Expansion of OSHA’s Respirable Crystalline Silica Standard

Workers who are exposed to respirable crystalline silica (breathable silica dust) are at an increased risk for developing lung cancer, silicosis, incurable lung disease, and chronic obstructive pulmonary disease. Crystalline silica is a common mineral found in such materials as sand, stone, concrete, brick, and mortar. Certain, common industrial or construction activities, such as using saws, drills, or grinders, can release silica dust into the air. To protect workers from exposure to silica dust, the “Respirable Crystalline Silica” standard has been developed by OSHA.

Compliance with the standard was originally limited to the construction industry. Construction industry employers were required to meet the requirements of the standard as of September 23, 2017. Importantly, however, as of June 23 of this year, the standard has been extended to cover all employers in the maritime and general industries in addition to employers in the construction industry.

Among other things, the standard requires all covered employers to:

• Assess employee exposure to silica;
• Protect workers from respirable crystalline silica exposures above the permissible limit (PEL);
• Limit worker access to areas where they could be exposed above the PEL;
• Use dust controls to protect workers from silica exposure above the PEL;
• Provide respirators to workers when dust controls cannot limit exposure to the PEL;
• Use housekeeping methods that do not create airborne dust;
• Establish a written exposure control plan;
• Offer medical exams, including chest x-rays and lung function tests, every 3 years;
• Train workers in ways to limit exposure to silica dust; and
• Keep records of exposure measurements, objective data, and medical exams.

All employers now covered by the Respirable Crystalline Silica standard should immediately conduct a review of their written safety program(s). These programs, and accompanying employee training, should be updated as necessary to meet the requirements of this standard. Any questions regarding the Respirable Crystalline Silica standard can be directed to tdavis@poynerspruill.com.

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