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OSHA Releases Proposed Silica Standards

OSHA has released proposed silica standards that could present significant challenges to many contractors working with and managing their silica exposure.  What is silica?  Well, it's sand.  Of course, sand by itself is not really dangerous (unless it happens to be a pool of quicksand that you are standing in without a rope).  However, sand that is being ground or smashed into dust particles can be inhaled.  Accumulating inside your lungs, it may cause silicosis, a lung disease.

The regulation is more than 500 pages long.  You can find it here.   ASA (the hard hat group, not the softball league) has put together a helpful summary of the proposed standard.  Here is an excerpt of the requirements.  You can read the whole summary here

What will the OSHA proposed rule require of construction employers?
 
Generally, OSHA’s proposed rule would require construction employers to measure workers’ exposure to silica; train workers on how to avoid exposure to silica; limit worker access to areas where they could be exposed to silica; provide technological means to protect workers, such as dust controls and respirators; offer medical exams to workers exposed to silica; and keep records on worker exposure and medical exams.
 
You said that construction employers will have to measure workers’ exposure to silica. When does that requirement apply?
 
Under OSHA’s proposed rule, a construction employer would have to measure and keep records of the amount of silica that its workers are exposed to if it may be at or above 25 μg/m3 (micrograms of silica per cubic meter of air), averaged over an 8-hour day. This is known as the “action level.” A construction employer would have to protect its workers from respirable crystalline silica exposures above a permissive exposure level of 50 μg/m3, averaged over an 8- hour day. This is known as the PEL. It is our understanding that at the proposed action level, all work on a construction jobsite would fall under this standard.
 
Under OSHA’s proposed rule, what procedures will I have to use to protect workers?
OSHA’s proposed rule essentially provides four ways to protect workers from crystalline silica:
  1. Train workers on the dangers of silica exposure and ways to mitigate exposure.
  2. Limit workers’ access to areas where they could be exposed above the PEL.
  3. Use dust controls to protect workers from silica exposures above the PEL.
  4. Provide respirators to workers when dust controls cannot limit exposures to the PEL.
In its proposed rule, OSHA provides some flexibility to employers on how to comply. For example, an employer would not have to measure its workers’ exposure to silica if it chooses to control silica dust using OSHA-designated methods to control silica dust on specified construction activities. Alternatively, a construction employer could choose to measure its workers’ exposure to silica and independently decide which dust controls work best on its jobsites.
Well, contractors?  Is this a fair and reasonable standard?  My experience with Obamacare's regulations has made me a cynic.
 

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