NRCA has developed tools for contractors to use to comply with provisions of the U.S. Occupational Safety and Health Administration's (OSHA's) new regulation targeted at respirable crystalline silica (RCS) in the workplace.
In this section you will find:
The regulatory text of the rule at 29 CFR §1153 and Appendices A and B29 CFR §1153
A sample written exposure control plan that contractors may adapt to specify the elements required by the rule to limit worker exposures based on the specific tasks workers are performingSAMPLE EXPOSURE CONTROL PLAN
Links to outside resources that may be useful for compliance assistance with equipment options, objective data compilations, industrial hygiene and laboratory needs, and plan developmentWEBSITE RESOURCES
NRCA's objective data collection for roofing industry exposures under 29 CFR 1926.1153 (this document will be supplemented as more roofing tasks are sampled and lab reports are received)DATA COLLECTION
A silica decision tree to assist roofing contractors in determining the proper steps for compliance with the OSHA regulation by following a straightforward question and answer diagram to detail the proper procedures to follow.DECISION TREE
Silica refers to the chemical compound silicon dioxide (SiO2), the most common form of which is quartz. Sand, a key component in many building products such as mortar, clay and concrete tiles or pavers, and brick, is mainly composed of silica in the form of quartz. The danger results when the smallest of particles (respirable) penetrate to the gas exchange area of the lungs; larger particles do not travel that deep into the lungs and are purged by natural actions of the body. The respirable particles remain in the lungs and cause permanent scarring of lung tissue, making breathing increasingly more difficult—an occupational disease known as silicosis that often does not manifest until many years after exposure. According to the American Lung Association, silicosis also increases the risk of other lung issues such as tuberculosis, lung cancer and chronic bronchitis.
OSHA has published a new rule regarding worker exposure to RCS in construction that took effect Sept. 23, 2017. Silica is a concern when certain products or materials are cut, drilled or ground using powered equipment and abrasive blades, drills or other equipment that results in dust comprising respirable particles. Products that list silica, quartz or sand on the safety data sheet supplied by the manufacturer or materials that contain those components may be a source of RCS. The OSHA regulation sets out new protocols for minimizing worker exposure that are more comprehensive than the prior rule and will require greater compliance efforts on the part of contractors.
The rule applies to all exposures in construction except where worker exposure remains below 25 micrograms per cubic meter of air as an eight-hour time-weighted average. The 25-microgram threshold is what OSHA defines as the action level. A more protective or restrictive permissible exposure limit (PEL) of 50 micrograms per cubic meter of air as an eight-hour time-weighted average has been established under the rule. A unique feature of the rule is OSHA's specification in Table 1 at 29 CFR §1153(c)(1) of control methods for 18 construction tasks or equipment uses. If a contractor implements the engineering controls and respiratory protection listed in Table 1 for a specific task, the contractor is considered in compliance with the rules for exposure to crystalline silica under the rule?initial exposure monitoring would not be required. As an example, Table 1 requires an integrated water delivery system that continuously feeds water to the blade of a handheld power saw used to cut suspect material. For outdoor use of four hours or less, Table 1 does not require the operator to wear a respirator in conjunction with water delivery to the blade. However, if cutting exceeds four hours, a respirator with an assigned protection factor (APF) of 10 also must be used with the water delivery system.
If workers are performing tasks not listed in Table 1 or if the control methods specified in Table 1 for a task are not fully implemented, a contractor must ensure no worker is exposed to RCS in amounts exceeding the PEL. This assessment may be done through any combination of air monitoring or the use of objective data. OSHA notes that reliance on objective data is intended to provide the same degree of assurance as is provided by air monitoring of worker exposures through personal breathing zone sampling, and it comes with a specific recordkeeping requirement. Objective data must reflect workplace conditions closely resembling the processes, material types, control methods, work practices and environmental conditions in the contractor's current operations. Industry data is acceptable under the rule's definition of the term.
The rule also establishes a medical surveillance requirement tied to the number of days a worker must use a respirator. If respirator use will be required on 30 or more days during a year, the contractor must ensure a number of medical examinations and procedures take place. For example, an initial examination must focus on the worker's medical and work history and include a physical exam, chest X-ray, pulmonary function test and tuberculosis test. OSHA requires an initial examination as a baseline evaluation to be performed within 30 days after the worker's initial assignment.
Finally, with respect to training, the rule requires a contractor to include RCS in its hazard communication program and specifically address cancer, lung, immune system and kidney issues related to exposure. A contractor must make sure workers demonstrate knowledge and understanding of hazards related to silica exposure, tasks in the workplace that can result in exposure, control measures the contractor has implemented to protect workers, the provisions of the new OSHA rule, identity of the competent person who will inspect job sites to implement the written exposure control plan, and the purpose and features of the medical surveillance program.