Who's ready for the new OSHA silica regulations?

Discussion in 'Health & Safety Forum' started by tsb, Apr 17, 2017.

  1. tsb

    tsb well dressed

    So we've always had necessary engineering controls in place for our work and I have my safety policy written and should have the templates for our written exposure control plan for all the tasks we do by the end of the week hopefully. Maybe next week...

    I can't live under table one so I'm going to have to implement air sampling. Finding the right equipment for this is a chore. Have to pay attention to sampling rates and job task duration as most pumps are low flow and if the task doesn't last 6-8 hours you don't end up with a large enough sample size for the lab.

    Having a little trouble finding a medical facility that is ready to begin the medical surveillance portion right now. All the big chains that specialize in occupational health seem to be getting their ducks in a row and should have procedures in place in the next couple months from the way it sounds. (Medical surveillance is only required if an employee is expected to wear a respirator for 30 or more days in a year, we might not meet that requirement but won't know until we begin our air monitoring program).

    I'm really curious what you floor installers are going to do. You are no longer allowed to dry sweep. Either vacuum with a hepa filter or "lightly wet" the surface prior to sweeping. I haven't seen anything mentioned in osha manuals/info that I've read that pertains to sanding concrete/etc. You'll either have to do it wet or hook your floor buffer up to a hepa filter with a pre seperator or a mechanical filter cleaning mechanism. But because it doesn't specifically state it in table one, my understanding is you have to do air monitoring to make sure silica levels stay below permissible exposure limits (PEL). Demoing existing flooring is going to be super interesting too. I wonder if
    pulling up carpet is going to put you over the PEL. I would guess ride-on floor scrapers are out unless a respirator is worn. But it's not listed under table one so air monitoring is required.

    Having said all that, NO ONE I talk to seems to understand what all is going to be involved with this. Which really sucks because I'm spending all this time and money so I can comply and no one else is doing the same. Going to be real interesting to see how enforcement goes.
     
  2. tsb

    tsb well dressed

    If you haven't started researching this yet, the OSHA Small Entity Compliance Guide for the respirable Crystalline Silica Standard for Construction is as good a place as any to start:

    https://www.osha.gov/Publications/OSHA3902.pdf
     
  3. Mike Antonetti

    Mike Antonetti I Support TFP Senior Member

    Ermator with JonDon had a good seminar. Trying to digest info is time consuming. A Micro Gram is tiny, you can't do anything without breathing in the minimum.

    I say politics may delay further but that doesn't stop people from dying of silicosis. The provisions are going to be difficult to be under limit. Just seems unrealistic.
     
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