Today's the Day- Silica: What you need to be ready if OSHA shows up

The day all of us in the construction industry have been dreading (and holding would go away) is here today. There's no date extension.  Nothing has been updated in the regulation despite the many efforts from the MCAA and the construction industry to work with the DOL to find a way to make the regulation more practical.

On a positive note, we did see yesterday a memo from OSHA stating that they would not be issuing fines to contractors that are showing efforts to comply. They have been tasked with helping contractors to comply.

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“OSHA will assist employers who are making good faith efforts to meet the new requirements to assure understanding and compliance.

If, upon inspection, it appears an employer is not making any efforts to comply, OSHA’s inspection will not only include collection of exposure air monitoring performed in accordance with Agency procedures, but those employers may also be considered for citation.”

— Memorandum: Launch of Enforcement of the Respirable Crystalline Silica in Construction Standard, 29 CFR § 1926.1153

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What does this mean and what can you do to ensure that you're on the road to complete compliance?

• Establish your competent person and make sure they know what is required to be compliant. MCAA is still holding Train the Trainer classes since there are still a lot of companies that haven't completed the necessary training. Sign up here.
• Have your written silica exposure plans in place and share them with your teams. MCAA members can build their programs here. Your employees need to know how to access these. We can help you with this process if you need help with specific language.
• Train your employees or at least have the training scheduled to do so. As stated above, having an in-house trainer will allow you to train both your competent person(s) and your employees. Make sure the training includes the written plans, who the competent person is, and what the new requirements are, along with all other requirements. OSHA will likely be asking folks if they've been trained, who their competent person is, and if they know about the silica plan.
• At least be cutting wet. Dry cutting is going to make a ton of dust and shows that you're not even trying to meet the regulations.
• Be considering what additional equipment you need- most likely a dust collection system that will work with a grinder (for tuck pointing and small cuts) and drills if you're in masonry. You can contact us or your tool rep for help with what is necessary and can either fall in Table 1 or have objective data that proves the complete system is under the PEL for the task you're performing.
• If you're a business owner or leader in your company, you need to know the regulation. Don't rely solely on your team to make sure it happens. There's a lot of misunderstanding of the requirements. You could easily be doing the wrong thing, even doing more than you need to in some cases.

Download our Silica by the Numbers info-graphic for the main points you need to know. Feel free to contact our team if we can help you with anything.  As the construction industry, we're all in this together to keep this from bogging down our production and profitability.

Post by:  Elizabeth "Liz" Graves, Sales Manager at Spec Rents, LLC.  Contact Liz at lizg@specrents.com

14 Days and Counting....

14 days. 

That’s what we’ve got left before the OSHA Respirable Silica regulation is due to be enforced by OSHA.  I’m friends with a lot of contractors, and, as of now, there is still a lot of certainty on what will happen. 

Here’s several of the many questions I’ve gotten in the past week or so now that we are that close to September 23rd:

• Will it be pushed back again?
  • According to MCAA, likely not if the DOL has their way.
• Will Trump get rid of it?
  • I’m not thinking this is something he can easily reverse.
• If it goes into effect, won’t there be a lawsuit?
  • Maybe.  But how long will it be before that happens and a change is made?
• Will they “open up Table 1”?
  • There is still a good chance for that to happen.  This would be good since masonry mixing stations are currently not included, causing quite a bit of uncertainty amongst the masonry industry.
• Will OSHA enforce this regulation heavily?
  • This is something your company has to consider.  My guess is that OSHA will be enforcing this at the same level they do anything else.  There’s no additional funding for this to my knowledge. 
• If OSHA can’t handle enforcing the regulations now, how are they going to handle this?
  • Like many other regulations, this will likely be enforced more by your General Contractors, Construction Managers, and, in cases of universities and other larger projects, owners’ reps.  Even if this “goes away” from a legal stand point, there’s a chance some of the regulations will stay in place in these safety programs.
• Can’t I just cut wet and be ok?
  • It depends.  Reference Table 1 (Download here).  There are more tasks listed than just cutting with saws that create respirable silica and need to be addressed.  Starting there is a good place to decide what you may need to get additional tools and/or accessories to “stay in table 1” and avoid objective testing.
  • In some cases, cutting wet still requires a respirator, so water doesn’t fix everything. But I personally think it can be an easier alternative to a vacuum system.
• What tools do I need?
  • Again, it depends on what you need to do.  Get with your tool reps to find out which of your tools you can continue to use with proper accessories (vacuums with shrouds connecting them, for example).  They should be able to help you find what you need. 
  • There’s an abundance of options out there, but don’t wait until 9/22 to get this because you may be out of luck at that point. 
  • Also, remember that your employees must be trained on how to use and properly maintain all equipment relating to this.
• How can I avoid having to do medical testing for my employees?
  • Avoid using respirators (even the N-95, AKA “two-strap dust masks”) is the easy answer. 
  • The hard answer is to avoid tasks that require the use of a respirator.  This again comes down to using Table 1 OR using objective data through either your own testing or through testing that accurately represents the task you’re doing.

The list of questions I’m being asked goes on and on. 

Here are the main points you need to know:

• If you haven’t already trained your employees on silica, do it.  NOW.  MCAA has a train the trainer course that gives your team the ability to train in-house, along with the materials you need to do so.  The next class in Texas is in Dallas on October 3rd and is sponsored by Spec Rents.  Register here.

• Establish who your competent persons are for this.  They must know the regulations in and out in order to make sure your employees are all in compliance.

• Make sure you get good information or really read and educate yourself on the regulations before you train your people or buy the wrong tools and/or accessories.
• Don’t go at this alone.  Reach out to your sales reps or other contractors that have already been through the training to get the information you need.
• Make sure you’ve done your Silica Exposure Policy.  If you’re a member of MCAA, you have access to their tools, which will build this for you with everything you need to meet OSHA’s standards.  Create your policy NOW.

Take a deep breath.  Just like other new things, we will adjust to change together.  For questions about the OSHA silica standard or how you can prepare for it, feel free to contact Liz Graves.

Post by:  Elizabeth "Liz" Graves, Sales Manager at Spec Rents, LLC.  Contact Liz at lizg@specrents.com

More than just a Hard Hat

If you're in the construction industry, you know a hard hat is more than just another piece of PPE.  Don't get me wrong- keeping your head protected is its number one job. However, it does so much more.

In many ways, it's part of a worker's identity. They wear this every day. Some people like to keep collecting stickers to show the numerous jobs they've been on while others like to have theirs kept as clean as possible. I'm personally somewhere in between. It's a hard hat.  But it's mine- so I like to keep it in good shape but I want it to look a little dirty so I don't stand out so much!

Some companies provide their employees with hard hats in a certain color or with the company logo, making it easier to identify the team members. I know a lot of guys take pride in who they work with so providing them with one can go a long way to show employees their employer cares (even though technically OSHA says employers are required to provide them). 

A happy medium for companies might be having "plain old white ones" for new employees giving them a colored and/or logo'd one after a couple of months (or whatever time period works). This would also help to identify the "green" employees- not to pick on them- but to help team members keep an eye on them and provide mentorship. After all, new employees get injured at a much higher rate and we all know that turn-over for these employees is slightly higher too, so it's in everyone's best interest to help them out. Plus, if they find it's to hard and walk off with your hard hat, at least it was the cheaper one.

All-in-all, hard hats are more than just a hard hat.  And Spec Rents can help you whether you want the Plain Jane white ones or a colored one with a logo. Either way, you'll have a quality hard hat at a great price. Contact us for your quote today.

Post by:  Elizabeth "Liz" Graves, Sales Manager at Spec Rents, LLC.  Contact Liz at lizg@specrents.com

Busy is as Busy Does

For the past few months it seems that every customer I call on has the same answer when asked how things are going:  Busy.

And my response, most often, is that it beats the alternative.  But does it?

It can, if done right!  

I hear all the time how hard it is to find (and keep) good employees.  As I write my first blog for our new website, I have been pondering ways that contractors can keep up with all of this while facing a labor shortage we are (or will be) running up against.  Here's a few ideas:

• Recruit and train new employees- You can't have one without the other.  If you can't recruit them, you can't train them and if you're not willing or able to train them, then you can't recruit them.  If you're in a local, state, or national association, make sure you're taking part in their offered training programs or helping to develop some.  Skilled employees, such as masons, must be taught correctly.  Those that aren't sacrifice production and quality.  Some labor positions are basic but there are still basics that must be taught as well. Knowledge is power. 

• Retain good employees- Ask yourself a few questions.  Are you seeing a lot of turn-over? Are you seeing a patter with certain supervisors losing more employees?  Are you paying enough?  What are your competitors offering for benefits?  What is the culture of your company?  If you're having trouble keeping people, the reason may lie within one of these answers.

• Check your safety-  Are your jobs safe?  Are you being shut down by the owner or general contractor's safety manager?  Being proactive about safety issues doesn't just keep people safe, happy, and healthy, it also prevents downtime and potential OSHA fines.

• Invest in good equipment- The first thing most people ask about equipment and tools is about cost.  The other day one of my customers called our Mud Hog mixers the "Cadillac of mixers" and said it came with a price tag to match.  I guess I'll take that as a compliment.  You get what you pay for- if a mixer breaks down and you can't get mortar to your crew, you're losing production AND someone has to fix the mixer.  You're now paying for two problems.  If this happens a few times over the lifespan of the mixer, you've already spent your cost savings from buying a cheaper alternative.  This holds true whether it's a mixer or any other piece of equipment.  

• Plan and Schedule- We've already gotten pretty good at this but communicating realistic deadlines and manpower projections with the general contractors from the beginning is key.  More people does not always mean more production.  Communicating schedules with your crews helps with productivity, as well as jobsite morale because the team feels included and they know what to expect in the next few weeks to months.

• Encourage English- This could be politically incorrect but, if you have a non-English speaking workforce, encourage them to work on learning to speak English.  Good communication on any jobsite is key but many times quality and production can suffer because of miscommunication.  There are free English courses held at many churches that employees could benefit from... and not just from an employment standpoint.  Often times some of your non-English speaking employees are your best guys and gals.  Let's help them and us!  

May you all be busy in a productive and safe way this week!  I'd love to hear some of your tips.

Post by:  Elizabeth "Liz" Graves, Sales Manager at Spec Rents, LLC.  Contact Liz at lizg@specrents.com