Over the last few months, there’s been a lot of discussion swirling around OSHA’s Crystalline Silica Rule, and most specifically, how it will impact work as we know it in the construction industry. The new permissible exposure limit (PEL) stating how much crystalline silica someone can be exposed to over the course of an 8-hour work day is significantly lower than before. This is not the first time a change like this has been implemented… Over a decade ago, there was a huge focus on exposure to hexavalent chromium, the respirable by-product created when welding stainless steel. That change forced almost everyone in the welding industry to increase their efforts aimed at fume extraction for all welding operations. While that standard hasn’t gone away, it’s no longer an issue of impending doom like it was initially simply because it’s become a normal part of how work is done. Although it will certainly take some time to adapt, I fully expect the same as it relates to how we deal with respirable crystalline silica.
So where does this stuff come from? OSHA’s Fact Sheet says “Crystalline silica is a basic component of soil, sand, granite, and many other minerals. Quartz is the most common form of crystalline silica.
Cristobalite and tridymite are two other forms of crystalline silica. All three forms may become respirable size particles when workers chip, cut, drill, or grind objects that contain crystalline silica.”
And how are workers in the construction industry typically exposed to crystalline silica? According to OSHA, “Exposure occurs during many different construction activities. The most severe exposures generally occur during abrasive blasting with sand to remove paint and rust from bridges, tanks, concrete structures, and other surfaces. Other construction activities that may result in severe exposure include: jack hammering, rock/well drilling, concrete mixing, concrete drilling, brick and concrete block cutting and sawing, tuck pointing, tunneling operations.”
So what can WE do about it? One of the most effective things we can do, according to OSHA, is “Use all available work practices to control dust exposures, such as water sprays.” This is already a common practice for tasks such as core drilling. Tool manufacturers are now offering options to retro-fit tools with dust collection devices as well as ways to introduce water to the process. And as defined in the hierarchy of controls, we should always be working to eliminate the hazard before simply requiring additional PPE. Engineering controls should be our first line of defense, such as these tools designed for mitigating the hazard. Administrative controls are the next option, which often include steps to limit the exposure any one individual has to the hazard. If those don’t reduce the hazard to be below the PEL, PPE may be the next option. In this case, that could involve respirators; certainly not the simplest or easiest option.
Keep in mind, this is certainly not an all-inclusive article. Compliance with this standard will involve significantly different things for each employer based on the scope of work that’s being done. My goal with this was to provide you with some basic talking points that you may be able to cover with your team as well as an understanding that you WILL have to have this on your radar moving forward. While OSHA has temporarily delayed enforcement of this new standard, it is the new law of the land (effective July 23) for those of us that deal with VOSH.
Hope this helps,
Wes Dove, SHRM-CP/CHBC
Safety & Human Resource Manager, Blauch Brothers, Inc.