with the training requirement can be based on the ability of any and all of your crew persons being able to answer OSHA questions regarding silica and the requirements of the standard. An OSHA inspector might ask:  “What are the health hazards associated with exposure to airborne respirable silica?” “Is it OK to sweep that dust over there with a broom?” “What is your employer doing to protect you from airborne respirable silica dust?” “When should you get new cartridges for your respirator?”  These are just a few of the questions that could be posed.

A second key aspect is personal monitoring to determine employee exposure to RCS, assuming that one is not pursuing compliance by adherence to Table 1 (1926.1153 (c)(1) that can be referenced here.  To completely fulfill the requirements for an acceptable personal sample for RCS the sampling must be conducted according to the OSHA method, properly configured on the worker, with the specified flow rate, and for the specified duration of time. Carefully removing the sampling apparatus and the actual sample is also crucial to obtaining reliable analytical results.  Sampling for RCS should be performed either by or under the direct supervision of an American Board of Industrial Hygiene (ABIH) Certified Industrial Hygienist (CIH) for the data to be defensible.

F&R possesses a staff of qualified, experienced, and trained industrial hygiene sampling technicians and health and safety training providers that conduct sampling and silica awareness training all under the direction of a Certified Industrial Hygienist and a Certified Safety Professional. Our sampling techniques are non-intrusive and our training is hands-on and participation driven, increasing the likelihood that your crew persons will learn and retain essential information.

The abundantly acronym-ed Glenn Hargrove heads up F&R’s Industrial Hygiene efforts. A Certified Industrial Hygienist, Certified Safety Professional and Certified Awesome Guy, Glenn is our in-house expert on all matters pertaining to occupational risk management, hygiene, safety and other compliance based and regulation-heavy fields of practice. In short, he knows all the rules and he assists clients with following them in practical and strategic ways to limit their exposure to inherent workplace risks. This support is comprised of evaluation of client work processes, monitoring of workplace stressors, evaluation of analytical results for personal and/or ambient air monitoring, and recommendations for response actions to include engineering and administrative controls and personal protective equipment. Not satisfied with just being the authority on what goes on inside your environment, Glenn is also a registered Professional Geologist giving him the unique perspective on what is happening underneath it as well.