I hope by now everyone who is reading this has already been put through the “scare” about SILICA. I will attempt to glean some of the key points for you without going into detail.
Silica exposure can be dangerous however it can be reduced with proper equipment and control measures put in place. One of the main health effects of exposure is silicosis. Silicosis is an irreversible, often disabling and sometimes fatal fibrotic lung disease.
- Chronic silicosis is the most common type of silicosis and usually occurs after at least 10 years of exposure to respirable crystalline silica
- Accelerated silicosis may occur within 5-10 years due to high levels of exposure
- Acute silicosis may occur within a few months to less than 2 years due to extremely high levels of exposure
Symptoms of silicosis may include:
- Shortness of breath
- Cough (with or without blood or mucus)
- Fatigue or weakness
- Night sweats
- Fever and loss of appetite may indicate other diseases associated with silica exposure such as TB infection or lung cancer
- There may be no symptoms for early stages of the disease
Other health effects of Silica exposure:
- * crystalline silica has been listed as a known human carcinogen
Silica exposure has been associated with:
- COPD, including chronic bronchitis and emphysema
- Several types of kidney disease, including end-stage renal disease
- Autoimmune conditions, including progressive systemic sclerosis, systemic lupus erythematosus, and rheumatoid arthritis
- Increasing an employee’s chances that latent TB will develop into active pulmonary TB infection
- Lung Cancer
The new Silica standard went into effect on September 23, 2017, nationally while Virginia used the July 23, 2017 date to implement the standard on a state level. I cannot speak to other state programs except for Maryland. Maryland OSHA will implement the new standard however with the various active conversations and lawsuits they will not proceed until such a time that a “final” final order is announced. As for federal enforcement, a Memorandum was sent out on September 20, 2017. The following is a link to that memorandum (you may have to copy and paste the link):
The memorandum outlines the criteria for a “grace period” of 30 days (from 9/23/17) whereby compliance officers will carefully evaluate the employer’s good faith efforts to meet the new construction silica standard. OK, what does that mean? Every employer still must have:
- Their company wrote Silica Exposure Control Plan
- Training documents of all potentially exposed employees and competent persons
- Along with other components of the rule in place (which could include required equipment with the integrated water delivery and vacuum systems)
- And show that you are working toward implementation of the standard
If they deem you not to be working towards compliance they may issue a citation.
If you have not completed or even started your written Silica Exposure Control Plan I would strongly recommend you read the 26 critical pages of 29CFR1926.1153. Get very familiar with the tasks, control methods and respiratory requirements in Table 1. You may notice that there are only 18 tasks in Table 1. If you will be performing a task, not in Table 1 you must first have sampling done to determine the exposure level for that process. Two numbers that you need to remember are:
- 50 micrograms per cubic meter of air (Permissible Exposure Limit or PEL)
- 25 micrograms per cubic meter of air (Action Level)
Analytical results that are below 25 micrograms per cubic meter of air the employer can discontinue monitoring and work can continue as long as control methods are properly used. Results above 25 but below 50 micrograms per cubic meter of air the employer will have to repeat the monitoring within 6 months. Exposed workers will be required to be entered into a medical surveillance program. Medical surveillance is also required whenever a worker is required to use a respirator for 30 days or more per year. The standard requires specific tests to be included in the examination. Medical exams must take place every 3 years or more frequently if the Physician or other licensed health-care professional (PLHCP) recommends it.
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I hope the information I have put together has been helpful.
Terry L. Foy
Foy Safety Consulting, Inc.