Silica and OSHA Enforcement

Silicon dioxide, chemically formulated as SiO₂, is a compound that is found commonly throughout nature. Though naturally occurring, when silica dust is inhaled, there are a range of health complications that can result. The compound is often a byproduct in sectors such as construction and the maritime industry. To help protect workers, OSHA regulates exposure to silica in these industries. Two OSHA silica guidelines in particular are important for employers in these fields to become familiar with in order to ensure compliance. Both of these standards will receive an update in 2021. Continue reading for an in-depth look at these standards and expected revisions and the importance of protecting people from silica exposure hazards.

Understanding OSHA’s Silica Standards
The first OSHA silica standard is the Respirable Crystalline Silica Standard for Construction. Passed in 2016, this standard is written to limit worker exposure to respirable crystalline silica in the construction sector. Its actionable level of exposure is 50.0 µg/m³, which is weighed based on the average of an eight-hour day, and it further outlines steps employers must take to limit staff exposure.

The Respirable Crystalline Silica Standard for General Industry and Maritime followed in 2018 to govern the maritime and general industries. It defines the actionable exposure level of 25 µg/m³, which, like its predecessor, is averaged over a day lasting eight hours. It further dictates that workers should have limited access to areas where exposure could occur, and dust controls should be utilized to protect staff.

These standards are different in their specifications of exposure, but they are similar in the guidelines they establish: provide protective equipment to employees, monitor exposure, and provide access to medical care for exposed employees. These are just a few of the stipulations these standards establish for employers whose staff may be exposed to respirable crystalline silica in the workplace.

Upcoming Additions and Revisions to Standards
In 2021, you can expect a few updates to these two OSHA standards. Keep your eye out for the following new guidelines to be integrated into the implementation of the silica-specific acts affecting construction, maritime and general industries:

• The oil and gas industries will be expected to limit exposure by implementing dust controls by June 23, 2021.
• By June 23, 2021, employers must also offer medical surveillance to staff who are exposed at an actionable level.
• A proposed update to permissible exposure limits would implement an actionable exposure level of 50.0 µg/m³ across all industries.
• An instructional directive published June 25, 2020, indicates that OSHA silica enforcement inspectors will now perform exposure assessments and communication of hazards.

It’s important to stay aware of OSHA’s latest developments, especially as they relate to silica standards and enforcement. That’s the first step to keeping workers safe and maintaining compliance at your facility or worksite in 2021.

OSHA Enforcement, Guidelines and Violations
Though maintaining compliance or preparing for an inspection can be somewhat stressful, OSHA enforces these standards for the safety of staff and the overall benefit of industries. Inspections are designed to be uniform, objective, and effective in order to ensure that safe conditions are achieved. Enforcement guidelines are made available to employers, too, so that expectations are clear and accessible.

In 2018, one company was fined $304,130 and issued five citations for violations relating to crystalline silica exposure. The penalties were levied by the Virginia Department of Labor and Industry following an inspection which revealed that employees did not have proper face protection. The inspection also revealed that employees were not properly trained in communicating hazards, and exposure was not properly assessed.

In 2019, hazard communication, respiratory protection and eye and face protection all placed on OSHA’s list of top workplace violations. Providing workers with training and necessary personal protective equipment (PPE) helps minimize dangerous silica exposure. Safety visuals, like facility signs that reinforce the use of PPE and safety labels that highlight health hazards, remind workers to take proper precaution when working in certain areas where exposure could occur.

Though infractions can happen even in the most meticulously managed worksites, there is always room for improvement. Some other examples of violations that could compromise your compliance include the following:

• Failure to restrict access to areas of silica exposure
• Lack of PPE provided to employees
• No medical supervision provided to exposed staff
• No testing of exposure levels
• Greater daily exposure than 50.0 µg/m³

OSHA issues rates citations on a scale of offense, with lesser, negligent infractions being subject to smaller fines and penalties than willfully harmful infractions. As such, the degree to which you violate these standards will inform the magnitude of the citation you potentially receive.

Compliance Strategies for Employers Across Sectors
Regardless of what sector your business is in, you can minimize the risk of citation by being proactive and assessing and mitigating risks that are present in your workplace – including those regarding silica dust. Maintaining compliance is imperative, and expert consultants can help you get closer to your safety goals. From a big picture perspective, two things can help to substantially reduce injuries and deaths related to silica: 1) increasing awareness of the hazard and 2) defining and implementing proper workplace procedures that use specific PPE. Safety signs can help accomplish both of those tasks. Clarion Safety is dedicated to helping companies like yours with machinery safety and compliance needs, as well as visual safety communication across equipment and workplaces. 

• Standards Insider