July 1, 2020

OSHA Directive Aims to Ensure Uniform Enforcement of Silica Standards

A new directive issued by OSHA on Friday provides guidance for OSHA compliance safety and health officers on enforcing the requirements of the agency’s respirable crystalline silica standards and clarifies topics such as variability in sampling, multi-employer situations, and temporary workers. The new directive also clarifies alternative exposure control methods when a construction employer does not fully and properly implement Table 1, “Specified Exposure Control Methods When Working With Materials Containing Crystalline Silica.” Table 1 matches common construction tasks and equipment with dust control methods that have been shown to be effective.

In addition, OSHA’s new directive covers requirements such as methods of compliance, exposure assessment, housekeeping, respiratory protection, regulated areas, recordkeeping, hazard communication, employee training, and medical surveillance.

OSHA’s final rule to protect workers from exposure to respirable crystalline silica was published in March 2016 and comprises two standards, one for construction and one for general industry and maritime. The standards include a lower eight-hour time-weighted average permissible exposure limit for respirable crystalline silica of 50 µg/m3 in general industry, maritime, and construction.

Most provisions of the construction standard became enforceable in September 2017, and enforcement of the requirements for sample analysis started in June 2018. OSHA began enforcing most provisions of the general industry and maritime standards in June 2018, but enforcement of some medical surveillance requirements began just last month on June 23, 2020. OSHA states that it will begin enforcing requirements for engineering controls for hydraulic fracturing operations in the oil and gas industry on June 23, 2021.

The new directive can be downloaded in PDF format from OSHA’s website. More information about OSHA’s respirable crystalline silica standards for construction and general industry and maritime is also available online.