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As industrial hygienists and safety professionals, we are on the brink of a long overdue but significant regulatory shift with the introduction of MSHA's silica rule, which is set to take effect in 2024. This rule will lower the permissible exposure limit (PEL) for respirable crystalline silica to 50 micrograms per cubic meter of air (µg/m³) over an 8-hour time-weighted average, aligning with OSHA standards and reflecting an increased emphasis on miner health and safety. It will also introduce an action level for silica of 25 µg/m³ for a full-shift exposure, calculated as an 8-hour TWA. If exposure monitoring indicates an exceedance of the action level, then the mine operator would be required to conduct periodic sampling.

The rule will impact coal mines and all metal and nonmetal mining industries. This includes operations involved in the extraction and processing of minerals and materials that contain crystalline silica, such as underground and surface mining, quarries, sand and gravel extraction, and other activities related to the mining sector.

Key Components of the Rule

The rule introduces a stringent PEL for respirable crystalline silica, emphasizing the need for enhanced monitoring and control measures in mining operations. To ensure compliance with the new PEL, the rule will require more frequent and comprehensive silica dust sampling in mining environments. The rule also includes more rigorous enforcement protocols, with potential for increased inspections and penalties for noncompliance.

Impact on Analytical Laboratories

The increased sampling requirements will inevitably lead to a surge in demand for laboratory analysis of silica samples, presenting both challenges and opportunities for analytical laboratories. Laboratories must prepare for a significant uptick in sample volume, which may strain existing capacities and necessitate operational expansions.

Because laboratories rely on third parties to manufacture and provide sampling media used for collection of field samples, a sudden demand for this media could result in supply chain interruptions while manufacturing struggles to meet the increasing demand. To efficiently handle the increased workload and ensure precise results, laboratories might need to invest in advanced analytical technologies and automation.

The complexity and volume of analyses will drive demand for skilled technicians and analysts, highlighting the need for robust training and development programs. With the rise in sample throughput, maintaining high-quality control and assurance standards will become paramount to ensure accuracy and reliability in silica analysis.

Recommendations

Laboratories should assess their current capabilities and plan for scalable expansions in personnel, technology, and facilities to accommodate the anticipated increase in sample analysis. Embracing advanced analytical techniques and investing in employee training can enhance laboratory efficiency and accuracy, positioning facilities as preferred partners in silica analysis. Engaging with mining companies, regulatory bodies, and health professionals can provide insights into evolving industry needs and regulatory expectations, guiding strategic planning and service offerings.

With the implementation of MSHA's 2024 silica rule, the landscape of industrial hygiene and safety is poised for change. Analytical laboratories play a crucial role in this transition, and their readiness to adapt will be instrumental in ensuring the mining industry's compliance with these new standards, ultimately contributing to a safer working environment for miners.