Things to consider if OSHA’s silica dust rule affects you

Silica dust is small enough to be invisible to the naked eye and circumvent the body’s natural defenses. Graphic courtesy of FelCom.

The Occupational Safety & Health Administration‘s (OSHA) deadline for compliance on respirable crystalline silica (RCS) dust emissions is approaching for general industry and maritime.

As OSHA’s June 23 deadline nears, manufacturers have been preparing operators to safeguard the health of workers with equipment that can minimize fine particulates, forced downtime and potential litigation.

“We believe dust control doesn’t need to come at the expense of production or profits, but should support operations and deliver a return on investment,” says Jerad Heitzler, Foundations training manager at Martin Engineering, which manufactures bulk material handling solutions such as belt cleaners and dust management solutions. “Although added regulations are always a strain on any business, compliance is an opportunity to assess aging systems and improve efficiency.”

Not only does OSHA’s final rule require regular monitoring by employers, but it sets personal exposure limits (PEL) and suggests engineering controls and particulate isolation rather than putting the entire onus of wearing respirators on employees.

“The RCS regulations are touching a wide range of companies,” says Edwin Peterson, CEO of BossTek, which manufactures dust suppression equipment. “Some operations can implement a single solution, whereas others create dust throughout the entire process and require unique solutions at each stage.”

Compliance

Companies that fall under OSHA’s purview are required to follow the agency’s compliance rules by using a personal dust monitor worn by a trained employee to monitor the amount of RCS and determine whether the exposure is under the average “action level” of 25 micrograms of RCS per cubic meter of air (µg/m³⁾. Plants must protect workers if they have an amount of RCS dust above the PEL of 50 µg/m³, averaged over an eight-hour day.

To control these levels, OSHA provides guidelines regarding methods of compliance, advising companies to take these steps:

1. Use engineering controls. These include isolating dust in sealed chute systems and dust collectors or using water-based atomized suppression systems.
2. Provide respirators. Compliance cannot be achieved by respirators alone, but respirators must be provided for use in areas where engineering controls cannot adequately limit exposure.
3. Limit worker access to high exposure areas. Limit access to areas where workers could be exposed to dust concentrations above the PEL.
4. Develop a written exposure control plan. Have it available along with monitoring results.
5. Offer medical exams to highly exposed workers. Review the regulation for compliance details.
6. Train workers on silica risks and how to limit exposure. Workers should be able to identify to OSHA inspectors the dust control supervisor and the compliance details when asked.

Non-compliance could result in fines, process disruptions and legal action by federal or state agencies or workers. If PEL readings are at or above the permissible exposure level, plants must take action with isolation or engineered controls, and fines for first offenses can be steep. For example, following the construction industry deadline last summer, some general contractors and developers faced fines of up to $70,000.

“Compliance not only protects workers, but also protects the bottom line from fines, downtime and lawsuits,” Peterson says. “Investing in long-lasting and field-proven equipment translates to a sensible ROI and peace of mind over the long term.”