Silica Resource Packet

Dear CSA Member:

We are pleased to provide you this Silica Resource Packet.

As you are aware, both California and Federal OSHA have issued new warnings and regulatory guidelines pertaining to silica and the hazards it presents in the construction trades.

Employer obligations under the new Respirable Crystalline Silica standard for construction, found in the California Code of Regulations, Title 8, section 1532.3, commenced on June 23, 2017. Effective October 23, 2017, Cal/OSHA is fully enforcing all appropriate provisions of the standard. This follows federal OSHA’s approach regarding enforcement of their corresponding standard.

Sign contractors who engage in activities that create silica dust, such as by cutting, grinding or blasting materials like concrete, stone and brick, must meet a stricter standard for how much of that dust workers inhale. The same goes for employers of tradespeople working around such activities. The new standard also specifies what services employers must make available to workers who are exposed to high levels of silica dust and the training required of those who are at risk.

This new standard has been under development for almost 20 years and supersedes OSHA’s first silica standard, issued in 1971. The old standard required that silica dust particles, which are 100 times smaller than sand granules, be limited to 250 micrograms per cubic meter of air over an average of eight hours — the hours of a typical work shift. The new standard reduces that to 50 micrograms over the same time period.

In addition to the exposure limits, the new rules require contractors to:

1. Develop a written silica exposure control plan.
2. Designate someone to implement the plan.
3. Adjust housekeeping practices to maximize control of silica dust.
4. Provide medical exams every three years to employees who are exposed to silica to the point of having to wear a respirator for 30 days or more each year. The exams must include lung-function tests and chest X-rays.
5. Train workers on how to limit exposure to silica.
6. Keep records of workers’ silica exposure and related medical treatment.

Implementing the new rules requires an initial assessment of how much silica dust a company’s operations generate.

EXCEPTION:  If an exposure reading falls below the level of 25 micrograms, then the company is not required to provide medical tests, develop a written plan or undertake any of the suggested engineering controls (such as wearing respirators, wetting work down with tools like a wet saw, or using a vacuum device to reduce the volume of dust).

However, workers should nonetheless be aware of and take precaution from potential jobsite exposure caused by other onsite construction activities unrelated to their trade, such as demolition work, concrete, asphalt, stucco, drywall, gunite, etc, performed by other contractors.

Q: What about plastics or acrylics?
A: Federal Heath recently conducted a silica audit test at one of its facilities. Dennis Lytle, Federal Heath’s Safety Manager (and current CSA president), reports, “The sample was taken for 8 hours while all variety of acrylics/plastics were cut on our router. The levels were barely detectable, much less measurable. As such the readings were well below the permissible levels outlined in the Silica Standard.”

Nonetheless, CSA members are reminded that results will be different for each shop, depending on the methods and machinery utilized. Each contractor is responsible for making its own determination — and maintaining proper documentation is mandatory.

THESE RESOURCES, including the California Department of Industrial Relations silica assessment online e-tools, should be consulted for further guidance:

• Silica Hazard Alert (English/Spanish) from the Calif Dept of Industrial Relations, including a training requirements checklist https://www.dir.ca.gov/dosh/dosh_publications/P08-019V3.pdf

https://www.dir.ca.gov/dosh/dosh_publications/P08-019V3s.pdf

• Cal/OSHA “Hazards of Silica in Construction” e-tool

https://www.dir.ca.gov/dosh/etools/08-019/index.htm

• Guidance on How to Control the Hazard

https://www.dir.ca.gov/dosh/etools/08-019/EP08-019All.pdf

• Specific Exposure Control Methods — weblink to the governing California regulation, Section 1532.3 https://www.dir.ca.gov/title8/1532_3.html

> ISA weblinks to Silica management best practices. ISA Silica Resources

• “Silica in Construction” Training Kit – weblink from the State of Washington

http://www.lni.wa.gov/SAFETY/TRAININGPREVENTION/TRAININGKITS/SILICAINCONSTRUCTION/DEFAULT.ASP

> Preparing a Silica Control Plan. This is an easy online free program:  https://plan.silica-safe.org/

DISCLAIMER.  This information is general in nature and provided as a member service from sources believed to be reliable, including ISA and the California Dept of Industrial Relations.  However, it should not be construed as legal advice or regulatory guidance from CSA about your particular operations.  Members are encouraged to consult legal counsel with any questions.