Avoiding the Pitfalls of OSHA Silica Standard Compliance
In a popular session titled “Avoiding the Pitfalls of OSHA Silica Standard Compliance Across Large and Small Construction Organizations” at AIHce EXP 2019 in Minneapolis, Minn., in May 2019, industrial hygiene professionals learned about the most prevalent silica-related OSHA violations and strategies to avoid them.
“As industrial hygienists, we take a lot of time to come up with great policy,” said presenter David Olvera, MPA, MPH. “We develop programs. We come up with training. We invest a lot of time in those, and sometimes when get out into the field it seems like things fall apart when we fall into the old classics of complacency, the perishable nature of knowledge, and a lot of other variables that are in play.”
Olvera, the Corporate Occupational Health Manager for Zachry Group in San Antonio, Texas, outlined the most common silica-related violations cited by OSHA, discussed common pitfalls industrial hygienists face in each area, and suggested a wide array of best practices.
OSHA Citation #1: Failure to Conduct an Exposure Assessment
According to Olvera, “Assuming that exposure assessment under the scheduled monitoring option constitutes an easier path . . . doesn’t play very well with the actuality of construction. To get that data in a timely manner and to be able to draw conclusions from it, you’re basically chasing folks.” He offers this alternative: “The idea here is to plug the industrial hygienist into larger structures of management—not to rely on things like safety professionals, or even foremen, but to plug in with planners, with the logistical folks, who are handling materials, to understand when this work is going to occur so that you can be successful in gaining an edge on sampling. You can be more strategic about collecting those exposures and getting data that’s useful for other purposes.”
OSHA Citation #2: Failure to Adhere to Table 1
Olvera asserts that lack of adherence to Table 1 in OSHA’s silica standard for construction may stem from a failure to understand and navigate operational realities that influence compliance. “In the picture-perfect world in the timeline of construction, we start with a project, we mobilize our IH programs, and then we implement them in the field,” he said. “Unfortunately, this is rarely, if ever, the case.” He encouraged IH teams to remain aware of contract and project timelines and funding constraints. He also recommended several strategies to create efficiencies and protect a project’s timeline, including building relationships with equipment rental vendors. “The problem with purchasing is, if I purchase devices and controls, I am now in the business of managing equipment,” Olvera said.
OSHA Citation #3: An Inadequate Exposure Control Plan
When writing an exposure control plan, industrial hygienists should take care to review legacy information, Olvera said. “The tendency when we write our exposure control plans is to reinvent the wheel every time we go from site to site. In larger organizations, we catalog the information we come up with and our best practices, and we disseminate it. There is learning value in capturing the data and the information as you move from client to client. And our information is readily available in the field.”
AIHA: “Recommended Skills and Capabilities for Silica Competent Persons” (PDF).
EHS Today: “What the First Six Months of Silica Enforcement Tells Us” (June 2018).
Laborers’ Health & Safety Fund of North America: “What We’re Learning About OSHA Enforcement of the Silica Rule in Construction” (December 2018).