Today marked the first day that OSHA is requiring employers to be in full compliance with the new Respirable Crystalline Silica in Construction Standard (29 CFR 1926.1153). Mason Contractors Association of America (MCAA) is working to track citations related to this rule. They ask for your help in tracking these so they can address them at a national level.
If you get a citation, please contact the MCAA office at 800-536-2225 and ask to speak with Jeff Buczkiewicz . They will likely ask for a copy of the citation and move forward with any assistance we can provide. See full article from MCAA: Silica Rule Full Implementation Begins October 23.
Last week, OSHA issued this memorandum to OSHA Regional Administrators to provide interim enforcement guidance for Compliance Safety and Health Officers (CSHOs) beginning today. This will expire when the standard's companion compliance directive becomes effective and available.
A few highlights of the memo include:
- CSHOs will do the following during an inspection/investigation:
- Collect personal breathing zone samples when tasks listed in Table 1 are not being fully and properly implemented or if required by their flowcharts. See below Flowcharts A and B that will be used in OSHA's memo.
- Review the employer's written silica Exposure Control Plan and other relevant programs (e.g., respiratory protection program, hazard communication program, etc.) as part of the investigation.) Members of MCAA can create a plan/policy by clicking here.
- Interview affected employees, including the competent person, as part of the overall assessment of the employer's implementation of its Exposure Control Plan.
- OSHA addressed Housekeeping Practices (paragraph f)
- Sweeping compounds (e.g., non-grit, oil- or waxed-based) are approved as a housekeeping method
- The use of compressed air for cleaning is allowed where the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air, or where no alternative method is feasible.
- The employer's exposure control plan must include the description of the housekeeping measures.
- Employees who will be required a respirator for 30 or more days a year applies per employer. Any partial day of respirator use (even if for only one hour or less) is considered one day of respirator use for the purposes of medical surveillance requirements.
- OSHA revoked their National Emphasis Program on Crystalline Silica which provided guidance to CSHOs for targeting inspections of jobsites with the potential to generate elevated exposures to crystalline silica.
For more information on how you can comply with this new rule please visit our Silica Solutions page or contact us. We're happy to help you find the solutions you need to stay safe and productive by offering free consultations and a full line of dust collectors and wet saws.
Post by: Elizabeth "Liz" Graves, Sales Manager at Spec Rents, LLC. Contact Liz at firstname.lastname@example.org