The enforcement of OSHA’s respirable crystalline silica standard that applies to the construction industry begins on September 23, 2017. After some delays to allow OSHA to conduct additional outreach and to provide educational materials and guidance to employers, the date is almost upon us. Are you ready? If not quite there yet, KCA can help.
Since it could be debated that this is one of the most complex standards the construction industry has faced, it was understandable that it seemed as though a silica event happened daily throughout the country. At the Keystone Contractors Association, we wanted to host one more educational event on this topic to assure construction employers are prepared. This week we hosted a facilitated discussion led by OSHA’s Dale Glacken, Compliance Assistance Specialist for the OSHA Harrisburg Area Office. This discussion included commercial construction professionals from both general contractors and subcontractors based throughout the Commonwealth.
Here are the key takeaways from this discussion:
- List – Prior to project commencement, make a list of all potential silica hazards. Add the tasks that will need to be performed on a project where workers could be exposed to silica. Will sandblasting be performed on this project? What about jackhammering, concrete drilling, brick/concrete cutting, concrete mixing, chipping/scraping, etc.? Just think about the project and what construction activity needs to happen as you reach milestones along the way.
- Assessment – After your list is created, go down each activity and assess each one. Provide the details for each item to understand them better – how much time will it take, what tools are needed, how many people, etc.?
- Controls – While working off the list created earlier and the details on each item, think now about how to control the silica exposure for your workforce. What PPE is needed? Do the tasks have to be completed near other workers, or for example can blocks be cut away from others in an enclosed area? What are ways that dust be controlled? At this point you may want to refer to the table 1 of the OSHA silica standard to assist you in determining if you’re in compliance: https://www.osha.gov/silica/SilicaConstructionRegText.pdf.
- Plan – Led by your company’s silica competent person, create the project specific plan, which includes specific controls for each activity that could potentially expose workers to crystalline silica. This plan should highlight scope of work to be completed, control methods, and housekeeping. Housekeeping is important in a silica plan, just as it is important in every aspect of safety. I’ve noticed that a clean jobsite, tends to be a safer jobsite. Also while developing the plan, think about if areas should be restricted to limit silica exposure. But don’t just create a plan and let it collect dust, make sure to implement it and carry out those competent person inspections, plus refer to the plan throughout the project to make sure it is being carried out and workers are protected.
- Training – As highlighted in the plan, training plays a vital role. In this plan, training should focus on tasks that expose workers to silica. Along with making sure tools and PPE are made available, make sure too that training is available for those tools and PPE; proper use is necessary and don’t assume someone knows how to use something. The copy of OSHA’s Silica Standard should be readily available to all workers.
- Medical – Making sure workers are healthy, and keeping them healthy, is important to this new standard. If a worker is to wear a respirator for more than 30 days per year, medical surveillance is required by the employer. This examination must be completed within 30 days of assignment unless the employee has had an examination within the last three years. Then periodical medical examinations should be offered at least every three years, or more if recommended by a health care professional. The employer will maintain a medical surveillance record on each employee.
Along with the rousing discussion, this KCA silica event also featured plenty of resources on the topic. KCA has each resource that was discussed, as well as numerous other silica resources that can help your company. Please do not hesitate to contact the KCA for help. To reach KCA call 717-731-6272.
NOTE: Comments were made during the event that many small businesses that work in the construction industry may not be prepared for the silica changes. Many KCA contractor members extended an invite to subcontractors who did not even know about this standard. If you encounter firms that need help, please let them know the KCA is here for them. We can schedule a time to stop by their operation or if they’d like we can simply provide them the resources needed on OSHA’s New Silica Standard.