Occupational Exposure to Crystalline Silica Proposed Rule

Silica Proposed Rule Proposed rule published on September 12, 2013

Exposure and Health Risks  Exposure to respirable crystalline silica has been linked to: –Silicosis; –Lung and gastric cancers; –Chronic obstructive pulmonary disease; Emphysema, bronchitis –Kidney and immune system disease

Some Reasons for the Proposed Rule  Current Permissible Exposure Limits (PELs) are formulas that many find hard to understand  Vary by industry  Current PELs do not adequately protect workers

Silica Proposed Rule Would establish a single exposure limit –Current PEL’s calculated based on % of silica in product – different calculation and exposure limits for GI and Construction –Required application of formulas from 1968 & 1970 to determine PEL General industry formula PEL is about equal to 100 µg/m3; construction/shipyard formulas are about 250 µg/m3

Proposed Exposure Limits PEL = 50 ug/m3 Better protection for estimated 2.2 million exposed workers The proposed PEL is still considered to present significant risk!! Lowest technologically feasible (currently)

Exposure Assessment Personal sampling – full shift Initial monitoring –Alternatives are use of historical monitoring data or objective data Periodic monitoring –Fixed Schedule –Performance Based

Hierarchy of Controls Engineering –Substitution –Isolation –Ventilation –Dust suppression Administrative/Work Practice PPE

Dust Controls Grinding without dust controls Grinder with vacuum dust collector

Where Are We Now? Proposed Rule published 9/12/13 Comment period was open until 2/11/14 Web Chat held on 1/14/14 –Archive available on OSHA website Public hearings held 3/18/14 – 4/4/14 Written comments taken through mid- August Move toward final rule?

Do’s and Don’ts for an OSHA Inspections A Few Ideas…..

OSHA Inspections Have a plan for the inspection –Who will participate/backup –OSHA policy on “waiting” Have records and programs readily available –Ensure people know where to find important documents Be open and honest

Employer Rights Right of refusal Participate! Side by side sampling/video Take advantage of post inspection options

Employee Rights Receive safety and health training Request information from employer on OSHA standards, injuries and illnesses, job hazards and worker rights Request employer to correct hazards/violations File an OSHA complaint Participate in an OSHA inspection Find out results of OSHA inspection

Requested Programs and Records OSHA 300 logs Site Safety and Health Program Hazard Communication Program PPE Hazard Assessment Training Documentation

Other Recommendations Assign responsibilities for managing different elements of safety program Have a system for auditing your workplace and correcting identified hazards in a timely manner Know the MFC’s for your industry and do a gap analysis

Questions? Comments?

Disclaimer This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer’s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA’s website at