Starting October 1, 2018 DOSH (Division of Occupational Safety and Health, L&I) is enforcing the new silica rules. This rule – which went into effect on February 1 – separates respirable crystalline silica out from other respiratory hazards and requires a distinct written plan and protection program for workers with exposure to respirable silica.
Key components
If you have workers that undertake tasks that create silica dust (e.g. cutting roads and sidewalks, using jackhammers or cement saws), then your organization will need to implement a silica protection program. Here are some key features that should be included in your program:
- Provide employee training on crystalline silica hazards, your organization’s control plan, and the specific engineering controls used to protect workers.
- When required per Table 1, provide respiratory protection
- Establish a written exposure control plan
- Designate a competent person for your program who through training/experience can make informed decisions about exposures and controls
- For employees who must ear respirators due to silica exposure for ≥30 days a year, offer medical exams
- Restrict housekeeping practices that create additional exposures to crystalline silica (e.g. dry sweeping)
Resources for you
Federal OSHA have provided some very good resources to help organizations with implementation of the silica rules. You can view OSHA’s silica page for good explanations and resources on the rules. Especially helpful is the Small Entity Compliance Guide, which offers details on how to implement required protocols.
WAC 296-840-110 is called Table 1. Table 1 clearly identifies the engineering and administrative control methods needed for the types of work that your employees will be undertaking. It also tells you what the control implementation requires. View an enhanced copy of Table 1.
L&I has created a phone-friendly web tool that gives you the same information available in Table 1, but through a selective method where you identify the task being undertaken. For the selected processes, it provides checklists for reviewing equipment used to suppress dust.
Important points
An important first step to implementing a silica program is to have environmental sampling done on work that creates crystalline silica dust exposure. If you have not had this type of sampling done, we recommend that an industrial hygienist work with your organization to identify all the work duties that create crystalline silica hazard exposures, and then perform monitoring on representative employees doing those tasks. We recommend that you contact L&I consultation services to get this work done. L&I consultation services are complementary, and their industrial hygienists should be familiar with the parameters of the new silica rule and the monitoring necessary for them.
For employers who do not have workers that have exposure to crystalline silica ≥25 µg/m3 as a TWA8 under “any foreseeable conditions”, the crystalline silica rules do not apply. For this reason, some exposure monitoring done needs to be done without engineering controls, because OSHA has determined that the failing of engineering controls is a reasonably foreseeable event. We recommend you consult with your selected hygienist as to how to best accomplish this monitoring while keeping your employees safe.
AWC Retro will continue to provide additional guidance and tools for crystalline silica programs in the coming months. If you have any questions or need additional guidance, please contact us.