Respirable Crystalline Silica: Establish and Implement a Written Exposure Control Plan (ECP)

It has almost been one year since OSHA (Occupational Safety and Health Administration) began enforcement of its final rule regarding Crystalline Silica Exposure (June 23, 2018). As stated in an article that ran in Texas Asphalt Pavement Association‘s (TXAPA) publication, Texas Asphalt Magazine, this ruling has implications for general industry, maritime, and construction. Westward Environmental’s Bob Huddleston and Natalie Pless paint a picture of why crystalline silica can be a stealthy health risk if not properly and proactively addressed.

This article is to help employers establish and implement a written control plan that identifies tasks involving silica exposure and methods to ensure workers are protected. Each component of the plan needs to ensure compliance and must follow state and federal regulations.

The standards set a new Permissible Exposure Limit (PEL) of 50 micrograms of respirable crystalline silica per cubic meter of air (50.0μg/m3) as an 8-hour Time-Weighted Average (TWA) and an Action Level (AL) of 25μg/m3 as an 8-hour TWA. Employers must assess the 8-hour TWA exposure for each employee who is or may reasonably be expected to be exposed to respirable crystalline silica and ensure no employee is exposed above the AL. If employee exposures are above, or may under foreseeable conditions be above, the AL the standard requires the employer to establish and implement a written Exposure Control Plan (ECP). Not covered under the standards are tasks and operations where exposures will be below the AL “under any foreseeable conditions.”

An ECP for construction, maritime, or general industry, must contain, at a minimum, the following elements:

• A description of the tasks in the workplace that involve exposure to respirable silica. The plan must identify all tasks that could possibly result in any exposure to silica. The description should also include any workplace factors that may affect the potential for exposure for each task. For example, it could describe the types or amount of silica contained in any materials used in the task; if weather conditions could affect exposure levels, or the location of each task (indoors, outdoors, etc.), and the type of equipment used to perform the task. The detail used to describe a specific task can be minimal but using a generally broad term to describe a task as “construction” or “demolition” will not be enough detail to pass as a description.

• Engineering controls, work practices and respiratory protection used to limit employee exposure to respirable crystalline silica for each task. The silica standards include requirements for the use of engineering controls and workplace practices to keep exposure levels at or below the new PEL. Employers may not rely on respirators as the only means of controlling employees’ exposure. Employers must make efforts to keep silica out of the air, and these efforts must be described in the ECP.

For each task that could involve silica exposure, the plan should describe the engineering controls the employer uses to minimize or eliminate silica exposure. Controls may include ventilation and vacuuming systems, isolation, processes for watering down workplace operations, and any other means of keeping silica out of the air. The plan should also include effective work practices for using these control systems, such as instructions for operating the dust controls on a certain piece of equipment used to perform the task, schedules for conducting maintenance checks, and specifications for any required respiratory protection.

• Housekeeping measures used to limit employee exposure. Housekeeping requirements only apply where cleaning “could contribute to employee exposure to respirable crystalline silica.” In the housekeeping section employers must describe cleaning methods that are acceptable, cleaning methods that are unacceptable, and special instructions that may be necessary to limit exposure to silica while employees perform housekeeping tasks. Specifically, employers should include descriptions of:

• Cleaning methods the employer permits and prohibits to minimize the generation of airborne silica. Activities, such as dry sweeping, dry brushing and using compressed air, are generally prohibited in areas where they may generate airborne silica. The silica rules require employers to wet sweeping or use filtered vacuuming and other appropriate cleaning methods. The rule does provide some flexibility and the employer may use otherwise prohibited dry methods where no other feasible methods are available;

• Special instructions for cleaning methods (for example, using local exhaust ventilation if compressed air must be used);

• Hygiene-related subjects (such as not using compressed air to clean clothing) could also be addressed in this section; and

• Whether employees must wear a respirator or take any other special precautions while performing a particular housekeeping method.

When there is a change in production, process, control equipment, personnel or work practices, a reassessment of exposures is required. To learn more about silica exposure, visit: http://www.nxtbook.com/naylor/TAXQ/TAXQ0118/index.php?startid=5#/36