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2018 Changes in Handling Respirable Silica

New safety standards are being put in place by the Hawaii Occupational Safety and Health (HIOSH)) to better protect workers from the side effects of respirable crystalline silica. In order to support your organization as these changes take effect, ProService Hawaii has compiled a list of FAQ. If you need more information about these and other standards, please contact us at safety@proservice.com.

This FAQ guide will cover the following sections:

  1. Overview of Silica and Important Requirements
  2. More Details About the Written Exposure Control Plan
  3. Timing
  4. Failure to Comply
  5. Additional Resources

 

1. Overview of Silica and Known Requirements

Q: What is silica?
A: According to the Occupational Safety and Health Administration (OSHA):

  • Crystalline silica is a common mineral found in the earth's crust. Materials like sand, stone, concrete, and mortar contain crystalline silica. It is also used to make products such as glass, pottery, ceramics, bricks, and artificial stone.
  • Respirable crystalline silica – very small particles at least 100 times smaller than ordinary sand you might find on beaches and playgrounds – is created when cutting, sawing, grinding, drilling, and crushing stone, rock, concrete, brick, block, and mortar.

Workers who inhale these very small crystalline silica particles are at increased risk of developing serious silica-related diseases, including:

  • Silicosis, an incurable lung disease that can lead to disability and death;
  • Lung cancer;
  • Chronic obstructive pulmonary disease (COPD); and
  • Kidney disease.

For more information visit the OSHA overview on silica.

Q: What are the new requirements ProService has communicated?
A: ProService has communicated information regarding the following three important requirements:A respirator is required if there is exposure of greater than 25 micrograms of respirable crystalline silica per meters cubed, as an 8-hour time-weighted average (TWA) under any foreseeable conditions. Medical surveillance is required anytime a respirator is required (this includes dust masks) and can only be given by a licensed medical professional.

A written Exposure Control Plan, which according to HIOSH should “provide a systematic approach for ensuring proper function of engineering controls and effective work practices that can prevent over-exposures from occurring. HIOSH expects a written Exposure Control Plan will be instrumental in ensuring that employers comprehensively and consistently protect their employees.”

In other words, your Exposure Control Plan is your main list of everything you’re doing onsite to protect workers from silica dust.

Organizations must have a designated competent person. A competent person is defined by the Occupational Safety and Health Administration (OSHA) as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” As an employer, it is your responsibility to designate a competent person(s) who is able to recognize hazards associated with respirable silica.

 

2. More Details About the Exposure Control Plan Requirement

Q: What are the exact requirements for the written Exposure Control Plan?
A: According to HIOSH, your written Exposure Control Plan must contain the following four elements:

  • A description of the tasks in the workplace that involve exposure to respirable crystalline silica.
  • A description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task.
  • A description of the housekeeping measures used to limit employee exposure to respirable crystalline silica.
  • A description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed to respirable crystalline silica and their level of exposure, including exposures generated by other employers or sole proprietors.

Your Exposure Control Plan can also include anything else you think is important about keeping your employees safe from respirable crystalline silica at your worksite.

Q: Do any other requirements accompany the plan?
A: Yes. HIOSH also requires an annual review to ensure the plan is effectively updated.

For the construction industry, the employer also needs to designate someone to perform job site inspections, including materials and equipment, on a frequent and regular basis. It can be assumed this is to help implement the control plan. If you have questions, please contact OSHA or HIOSH.

Q: In the construction scenario, do I need to put the name of my competent person (or competent people) in the written Exposure Control Plan?
A: No. HIOSH is not requiring you to give the identity of the person in the written Exposure Control Plan. HIOSH says this is because it expects that the person (or persons) will change frequently.

Q: Do I need to have a copy of the plan available?
A: A copy of the plan needs to be readily available should an employee or inspector request it.

Since HIOSH has not specified how quickly the copy needs to be accessed, or if it can be accessed electronically, best practice is to make sure a physical copy is available.

Q: What are the requirements regarding the author of the Exposure Control Plan?
A: HIOSH expects that “a supervisor will develop and update the written Exposure Control Plan.” Based on this, it is our suspicion that HIOSH will want to see that the author of the plan has some sort of supervisory role. At the very least, the author should not be a new or entry-level employee.

 

3. Timing

Q: When will these safety standard changes go into effect?
A: HIOSH will hold a public hearing about the implementation of the new standards on May 18, 2018, and then they will go before the governor for approval. HIOSH is anticipating new standards to take effect in June 2018.

Q: How long will I have to prepare after the date for implementation is announced?
A: There will be no grace period or time allotted for organizations to become compliant. The requirements take effect immediately.

4. Failure to Comply

Q: What happens if I do not comply to these standards?
A: Failure to comply will result in a fine. In addition to being fined, contractors will not be approved to complete jobs and they could have to stop work mid-way through a job until they are compliant.

 

5. Additional Resources

Q: Where can I find more information on these and other changes? 
A: There are several resources available today that will help you prepare for these changes:

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