OSHA's new respirable crystalline standard now in effect

Heads up, construction industry: The new respirable crystalline silica standard issued by the U.S. Occupational Safety and Health Administration (29 C.F.R. 1926.1153) went into effect Sept. 23, 2017.

With 1.85 million construction workers exposed to silica annually — and 42 percent exposed to levels that exceed the current permissible exposure limit — OSHA’s new respirable crystalline silica rule limits crystalline silica to 50 micrograms per cubic meter of air, averaged over an eight-hour shift. The previous standard allowed up to five times that limit. At an Aug. 23 press conference, OSHA administrator David Michaels described the old standard as “dangerously out of date.”

“Anytime you blast, crush, cut, grind or even haul materials like concrete or stone, you’re creating silica dust,” said Kirstie Gray of Gray Services, a construction consulting agency based in Anchorage. “When you hear the term‘respirable

crystalline silica,’you’re talking about a form of silica 100 times smaller than a grain of sand. It’s everywhere, and it can negatively impact human health.”

While the new standard went into effect for the construction industry Sept. 23, 2017, OSHA offered compliance assistance in lieu of enforcement for the first 30 days for employers making good faith efforts to comply. General industry and maritime companies have until June 23, 2018, to comply.


A serious matter

The health hazards associated with respirable crystalline silica exposure cannot be overstated.

Acute silicosis can develop within weeks of heavy exposure to silica. Accelerated and chronic silicosis, lung cancer, COPD and kidney disease are all associated with exposure over the longer term.

According to OSHA, the previous permissible exposure limits (PELs) for silica were outdated, inconsistent and did not adequately protect worker health. In the 45 years since the previous PELs were established, the U.S. National Toxicology Program, the International Agency for Research on Cancer, and the National Institute for Occupational Safety and Health have all identified respirable crystalline silica as a human carcinogen.

From 2005 through 2014, silicosis was listed as the underlying or a contributing cause of death on over 1,100 death certificates in the U.S., according to OSHA. However, deaths from silicosis often go undiagnosed and unreported, and those numbers do not include additional deaths from other silica-related diseases.

Once the full effects of the new rule are realized, OSHA expects it to prevent 700 deaths a year from silica-related diseases — such as silicosis, lung cancer, other respiratory diseases and kidney disease — and to prevent more than 1,600 new cases of silicosis each year.


Spreading the word

AGC of Alaska has been instrumental in disseminating information about the new silica standard. On Aug. 8, the organization, along with Alaska Occupational Safety and Health, hosted a free safety Lunch and Learn event that covered the basics of silica exposure, OSHA rules and definitions, equipment usage and personal protective equipment. Gray helped plan and organize the luncheon alongside the AGC of Alaska’s safety committee.

“What people and companies need to understand is that the new silica standard is already in effect,” she said. “AGC was ahead of the curve on getting the word out.” Luncheon attendees even received USB flash drives with informational documents and links to training resources.

The full Code of Federal Regulations and appendices for the new respirable crystalline silica standard can be found online at osha.gov/silica/indexhtml. An informational webinar, as well as a webpage, “Respirable Crystalline Silica in Construction,” can be found at www.agc.org/industrypriorities/safety-health/respirablecrystalline-silica-construction.Gray also recommends AGC’s in-house safety database and silica-safe.org as resources to help contractors, workers and other stakeholders prevent silica related illnesses.


Methods of compliance

While the new regulations have the potential to make life more difficult for contractors, the standard provides flexible alternatives:

  • Table 1 identifies 18 construction tasks that generate high exposure to respirable crystalline silica. For each task, engineering controls, respiratory protection and work practices are stipulated.
  • Employers also have the option of measuring workers’ exposure to silica and independently deciding which dust control measures to employ.

 Whether employers choose Table 1 or use their own methods, there are six things they must do:

  1. Provide respiratory protection as needed and required.
  2. Create a written exposure control plan and appoint a competent person to make frequent and regular inspections of job sites, materials and equipment to implement the written exposure.
  3. Employ dust-control methods, such as using water to keep dust from getting into the air, or using a vacuum dust-collection system to capture dust.
  4. Provide medical exams, to include lung-function tests and chest X-rays, every three years to employees exposed to silica at the point of having to wear a respirator for 30 days or more each year.
  5. Train workers on tasks that result in silica exposure and methods to limit exposure.
  6. Keep records of workers’ silica exposure and medical exams.

 Engineering and work practice controls serve as the first line of defense against silica exposure. “The two primary methods are dust collectors and water spray,” Gray said. “When these methods are not enough to reduce employee exposure to respirable crystalline silica at or below the PEL, then you’re talking respirators.”

Employees must be fit-tested for their respirator. Per OSHA’s Respiratory Protection standard, facial hair cannot interfere with the face-to-facepiece seal or valve function.

“Employers are likely to get some pushback on this stipulation, but it’s important for worker health and safety,” Gray emphasized.

Kirk Waggoner, safety coordinator for Davis Constructors and Engineers, has been instrumental in instituting best practices around the new silica dust standard at Davis.

“It’s a challenge,” he admits. “In this industry, there’s a lot of seasonal work and transient employees, so even before you start a job, everyone has to be on the same page. It’s a constantly moving target.”

Waggoner said it’s likely that Davis has had an easier time than many companies adjusting to the new standard. A long history of health care construction means employees are experienced in infection control, which requires eliminating the presence of opportunistic microorganisms in environments where immuno-compromised patients reside. Many of these methods mirror silica dust-control techniques, such as the use of high-efficiency particulate air filters.

“Fit-testing respirators is fairly straightforward, but the new medical standard is potentially more costly and time-consuming,” he said. “But overall (the new silica standard) is a good thing. We need to step it up. It’s about the health of employees and making job sites cleaner.”


Carly Horton Stuart is a freelance journalist residing in Anchorage.