What You Probably Didn't Know About Silica
As of October 23, 2017, OSHA began fully enforcing all provisions of the Silica in Construction standard, relevant to the activity being undertaken, which requires employers to come into compliance with the new permissible exposure limit, or to implement specific silica controls for certain operations as provided in Table 1 of the standard. The primary framing tasks outlined in NFC’s FrameSAFE program that could cause exposure to crystalline silica on the jobsite include drilling concrete, cutting gypsum products, cutting fiber cementitious products, and cutting autoclaved aerated concrete (AAC) wall panels.
A recent article from EHS Today took a look at the first six months of enforcement and what the 117 violations, 80 percent of which were classified as “serious,” might tell us about OSHA’s enforcement priorities:
- 35 cited failure to conduct an exposure assessment of worker exposure to respirable crystalline silica. This was the most commonly-cited violation.
- 31 cited violations were for failing to adhere to the list of equipment and tasks, along with OSHA’s required engineering and work control methods and respiratory protection. This was surprising because these requirements are not mandatory. Rather, if a construction employer opts not to follow the controls and respiratory protections for the listed equipment and tasks, it is required to follow the alternative exposure control methods cited, including conducting an exposure assessment.
- 20 citations were issued for lack of a written exposure control plan. OSHA did not provide a breakdown describing which elements were not in compliance or whether employers simply lacked written plans.
The article goes on to say that the three main violations outlined above “could lead to the conclusion that OSHA inspectors are inconsistently enforcing the silica standard for construction.” While it goes on to explain that the data OSHA released didn’t include details regarding the number of inspections conducted or whether inspectors were citing employers for violations of both the engineering and work control methods and alternative exposure control methods in one inspection, it was evident that citations for violations of the silica standard were rarely given alone, rather they were “usually accompanied by violations of other regulations, such as the fall protection standards.”
“Our efforts are focused on helping FrameSAFE subscribers easily put together job-specific silica plans based on our primary tasks: drilling concrete and cutting drywall, fiber cementitious products and Autoclaved Aerated Concrete (AAC) wall panels,” explains Ken Shifflett of Ace Carpentry in Manassas, Virginia, who serves as Safety Committee Chair for the National Framers Council. The safety committee suggests framers focus on compliance with Table 1 for now, but “we’re not ruling out the alternative exposure control methods as a long-term solution.” The air monitoring options made available in the standard give framers the choice to measure and document exposure levels. If levels are found to be below the limits, those tasks are then exempt from Table 1 requirements.
NFC’s bilingual FrameSAFE program contains guidelines for silica exposure control, including how to implement Table 1 control methods for the tasks listed above and how to approach the option for scheduled monitoring. In addition to a series of Toolbox Talks on this topic, the program also includes a template for the required silica work plan as well as a field air monitoring worksheet.
Learn more about FrameSAFE and watch an NFC webinar on understanding jobsite silica enforcement at www.framerscouncil.org/framesafe.