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Osha 3902
Osha 3902
Osha 3902
Compliance Guide
for the Respirable Crystalline
Silica Standard for Construction
“To assure safe and healthful working conditions for working men
and women; by authorizing enforcement of the standards developed
under the Act; by assisting and encouraging the States in their
efforts to assure safe and healthful working conditions; by providing
for research, information, education, and training in the field
of occupational safety and health.”
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 1
All employers covered by the standard must: ■ Offer medical exams to employees who
will be required to wear a respirator under
■ Provide respiratory protection when required; the standard for 30 or more days a year;
■ Restrict housekeeping practices that expose ■ Communicate hazards and train
employees to respirable crystalline silica employees; and
where feasible alternatives are available; ■ Keep records of medical examinations.
■ Establish and implement a written
exposure control plan, including See the roadmap listed below for more
designating a competent person; information.
Roadmap for Meeting the Requirements of the Respirable Crystalline Silica Standard
1. Determine if the silica standard applies to your employees.
Could employees be exposed to respirable crystalline silica at or above 25 µg/m3 as an 8-hour TWA under any
foreseeable conditions, including the failure of engineering controls, while performing construction activities?
No: No further action is required under the silica standard.
Yes: Choose to comply with the standard using either the:
• Specified exposure control methods in Table 1, or
• The alternative methods of compliance
2. D
etermine what additional requirements you must meet under the standard, based on the compliance
method you are following.
Recordkeeping Yes, for any employees who are Yes, for exposure assessments
getting medical examinations and for any employees who are
getting medical examinations
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 3
Some employees in the construction sector example, for hole drillers using hand-held
perform tasks involving occasional, brief drills, if the duration of exposure is 15
exposures to respirable crystalline silica that minutes or less, the 8-hour TWA exposure
are incidental to their primary work. These can reasonably be anticipated to remain
workers include carpenters, plumbers, and under the 25 μg/m3 threshold (assuming no
electricians who occasionally drill holes exposure for the remainder of the shift), and
in concrete or masonry or perform other the standard would not apply.
tasks that involve exposure to respirable
crystalline silica. Where employees perform This exception for situations where
tasks that involve exposure to respirable exposures are not likely to present significant
crystalline silica for a very short period risk to workers allows employers to focus
of time, exposures for many tasks will be their resources on exposures of greater
below 25 μg/m3 as an 8-hour TWA. For occupational health concern.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 5
task. For example, an employee operating manufacturers’ instructions for minimizing
a walk-behind saw and another employee dust emissions. Manufacturer’s instructions
helping the operator guide the saw are both for minimizing dust can include:
engaged in the task. An employee operating
a jackhammer would be engaged in the ■ Water flow rates,
task, but another employee directing traffic ■ Vacuum equipment air flow rate and
near the employee jackhammering would capacity,
not be engaged in the task. When Table 1 ■ Rotation of the blade (speed, direction),
requires respiratory protection, employers ■ Maintaining and changing blades, and
must provide respirators to all employees ■ Frequency for changing water.
engaged in the task. Employers must See sections on Water Delivery Systems and
describe procedures for restricting access of Dust Collection Systems for more information
employees not engaged in the task as part of about the use of controls for respirable
its Written Exposure Control Plan. crystalline silica.
Fully and properly implemented means that Several entries in Table 1 have requirements
controls are in place, are properly operated for the use of respiratory protection with
and maintained, and employees understand a minimum “assigned protection factor”
how to use them. Several factors required (APF). Paragraph (d)(3)(i)(A) of the Respiratory
for full and proper implementation of Protection standard (29 CFR 1910.134) includes
controls are listed in the discussion for each a table that can be used to determine the
Table 1 entry below. The presence of large type or class of respirator that will provide
amounts of visible dust generally indicates employees with a particular APF, and it
that controls are not fully and properly can help employers determine the type of
implemented. A small amount of dust can be respirator that would meet the required
expected from equipment that is operating minimum APF specified by Table 1. Employers
as intended by the manufacturer; however, a have the flexibility to provide a more
noticeable increase in dust generation during protective respirator to those employees who
the task is a sign that the dust controls are not request one or require the employees to use
operating correctly. The difference between a more protective respirator. See section on
the small amounts of dust generated when Determining Task Duration and Requirements
control measures are working properly and for Respirator Use for information on how
the large amount of dust generated during to measure task duration to determine
tasks when control measures are not used or respiratory protection requirements for
not operated effectively is easily observed. employees doing one or more Table 1 task.
When this happens, prompt corrective
actions are required. Description of Table 1 Entries
As part of full and proper implementation, This section lists each Table 1 entry and
many Table 1 tasks require the employer explains the requirement for that entry.
to operate and maintain tools according to
(i) Stationary masonry saws Use saw equipped with integrated water None None
delivery system that continuously feeds
water to the blade.
Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
Stationary masonry saws must be equipped When using a stationary masonry saw
with an integrated water delivery system indoors or in an enclosed space (areas
(supplied by the equipment manufacturer where airborne dust can buildup, such as
and developed specifically for the tool in a structure with a roof and three walls),
use) that continuously feeds water to the employers must provide additional exhaust
blade. The water delivery system usually as needed to minimize the accumulation of
includes a nozzle for spraying water attached visible airborne dust.
near the blade that is connected to a water
basin by a hose and pump. The tool must See the section on Indoors or Enclosed Areas
be operated and maintained in accordance for more information.
with manufacturer’s instructions to minimize Respiratory protection is not required for
dust emissions. Stationary masonry saws work with stationary masonry saws
equipped with an integrated system for blade regardless of task duration.
cooling also suppress dust and meet the
requirements of Table 1.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 7
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
(ii) Handheld power saws Use saw equipped with integrated water
(any blade diameter) delivery system that continuously feeds
water to the blade.
Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
• When used outdoors. None APF 10
• When used indoors or in an enclosed area. APF 10 APF 10
Handheld power saws with any blade Table 1 does not specify a minimum flow
diameter must be equipped with an rate; however, water must be applied at the
integrated water delivery system (supplied flow rate specified by the manufacturer.
by the equipment manufacturer and
When working with handheld power saws
developed specifically for the tool in use)
of any blade diameter, respiratory protection
that continuously feeds water to the blade.
with a minimum APF of 10 is required for
The water delivery system usually includes
work done outdoors for
a nozzle for spraying water attached near
more than four hours per
the blade that is connected to a water basin
shift and for work done
via a hose and pump. The tool must be
indoors, or in an enclosed
operated and maintained in accordance with
location, regardless of
manufacturer’s instructions to minimize dust
task duration.
emissions. Handheld power saws equipped
with an integrated water delivery system for When using a handheld
blade cooling also suppress dusts and meet saw indoors or in
the requirements of Table 1. enclosed spaces (areas
where airborne dust
Full and proper implementation of water
can buildup, such
controls on handheld power saws requires
as a structure with a A worker cutting a concrete
the employer to ensure that:
roof and three walls), block using a handheld
masonry saw with an
■ An adequate supply of water for dust employers must provide
integrated water delivery
suppression is used; additional exhaust, as system.
■ The spray nozzle is working properly to needed to minimize the Photo courtesy Husqvarna.
apply water at the point of dust generation; accumulation of visible The equipment shown in
this picture is for illustrative
■ The spray nozzle is not clogged or damaged; airborne dust. See the purposes only and is not
■ All hoses and connections are intact. section on Indoors or intended as an endorsement
Enclosed Areas for more by OSHA of this company, its
products or services.
information.
Specialty handheld power saws for cutting ■ The dust collection bags are emptied to
fiber-cement board (with a blade diameter avoid overfilling.
of 8 inches or less) must be equipped with
commercially available dust collection Respiratory protection is not required for
systems and a filter with a 99 percent or work outdoors with specialty handheld
greater efficiency. The saws must be operated power saws while cutting fiber-cement board
and maintained in accordance with the regardless of task duration.
manufacturer’s instructions to minimize
dust emissions, and provide the air flow rate
recommended by the manufacturer or greater.
When employers are complying with Table 1,
the saws must only be used outdoors.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 9
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
Walk-behind saws must be equipped areas (areas where airborne dust can
with an integrated water delivery system buildup, such as a structure with a roof
(supplied by the equipment manufacturer and three walls), employers must provide
and developed specifically for the tool in use) additional exhaust, as needed to minimize
that continuously feeds water to the blade. the accumulation of visible airborne dust. See
The tool must be operated and maintained in the section on Indoors or Enclosed Areas for
accordance with manufacturer’s instructions more information.
to minimize dust emissions. Full and proper
implementation of water controls on walk- When working outdoors, respiratory protection
behind saws requires the employer to ensure is not required for work with walk-behind saws
that: regardless of task duration. When working
indoors, or in an enclosed location, respiratory
■ An adequate supply of water for dust protection with a minimum APF of 10 is
suppression is used; required regardless of task duration.
■ The spray nozzles are working properly
to apply water at the point of dust
generation;
■ The spray nozzles are not clogged or
damaged; and
■ All hoses and connections are intact.
Drivable saws used to cut silica-containing Respiratory protection is not required for
materials (such as concrete, asphalt, granite work with drivable saws regardless of task
and terrazzo) must be equipped with an duration.
integrated water delivery system (supplied
by the equipment manufacturer and
developed specifically for the tool in use)
that continuously feeds water to the blade
and must be operated and maintained in
accordance with manufacturer’s instructions
to minimize dust emissions. Employers
following Table 1 must only allow the saws to
be used outdoors.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 11
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
(vi) Rig-mounted core • Use tool equipped with integrated water None None
saws or drills delivery system that supplies water to
cutting surface.
• Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
(vii) Handheld and stand- • Use drill equipped with commercially None None
mounted drills (including available shroud or cowling with dust
impact and rotary hammer collection system.
drills) • Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
• Dust collector must provide the air flow
recommended by the tool manufacturer,
or greater, and have a filter with 99% or
greater efficiency and a filter-cleaning
mechanism.
• Use a HEPA-filtered vacuum when
cleaning holes.
■ The shroud or cowling is intact and Photo courtesy of DeWalt. The equipment shown in this picture is for
illustrative purposes only and is not intended as an endorsement by OSHA of
installed in accordance with the this company, its products or services.
manufacturer’s instructions;
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 13
■ The hose connecting the tool to the Respiratory protection is not required when
vacuum is intact and without kinks or using handheld or stand-mounted drills
tight bends; equipped with a dust collection system,
■ The filter(s) on the vacuum are cleaned including for overhead drilling, regardless of
or changed in accordance with the task duration.
manufacturer’s instructions; and
■ The dust collection bags are emptied to
avoid overfilling.
(viii) Dowel drilling rigs for For tasks performed outdoors only:
concrete
• Use shroud around drill bit with a APF 10 APF 10
dust collection system. Dust collector
must have a filter with 99% or greater
efficiency and a filter-cleaning
mechanism.
• Use a HEPA-filtered vacuum when
cleaning holes.
Dowel drills for concrete (i.e., gang drills) are A HEPA-filtered vacuum must be used when
drills equipped with multiple drill bits that are cleaning holes. Compressed air can be used
used to drill several holes at the same time. to clean holes when used in conjunction with
Dowel drills must be equipped with a shroud a HEPA-filtered vacuum to capture the dust
around the drill bit and a dust collection or a hole cleaning kit designed for use with
system that has a filter with 99 percent compressed air.
or greater efficiency. The dust collection
equipment must be equipped with a filter Respiratory protection with a minimum APF of
cleaning mechanism. Employers following 10 is required for all work with dowel drilling
Table 1 must allow dowel drilling rigs to only rigs for concrete regardless of task duration.
be used outdoors.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 15
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
(ix) Vehicle-mounted Use dust collection system with close None None
drilling rigs for rock and capture hood or shroud around drill bit with
concrete a low-flow water spray to wet the dust at the
discharge point from the dust collector.
OR
Operate from within an enclosed cab and None None
use water for dust suppression on drill bit.
Vehicle-mounted rock and concrete ■ The filter(s) on the vacuum are cleaned
drilling rigs must be equipped with a dust or changed in accordance with the
collection system with a close capture hood manufacturer’s instructions; and
or shroud around the drill bit, and a low- ■ The dust collection bags are emptied to
flow water spray to wet the dust discharged avoid overfilling.
from the dust collector. This combination
of local exhaust ventilation (LEV) and water Full and proper
application controls dust at all emission implementation of
points that can contribute to the operator’s water controls on
and other employees’ exposures. vehicle-mounted
drilling rigs requires
Employers also have the option to have the employer to
the drill operator work within an enclosed ensure that:
cab and, when necessary, apply water at
the drill bit, as described above, to reduce ■ An adequate
exposures to other employees in the area. supply of Vehicle-mounted drilling rig using water on the
See the section on Enclosed Cabs for more water for dust drill bit. The enclosed operator’s cab is on the
suppression right.
information on how to make sure cabs meet
the requirements of Table 1. is used; Photo courtesy of NIOSH.
■ The spray nozzles are working properly and
Full and proper implementation of dust produce a pattern that applies water on the
collection systems on vehicle-mounted drilling discharge point from the dust collector;
rigs requires the employer to ensure that: ■ The spray nozzles are not clogged or
damaged; and
■ The shroud or hood is intact and installed ■ All hoses and connections are intact.
in accordance with the manufacturer’s
instructions; Respiratory protection is not required for
■ The hose connecting the tool to the vacuum work with vehicle-mounted drilling rigs
is intact and without kinks or tight bends; regardless of task duration.
(x) Jackhammers and Use tool with water delivery system that
handheld powered supplies a continuous stream or spray of
chipping tools water at the point of impact.
• When used outdoors. None APF 10
• When used indoors or in an APF 10 APF 10
enclosed area.
OR
Use tool equipped with commercially
available shroud and dust collection system.
Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
Dust collector must provide the air flow
recommended by the tool manufacturer,
or greater, and have a filter with 99% or
greater efficiency and a filter-cleaning
mechanism.
• When used outdoors. None APF 10
• When used indoors or in an APF 10 APF 10
enclosed area.
Jackhammers and handheld powered If using the shroud and dust collection
chipping tools must be operated using either system, the vacuum dust collection
a water delivery system that supplies a system must provide at least the air flow
continuous stream or spray of water at the recommended by the tool manufacturer,
point of impact, or a tool equipped with a and have a filter with 99 percent or greater
commercially available shroud and vacuum efficiency and a filter cleaning mechanism.
dust collection system. Jackhammers and
other handheld powered chipping tools must The water delivery system is not required to
be operated and maintained in accordance be integrated or mounted on the tool; it can
with manufacturer’s instructions to minimize be assembled and installed by the employer.
dust emissions. However, it must deliver a continuous stream
or spray of water at the point of impact.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 17
Full and proper implementation of water Respiratory protection with an APF of 10 is
controls on jackhammers and other handheld required when the task is done outdoors
powered chipping tools requires the for more than four hours per shift, or when
employer to ensure that: the task is done indoors or in an enclosed
location regardless of task duration.
■ An adequate supply of water for dust
suppression is used; When working indoors or in an enclosed
■ The water sprays are working properly space (areas where airborne dust can
and produce a pattern that applies water buildup, such as a structure with a roof
at the point of dust generation; and three walls), employers must provide
■ The spray nozzles are not clogged or additional exhaust, as needed to minimize
damaged; and the accumulation of visible airborne dust. See
■ All hoses and connections are intact. the section on Indoors or Enclosed Areas for
more information.
Acceptable water delivery systems include
direct connections to fixed water lines or
portable water tank systems. These water
delivery systems can be operated by one
worker or could require a second worker to
supply the water at the point of impact.
(xi) Handheld grinders Use grinder equipped with commercially APF 10 APF 25
for mortar removal (i.e., available shroud and dust collection
tuckpointing) system.
Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
Dust collector must provide 25 cubic feet
per minute (cfm) or greater of airflow per
inch of wheel diameter and have a filter
with 99% or greater efficiency and a
cyclonic pre-separator or filter-cleaning
mechanism.
Handheld grinders for mortar removal Full and proper implementation of dust
(i.e., tuckpointing). Tuckpointing involves collection systems on handheld grinders
removing deteriorating mortar from between requires the employer to ensure that:
bricks using a handheld grinder and replacing
it with fresh mortar. ■ The shroud is intact, encloses most of
the grinding blade, and is installed in
The handheld grinders must be equipped accordance with the manufacturer’s
with a commercially available shroud and instructions;
dust collection system and operated and ■ The hose connecting the tool to the
maintained in accordance with manufacturer’s vacuum is intact and without kinks or tight
instructions to minimize dust emissions. The bends;
dust collection system must provide at least ■ The filter(s) on the vacuum are cleaned
25 cfm of air flow per inch of wheel diameter or changed in accordance with the
and have a filter that has a 99 percent or manufacturer’s instructions;
greater efficiency and either a cyclonic pre- ■ The dust collection bags are emptied to
separator or a filter-cleaning mechanism. avoid overfilling;
Cyclonic pre-separators and filter-cleaning ■ The blade is kept flush against the surface
mechanisms improve the suction of dust whenever possible; and
collection systems by preventing debris from ■ The tool is operated against the direction
building up on the filter. of blade rotation, whenever practical.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 19
When using handheld grinders for mortar
removal indoors or in enclosed areas (areas
where airborne dust can buildup, such as
a structure with a roof and three walls),
employers must provide additional exhaust
if needed to minimize the accumulation
of visible airborne dust. See the section
on Indoors or Enclosed Areas for more
information on how to determine when those
work situations apply.
Handheld grinders may also be used for tasks equipped with a commercially available
other than mortar removal, such as to remove shroud and dust collection system with the
thin layers of concrete and surface coatings. same features as the dust collection system
Two control options may be used: (1) A used for mortar removal for outdoor and
grinder equipped with an integrated water indoor work. The dust collector must be rated
delivery system (supplied by the equipment to provide 25 cfm or greater air flow per inch
manufacturer and developed specifically of wheel diameter, have a filter with a 99
for the tool in use) that continuously feeds percent or greater efficiency, and a cyclonic
water to the grinding surface operated for pre-separator or filter-cleaning mechanism.
outdoor work only; and (2) a dust collector Cyclonic pre-separators and filter-cleaning
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 21
mechanisms improve the suction of dust ■ The filter(s) on the vacuum are cleaned
collection systems by preventing debris from or changed in accordance with the
building up on the filter. The grinder and both manufacturer’s instructions; and
controls must be operated and maintained in ■ The dust collection bags are emptied to
accordance with manufacturer’s instructions avoid overfilling.
to minimize dust emissions.
Respiratory protection is not required when
The integrated water delivery system can water-based dust suppression systems are
be a free-flowing water system designed used regardless of task duration. When dust
for blade cooling as well as manufacturers’ collection systems are used, respiratory
systems designed for dust suppression alone. protection with a minimum APF of 10 is
This option applies only when grinders are required only when engaged in a task indoors
used outdoors. or in an enclosed location for more than four
hours per shift.
Full and proper implementation of water
controls on grinders requires the employer When using handheld grinders indoors or in
to ensure that: enclosed areas (areas where airborne dust
can buildup, such as a structure with a roof
■ An adequate supply of water for dust and three walls), employers must provide
suppression is used; additional exhaust as needed to minimize the
■ The spray nozzles are working properly accumulation of visible airborne dust. See
and produce a pattern that applies water the section on Indoors or Enclosed Areas for
at the point of dust generation; more information.
■ The spray nozzles are not clogged or
damaged; and
■ All hoses and connections are intact.
(xiii) Walk-behind milling Use machine equipped with integrated None None
machines and floor water delivery system that continuously
grinders feeds water to the cutting surface.
Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
OR
Use machine equipped with dust collection None None
system recommended by the manufacturer.
Operate and maintain tool in accordance
with manufacturer’s instructions to
minimize dust emissions.
Dust collector must provide the air flow
recommended by the manufacturer, or
greater, and have a filter with 99% or
greater efficiency and a filter-cleaning
mechanism.
When used indoors or in an enclosed area,
use a HEPA-filtered vacuum to remove
loose dust in between passes.
Two control options may be used when water to the cutting surface. Table 1 does not
using walk-behind milling machines and specify a minimum flow rate; however, water
floor grinders. Regardless of control option must be applied at flow rates specified by the
used, the tool must also be operated manufacturer.
and maintained in accordance with
manufacturer’s instructions for minimizing Full and proper implementation of water
dust emissions. controls on walk-behind milling machines
and floor grinders requires the employer to
Option one is to use an integrated water ensure that:
delivery system (supplied by the equipment
manufacturer and developed specifically ■ An adequate supply of water for dust
for the tool in use) that continuously feeds suppression is used;
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 23
■ The spray nozzles are working properly floor grinder to prevent the loose dust from
and produce a pattern that applies water being re-suspended. Removing loose dust
at the point of dust generation; with a HEPA vacuum also maximizes vacuum
■ The spray nozzles are not clogged or suction by improving the seal between the
damaged; and machine and floor. For indoor and enclosed
■ All hoses and connections are intact. spaces, employers must provide additional
ventilation as needed to minimize the
Option two is to use a dust collection system accumulation of visible airborne dust. See
recommended by the manufacturer of the section on Indoors or Enclosed Areas for
the milling machine or floor grinder and a more information.
filter with 99 percent or greater efficiency
and a filter-cleaning mechanism. The dust Respiratory protection is not required for
collection system used must be capable of work with walk-behind milling machines and
maintaining the air flow recommended by the floor grinders regardless of task duration.
manufacturer.
(xiv) Small drivable Use a machine equipped with supplemental None None
milling machines (less water sprays designed to suppress dust.
than half-lane) Water must be combined with a surfactant.
Operate and maintain machine to minimize
dust emissions.
Small drivable milling machines must on Indoors or Enclosed Areas for more
be used with supplemental water sprays information on how to determine when
designed to suppress dust and must be those work situations apply.
operated and maintained to minimize
dust emissions. The water used must be Respiratory protection is not required for work
combined with a surfactant. with small drivable milling machines (less than
half-lane) regardless of task duration.
Full and proper implementation of water
controls on small drivable milling machines
requires the employer to ensure that:
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 25
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
Required Respiratory Protection
and Minimum Assigned
Protection Factor (APF)
Engineering and Work Practice
Equipment/Task Control Methods ≤ 4 hours/shift > 4 hours/shift
Employers whose employees operate large on the drum enclosure and supplemental
(one-half lane or wider) milling machines have water sprays designed to suppress dust;
two control options for cuts of four inches in or (2) use a machine equipped with a
depth or less on any substrate and one control supplemental water spray, combined with a
option for cuts of greater than four inches surfactant, designed to suppress dust.
in depth on asphalt. When using any of the When using the controls specified in Table 1,
control options, the machine must be operated respiratory protection is not required for work
and maintained to minimize dust emissions. with large drivable milling machines (half-lane
When making cuts of greater than four inches or larger) regardless of task duration.
NOTE: Employers making cuts of greater than four inches
on roadway material containing asphalt only, on roadway material that is not asphalt only must follow the
the only control option is to use a machine alternative exposure control methods approach.
equipped with exhaust ventilation on the
drum enclosure and supplemental water
sprays designed to suppress dust.
When making cuts of four inches or less
on any combination of roadway material
(including asphalt and/or concrete), Milling machine milling asphalt road and loading debris into a haul truck.
Photo courtesy of NIOSH. The equipment shown in this picture is for
employers have two control options: (1) use
illustrative purposes only and is not intended as an endorsement by OSHA of
a machine equipped with exhaust ventilation this company, its products or services.
(xvi) Crushing machines Use equipment designed to deliver water None None
spray or mist for dust suppression at crusher
and other points where dust is generated
(e.g., hoppers, conveyers, sieves/sizing or
vibrating components, and discharge points).
Operate and maintain machine in
accordance with manufacturer’s
instructions to minimize dust emissions.
Use a ventilated booth that provides fresh,
climate-controlled air to the operator, or a
remote control station.
When using crushing machines, employers coverage but not so far that the water is
must provide workers with a remote control carried away by wind.
station or ventilated booth that provides
fresh, climate-controlled air to the operator. Respiratory protection is not required for
Water sprays or mists must be used for crusher operators regardless of task duration.
dust suppression at the crusher and other
points where dust is generated (e.g., at
hoppers, conveyors, sieves/sizing or vibrating
components, and discharge points). See
the section on Enclosed Cabs for more
information on how to make sure enclosures
meet the requirements of the rule. Table 1 also
requires that the machine be operated and
maintained according to the manufactures
instructions to minimize dust emissions. Crushing machine being loaded with construction debris by an excavator
Photo courtesy of Screen Machine Industries. The equipment shown
The water spray systems can be installed in this picture is for illustrative purposes only and is not intended as an
so that they can be activated by remote endorsement by OSHA of this company, its products or services.
control. To prevent airborne dust from being
generated, full and proper implementation of Heavy equipment and utility vehicles include
controls requires that: a variety of wheeled or tracked vehicles,
■ Nozzles are located upstream of dust ranging in size from large heavy construction
generation points and positioned to equipment, such as bulldozers, scrapers,
thoroughly wet the material; loaders, cranes and road graders, to smaller
■ The volume and size of droplets is adequate and medium-sized utility vehicles, such as
to sufficiently wet the material (optimal tractors, bobcats and backhoes with attached
droplet size is between 10 and 150 μm); and tools. Table 1 has two entries for heavy
■ Spray nozzles are located far enough from equipment and utility vehicles based on the
the target area to provide complete water types of tasks performed with that equipment.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 27
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
The next Table 1 entry is heavy equipment NOTE: When the operator exits the enclosed
and utility vehicles used to abrade or fracture cab and is no longer actively preforming
silica-containing materials (e.g., hoe-ramming, the task, the operator is considered to have
rock ripping) or used during demolition stopped the task. However, if other abrading,
activities involving silica-containing materials. fracturing, or demolition work is performed
These include activities such as fracturing or by other heavy equipment and utility vehicles
abrading rock and soil; demolishing concrete or in the area while an operator is outside the
masonry structures; and loading, dumping, and cab, that operator is considered to be an
removing demolition debris. employee “engaged in the task” and must be
protected by the application of water and/or
The operator must be in an enclosed cab. dust suppressants.
Modern heavy equipment already comes
equipped with enclosed, filtered cabs that meet
the requirements of Table 1. See the section on
Enclosed Cabs for more information on how to
make sure that the cab meets the requirements
of the rule. When other employees are engaged
in the task, water, dust suppressants, or both
must also be applied as necessary to minimize
dust emissions.
(xviii) Heavy equipment Apply water and/or dust suppressants as None None
and utility vehicles for necessary to minimize dust emissions.
tasks such as grading
OR
and excavating but not
including demolishing, When the equipment operator is the only None None
abrading, or fracturing employee engaged in the task, operate
silica-containing materials equipment from within an enclosed cab.
Heavy equipment and utility vehicles used water and/or dust suppressants as necessary
for tasks such as grading and excavating do to minimize dust emissions: (1) equipment for
not involve demolition or the fracturing or grading and excavating is not equipped with
abrading of silica. Tasks include earthmoving, enclosed, pressurized cabs or (2) employees
grading, and excavating; other activities such other than the operator are engaged in
as moving, loading, and dumping soil and the task. If water or dust suppressants are
rock; and dumping and grading of ballast applied as necessary to minimize visible dust,
in the railroad industry, which is generally the employer need not provide an enclosed,
subject to OSHA’s Construction standards. filtered cab for the operator.
Employers have two control options when the Respiratory protection is not required for
operator is the only employee engaged in the work with heavy equipment when it is
task and one option when employees other operated from within an enclosed cab, or
than the operator are engaged in the task. The when water or other dust suppressants are
first option requires the equipment operator used, regardless of task duration.
to operate the equipment within an enclosed
cab when the operator is the only employee
in the area. Most heavy equipment already
comes equipped with enclosed, filtered
cabs that meet the requirements of Table 1.
See the section on Enclosed Cabs for more
information on how to make sure that the cab
meets the requirements of the rule.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 29
Water Delivery Systems equipment that is designed to effectively
capture dust generated by the tool being
Integrated water delivery systems are
used and does not introduce new hazards
required for several types of equipment in
such as obstructing or interfering with safety
Table 1. Integrated water systems must be
mechanisms.
be supplied by the equipment manufacture
and developed specifically for the tool in use The “commercially available” limitation
so they will apply water at the appropriate is meant only to eliminate on-site
dust emission points based on tool improvisations of equipment by the
configuration and do not interfere with other employer. Employers can use products that
tool components or safety devices. Water are made by aftermarket manufacturers
systems designed for blade cooling also (someone other than the original tool
suppress dust and meet the requirements for manufacturer) that are intended to fit the
Table 1. make and model of the tool. This includes
custom-designed products made to meet
The water must be applied at flow rates
the particular needs and specifications of
sufficient to minimize release of visible
the employer purchasing the product. These
dust. Effective control of the dust depends
systems are designed to work effectively
on factors such as dust particle size, dust
with the equipment and not introduce new
particle velocity, spray nozzle size and
hazards such as obstructing or interfering
location, use of surfactants or other binders,
with safety mechanisms. When employers
and environmental factors (water hardness,
use methods other than commercially
humidity, weather, etc.), all of which must be
available systems for dust suppression, they
considered when using wet methods. The
must conduct exposure assessments and
appropriate water flow rates for controlling
comply with the PEL.
silica dust emissions can vary; therefore,
it is necessary to follow manufacturers’ Some Table 1 entries for dust collection
instructions when determining the required systems specify use of cyclonic pre-
flow rate for dust suppression systems on a separators and filter cleaning mechanisms to
given worksite. prevent buildup of debris on filters that result
in less dust capture. A cyclonic pre-separator
Any slurry generated when using water to
collects large debris before the air reaches
suppress dust should be cleaned up to limit
the filters. A filter cleaning mechanism
secondary exposure to silica dust when the
prevents the need for manually cleaning
slurry dries following procedures described in
filters to prevent buildup of debris (caking).
the employer’s Written Exposure Control Plan.
Some vacuums are equipped with a gauge
When working in cold temperatures, where indicating filter pressure or an equivalent
there is a risk of water freezing, additional device (e.g., timer to periodically pulse the
work practices such as insulating drums, filter) to help employees in determining when
wrapping drums with gutter heat tape or it is time to run a filter cleaning cycle.
adding environmentally-friendly antifreeze
additives to water may be needed. Indoors or Enclosed Areas
Several Table 1 entries refer to tasks
Dust Collection Systems performed “outdoors” or “indoors or in an
Commercially available dust collection enclosed area.” Indoors or in an enclosed
systems (i.e., LEV) are required for several areas mean areas where airborne dust can
types of equipment in Table 1. This build up unless additional exhaust is used.
requirement ensures that employers use For example, a work area with only a roof
Sufficient air circulation in enclosed or indoor The procedures for maintaining and cleaning
environments is important to ensure the the cab or booth, and for frequent and regular
effectiveness of the control strategies and to inspections of the cabs and booths, must be
prevent the accumulation of airborne dust. addressed through the employer’s Written
Employers following Table 1 are required Exposure Control Plan and Competent Person
to provide a means of exhaust as needed requirements described below.
to minimize the accumulation of visible
airborne dust for tasks performed indoors Determining Task Duration and
or in enclosed areas. The means of exhaust Requirements for Respirator Use
necessary could include: the use of portable Respirator requirements in Table 1 are
fans (box fans, floor fans, axial fans), portable divided by task duration:
ventilation systems, or other systems that
increase air movement and assist in the ■ “Less than or equal to four hours/shift” and,
removal and dispersion of airborne dust. To ■ “Greater than four hours/shift”.
be effective, the ventilation must be set up so
that movements of employees during work, Each of the following scenarios is considered
or the opening of doors and windows, will a “shift” for purposes of determining the
not negatively affect the airflow. maximum amount of time that an employee
may spend on Table 1 tasks without
Enclosed Cabs respiratory protection:
Enclosed cabs or booths are specified for ■ A standard 8-hour work period;
rock drilling, crushers, and heavy equipment. ■ A day with a break between work periods
Employers must ensure that the enclosed cab (e.g., four hours on, two hours off, four
or booth is: hours on);
■ Work periods longer than eight hours;
■ Maintained as free as practicable from ■ Double shifts within a single day;
settled dust; ■ A work period spanning two calendar days
■ Has door seals and closing mechanisms (e.g., 8 p.m. until 4 a.m.).
that work properly;
■ Has gaskets and seals that are in good Task duration time starts when the
condition and work properly; operator begins using the tool, and
■ Is under positive pressure maintained continues to be counted until he or she
through continuous delivery of filtered air; completes the task. This time includes
■ Has intake air that is filtered through a pre- intermittent breaks in tool usage and clean-
filter that is 95% efficient in the 0.3-10.0 up. However, tasks that are performed
µm range (e.g., MERV-16 or better); and multiple times per day, during distinct time
■ Has heating and cooling capabilities. periods, should be counted as separate
tasks, and times should be combined.
The controls for enclosed cabs lower the
potential for dust to be re-suspended inside The requirement to provide respirators is
the cab or enter the enclosed cab or booth. based on the anticipated duration of the task.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 31
Employers must make a good-faith judgment Where an employee performs more than one
of the task’s anticipated duration over the work task in Table 1 during the course of a shift,
shift, whether performed continuously or and the total duration of all tasks combined
intermittently, based on previous experience is less than four hours, the required
and all other available information. respiratory protection for each task is the
respiratory protection specified in the less
than four hours per shift column. If the total
Examples of Determining Task Durations duration of all Table 1 tasks combined is
1. Tasks with intermittent breaks. An more than four hours per shift, the required
employee cuts and places bricks, one at a respiratory protection for each task is the
time, for four hours consecutively and then respiratory protection specified in the more
spends 30 minutes cleaning up the saw and than four hours per shift column. As was
emptying slurry or dust collectors. All four discussed for single tasks, if multiple tasks
hours spent cutting and laying bricks along are estimated to last less than 4 hours, but
with the 30 minutes for clean-up count for a it becomes evident that the tasks will take
total task duration of four and a half hours. more than four hours total, the employer
must reexamine respiratory protection
2. Tasks with distinct time periods. An
requirements and immediately provide a
employee cuts multiple bricks for 15 minutes,
respirator, when required.
lays bricks for two hours before returning to
cut more bricks for another 30 minutes. The
total task duration is 45 minutes
Examples of Respiratory Protection
Requirements for Single Tasks in Table 1
If an employer estimates that an employee
will perform a single task for four hours or 1. An employer anticipates that it will take
less during a single shift, then the employer an employee 3 hours to cut concrete walls
must ensure that the employee uses using a handheld power saw (outdoors). No
whichever respirator, if any, is specified in respiratory protection is required.
the “≤ 4 hr/shift” column in Table 1. If an 2. An employer anticipates that it will take an
employer estimates that the task will take employee 5 hours to demolish an asphalt
more than four hours, then the employer road using a jackhammer (outdoors). The
must ensure that the employee uses any employer must provide a respirator with
respiratory protection specified in the “> 4 hr/ an APF of 10 and ensure that the employee
shift” column in Table 1, during the entire wears it for the entire duration of the task.
task, not just during the time beyond the first
3. An employer anticipates that it will take an
four hours that the task is performed.
employee 3 hours to grind a concrete floor
If an employer anticipates that a task will take (indoors) and, therefore, determines that
four hours or less, but unforeseen difficulties respiratory protection is not required under
will extend the task duration beyond four Table 1. However, at two hours, the employer
hours, the employer is required to provide the determines that it will take more than 4 hours
listed respiratory protection as soon as it to complete the task. The employer must
becomes evident that the duration of the task provide a respirator with an APF of 10 at that
may exceed the 4-hour limit, measured from time and ensure that the employee wears it
the beginning of the task. for the remaining duration of the task.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 33
ALTERNATIVE EXPOSURE CONTROL METHODS –
PARAGRAPH (D) OF THE STANDARD
Employers that conduct tasks not listed in where exposures are occurring; helping the
Table 1 or do not fully and properly implement employer select control methods and make
the engineering controls, work practices, and sure those methods are effective; preventing
respiratory protection described in Table 1 employees from being exposed above the
of the specified exposure control methods PEL; providing employees with information
approach must follow the alternative exposure about their exposure levels; and allowing the
control methods approach. The alternative employer to give the PLHCP performing
exposure control methods approach involves medical examinations information about
assessing employee exposure to respirable employee exposures.
crystalline silica, and limiting exposure to
the PEL using feasible engineering and work
practice control methods, and respiratory Calculation of TWA Exposures
protection when necessary. Each of the three
Both the PEL and the action level are expressed
components of alternative exposure control
as TWA exposures. TWA measurements
methods – the PEL, exposure assessment, and
account for variable exposure levels over the
methods of compliance – is explained below.
course of a work shift by averaging periods of
Permissible Exposure Limit (PEL) higher and lower exposures. The TWA exposure
for an 8-hour work shift is calculated using a
Employers complying with the alternative simple formula:
exposure control methods must ensure that
their employees’ exposures to respirable TWA = (Ca Ta + Cb Tb . . . Cn Tn) ÷ 8
crystalline silica do not exceed the PEL, which Where:
is 50 µg/m3 as an 8-hour TWA. This means
that over the course of any 8-hour work shift, TWA is the time-weighted average exposure
exposures can fluctuate, but the average for the work shift
exposure to respirable crystalline silica cannot C is the concentration during any period of time (T)
exceed 50 μg/m3. The PEL applies to the three where the concentration remains constant; and
forms of respirable crystalline silica that are
covered by the standard: quartz, cristobalite, T is the duration in hours of the exposure at the
and trydimite. Quartz is by far the most concentration (C)
common form of crystalline silica found at For example, assume that an employee is
construction workplaces, and in most cases, exposed to respirable crystalline silica in an
quartz will be the only form of respirable 8-hour workday as follows:
crystalline silica analyzed in air samples used
to measure employee exposures. Two hours exposure at 100 µg/m3
Two hours exposure at 50 µg/m3
Exposure Assessment Four hours exposure at 10 µg/m3
Construction employers following alternative Entering this information in the formula, we get:
exposure control methods must assess the
(2 x 100 + 2 x 50 + 4 x 10) ÷ 8 = 42.5 µg/m3
8-hour TWA exposure for each employee
who is or may reasonably be expected to be Because 42.5 µg/m3 is higher than 25 µg/m3,
exposed to respirable crystalline silica at or this employee’s TWA exposure would be above
above the action level of 25 µg/m3 as an the action level, but below the PEL of 50 µg/m3.
8-hour TWA. The purposes of assessing
employee exposures include: identifying
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 35
The performance option may be especially OSHA intends for employers using the
useful when measuring employee exposures scheduled monitoring option to conduct
is challenging, such as when tasks are initial monitoring as soon as work begins so
conducted for short durations of time or that they are aware of exposure levels and
performed under different weather conditions. where control measures are needed.
The performance option gives employers Under the scheduled monitoring option, just
flexibility for characterizing the exposures as under the performance option, employers
of all employees. For example, instead must correctly characterize each employee’s
of conducting air monitoring on two exposure to respirable crystalline silica.
employees who perform the same job
on different shifts, the employer could Exposure monitoring must include, at a
determine that there are no differences in minimum, one full-shift sample taken for each
exposure between those two employees, job function in each job classification, in each
and characterize the exposure of the second work area, and on each shift. Characterizing
employee based on the air monitoring each employee’s exposure may involve
results of the first employee. monitoring all exposed employees or a smaller
number of employees whose exposures can
Under the performance option, employers then represent those of other employees.
can characterize employee exposure within
a range to account for exposure variability. Representative sampling involves monitoring
Employers can also use that option to the employee or employees reasonably
show that exposures exceed the PEL by a expected to have the highest exposure to
certain level, such as less than 10 times the respirable crystalline silica (for example, the
PEL, after using all feasible controls. The employee closest to an exposure source).
employer would then know that he or she This exposure is then assigned to the other
must provide respiratory protection with employees in the group who perform the
an APF of at least 10, as well as medical same tasks on the same shift and in the same
surveillance for employees required to wear work area.
a respirator under the silica standard for Representative monitoring is allowed when
30 or more days per year. several employees perform the same job on
Scheduled Monitoring Option. The scheduled the same shift and under the same conditions.
monitoring option lets employers know when How Often Employers Must Monitor under
and how often they must perform exposure the Scheduled Monitoring Option. Under the
monitoring to measure employee exposures. scheduled monitoring option, how often
When following the scheduled monitoring monitoring must be done depends on the
option, employers must make sure that: results of initial monitoring and, thereafter,
■ Results represent the employee’s TWA any required further monitoring, as follows:
exposure to respirable crystalline silica ■ If the initial monitoring indicates that
over an eight-hour workday; employee exposures are below the action
■ Samples are collected from the level, no further monitoring is required.
employee’s breathing zone; and ■ If the most recent exposure monitoring
■ Samples are collected outside respirators so reveals employee exposures at or above
that they represent the exposure that would the action level but at or below the PEL, the
occur without the use of the respirator. employer must repeat monitoring within
six months of the most recent monitoring.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 37
controls, respiratory protection is the Engineering and Work Practice Controls.
corrective action that would be described in Employers must use engineering and
the written notification. work practice controls to reduce and keep
employee exposure to respirable crystalline
Observation of Monitoring. The employer silica to or below the PEL of 50 µg/m3,
must let affected employees or their unless the employer can demonstrate that
designated representatives observe any such controls are not feasible. If feasible
air monitoring of employee exposure engineering and work practice controls are
to respirable crystalline silica. When not able to reduce employee exposures to
observation of monitoring requires entry into or below the PEL, employers must still use
an area where use of protective clothing or feasible controls to reduce exposures to the
equipment, such as a respirator, is required, lowest possible level and then use respiratory
the employer must provide the observer protection along with those controls.
with that protective clothing or equipment.
The employer must provide the protective The main types of engineering controls for
clothing and equipment at no cost, and silica are wet methods and local exhaust
make sure that the observer uses such ventilation. Wet methods involve applying
clothing or equipment. water or foam at the point of dust generation
to keep dust from getting into the air. An
However, if the observer does not need to example is an integrated water delivery
enter an area requiring the use of protective system on a stationary masonry saw.
clothing or equipment in order to effectively Local exhaust ventilation removes dust by
observe monitoring (for example, if capturing it at or near the point where it is
monitoring can be viewed from outside the created. An example is a dust collector for a
hazardous areas), no protective clothing or handheld grinder.
equipment would be needed.
Another engineering control is isolation.
Methods of Compliance Isolation separates employees from the dust
Employers following alternative exposure source by containing the dust or isolating
control methods must comply with the employees. An example is a properly
methods of compliance requirements of ventilated cab on heavy equipment.
the standard. The methods of compliance Work practice controls involve performing a
section of the standard requires employers task in a way that reduces the likelihood or
to protect employees following the hierarchy levels of exposure. Work practice controls
of controls, which relies on engineering are often used with engineering controls
and work practice controls for reducing to protect employees. Employees must
exposures and allows for respirator use, know the appropriate work practices for
in addition to those controls, only when maximizing the effectiveness of controls and
feasible engineering controls cannot minimizing exposures. Examples of work
reduce exposures to acceptable levels. The practice controls include:
methods of compliance section also cross-
references other OSHA standards that apply ■ Inspecting and maintaining controls to
to abrasive blasting. prevent or fix malfunctions that would
result in increased exposures;
■ Making sure that nozzles spray water
at the point of dust generation for wet
method controls;
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 39
RESPIRATORY PROTECTION – PARAGRAPH (E)
OF THE STANDARD
Employers must provide employees with used in the workplace and are effective
appropriate respirators where required by the in protecting employees. See the Small
silica standard. The respirators must comply Entity Compliance Guide for the Respiratory
with requirements of the silica standard and Protection Standard for information on the
with OSHA’s Respiratory Protection standard requirements of that standard.
(29 CFR 1910.134).
If an employer following the specified
Employers who follow the specified exposure exposure control methods fully and properly
control methods listed in Table 1 must implements the engineering controls, work
provide respiratory protection where required practices, and respiratory protection required
by Table 1. Employers who follow alternative in Table 1, the employer will be considered to
exposure control methods must provide be in compliance with the requirements of the
respiratory protection: silica standard and the respiratory protection
standard for identifying and evaluating
■ Where exposures exceed the PEL during respiratory hazards and providing each
periods necessary to install or implement employee with an appropriate respirator.
feasible engineering and work practice
controls; Employers following Table 1 must comply
■ Where exposures exceed the PEL during with all other requirements of the Respiratory
tasks, such as some maintenance and Protection standard.
repair tasks, for which engineering and
work practice controls are not feasible;
■ During tasks in which the employer has Voluntary Use of Respirators
implemented all feasible engineering Employers may provide respirators at the
and work practice controls but exposures request of employees or let employees use
remain above the PEL. their own respirators when respirators
Where respirator use is required, employers are not required under the silica standard.
must implement a respiratory protection See the Small Entity Compliance Guide for
program in accordance with the respiratory the Respiratory Protection Standard for
protection standard. The respiratory protection information about employer responsibilities
program ensures that respirators are properly when employees voluntarily wear respirators.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 41
WRITTEN EXPOSURE CONTROL PLAN – PARAGRAPH (G)
OF THE STANDARD
All employers covered by the standard,
including employers who fully and properly Example: Cutting bricks using a stationary
implement the specified exposure controls masonry saw outdoors.
in Table 1, must develop and implement
a written exposure control plan. Written The plan must include a description of
exposure control plans describe workplace engineering controls, work practices, and
exposures and ways to reduce those respiratory protection used to limit employee
exposures, such as engineering controls, exposure to respirable crystalline silica for
work practices, housekeeping methods, each task. For each task that employees
and restricting access to areas where perform, employers must describe types
high exposures occur. The plans improve of controls used, like a dust collector with
employee protections by making sure that manufacturer’s recommended air flow and
employers identify all exposures and controls a filter with 99 percent efficiency, effective
to prevent overexposures. Such plans are work practices, as in checking that water
also useful for letting employees know what nozzles are not plugged, and if required,
kind of protections they should expect to see appropriate respiratory protection, like a
on the job. respirator with an APF of 10. Employers could
also describe signs that controls are not
What Must be Included in a Written working effectively, such as an increase in
Exposure Control Plan visible dust or no water being delivered to the
Below is a list of what the employer must saw blade.
include in each section of the written
This section of the written exposure control
exposure control plan, with general examples
plan is especially important for construction
of the types of information that could be
employers who use controls in Table 1,
included and sample entries for the use of a
because they are not required to measure
stationary masonry saws for cutting bricks.
exposures to make sure that controls are
The plan must include a description of working. Therefore, including information
workplace tasks involving exposures to such as manufacturer’s instructions for
respirable crystalline silica. Employers must operating and maintaining tools to decrease
list all tasks that employees perform that dust, when possible, demonstrates that the
could expose them to respirable crystalline employer has a complete understanding
silica dust. This section could also describe of those instructions and is using them to
the equipment used and factors that affect control dust. Describing those instructions in
exposures, such as types of silica-containing the written exposure control plans also lets
materials handled in those tasks (concrete or employees know what the employer needs to
tile), weather conditions (wind or humidity), do to protect them.
soil types (clay versus rock), and if tasks
are done outdoors versus indoors or in
enclosed locations.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 43
access when employees are engaged in tasks Availability of the Written Exposure
that require respirator use under Table 1. For Control Plan
example, if an employer following Table 1
Employers must allow the written exposure
has an employee who is jackhammering for
control plan to be viewed or copied by
more than four hours and is therefore wearing
each employee covered by the standard,
a respirator, the employer or the competent
their designated representative, and
person must make sure that an employee
representatives from OSHA or NIOSH,
directing traffic (not engaged in the task),
upon request. Making the written exposure
is positioned away and upwind from the
control plan available to employees and
employee who is jackhammering.
their designated representatives empowers
The employer or competent person must also and protects employees by letting them
restrict access, when needed, for exposures and their representatives know the silica
generated by another employer or self- hazards the employer identified and controls
employed person. Such a situation might for those hazards. This allows employees
occur if the other employer of self-employed and representatives to question employers
person is conducting a task that generates if controls are not fully and properly
clearly visible dust. implemented or maintained. Likewise,
making written exposure control plans
readily available to OSHA or NIOSH allows
Example: When the controls on a stationary them to verify that employee protections
masonry saw are fully and properly are effective. If OSHA inspects a workplace,
implemented, access does not need to be the OSHA Compliance Safety and Health
restricted to decrease other employees’ Officer will ask to see the employer’s written
exposure to respirable crystalline silica. exposure control plan.
The competent person can use traffic cones
or barrier tape to restrict access if needed for Sample Written Exposure
other reasons such as safety concerns. Control Plans
To help employers develop written exposure
control plans, a sample plan is included below.
Yearly Review of Written Exposure This sample shows an easy-to-use format that
Control Plans can be changed to address the specific tasks
performed by each employee. The sample
The respirable crystalline silica standard
plan meets the requirements of the standard
requires employers to review and evaluate
and contains the level of detail that OSHA
the effectiveness of the written exposure
considers useful for employers in helping
control plan at least once a year and update
them protect their employees. As the sample
it as necessary. A yearly review is needed
shows, the plan can contain useful information
to make sure that all information in the plan
without being long or complicated.
is up-to-date. For example, the employer
might have bought a new type of equipment
or asked employees to conduct a new task
involving exposure, and that information
needs to be described in the written plan.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 45
Sample Written Exposure Control Plan
Description of Task:
Demolishing concrete and tile floors inside homes or public buildings using a jackhammer.
Control Description
Controls:
• Use jackhammer equipped with the appropriate, commercially available shroud and a vacuum
dust collection system with the flow rate recommended by the jackhammer manufacturer, a filter
that is at least 99 percent efficient, and a filter cleaning mechanism.
• Use a portable fan to exhaust air and prevent the buildup of dust.
Work practices:
• Check shrouds and hoses to make sure they are not damaged before starting work.
• Make sure the hoses do not become kinked or bent while working.
• Use switch on vacuum to activate filter cleaning at the frequency recommended by the manufacturer.
• Replace vacuum bags as needed to prevent overfilling.
• Use the jackhammer and vacuum controls according to manufacturer’s instructions for reducing
the release of visible dust.
• If visible dust increases, check controls and adjust as needed.
Respiratory protection:
• Use respirator with APF of 10 the entire time the task is being performed.
• See the written respiratory protection program for information on selection, training and fit
testing requirements, in addition to proper use instructions for respirators (for example, being
clean shaven when using a respirator that seals against the face).
Housekeeping:
• Dust containing silica on work surfaces and equipment must be cleaned up using wet methods or
a HEPA-filtered vacuum.
• Do not use compressed air or dry sweeping for removing dust and debris containing silica from
work surfaces.
• Dispose of used vacuum bags in a container and keep the container sealed.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 47
MEDICAL SURVEILLANCE – PARAGRAPH (H)
OF THE STANDARD
Medical surveillance is intended to: An employer will be able to estimate how often
(1) identify respirable crystalline silica-related respirator use will be required by the standard
diseases so that employees with those in the upcoming year based on the types of
diseases can take actions to protect their tasks that the employee will perform, as well
health; (2) determine if an employee has any as how long and how often those tasks are
condition, such as a lung disease, that might performed. Respirator use with past employers
make him or her more sensitive to respirable does not count toward the 30-day threshold.
crystalline silica exposure; and (3) determine
the employee’s fitness to use respirators. When unexpected circumstances result in
employees being required to wear respirators
The standard specifies which employees more frequently than first expected,
must be offered medical surveillance, when employers must make medical surveillance
and how often the examinations must available as soon as it becomes apparent that
offered, and the tests that make up medical the employee will be required by the silica
examinations. The standard also specifies standard to wear a respirator for 30 or more
the information that the employer must give days in the upcoming year.
to the physician or other licensed health
care professional (PLHCP) who conducts Frequency of Medical Examinations
the examinations and the information that Employers must offer medical examinations:
the employer must ensure that the PLHCP
provides to the employee and employer. ■ Within 30 days of initial assignment (the
day the employee starts working in a job/
All medical examinations and procedures task in which he or she will be required
required by the standard must be performed by the silica standard to wear a respirator
by a PLHCP. Medical surveillance must for 30 or more days per year), unless
be provided at no cost to employees, and the employee has had an examination
at a reasonable time and place. If getting that meets the requirements of the silica
the medical examination requires the standard within the last three years.
employee to travel away from the worksite, ■ Every three years from the employee’s last
the employer is required to cover the cost examination that met the requirements
of travel. The employer must also pay of the silica standard, or more frequently
employees for time spent traveling and taking if recommended by the PLHCP, if the
medical examinations. employee will continue to perform tasks
that require respirator use under the silica
Which Employees Must be Offered
standard for 30 or more days per year.
Medical Surveillance
Employers must make an initial or periodic A PLHCP might recommend more frequent
medical examination available to employees medical examinations based on factors such
who will be required by the silica standard to as high exposure levels or a medical finding
wear a respirator for 30 or more days per year such as an X-ray suggesting silicosis.
in the upcoming year (the next 365 days). If Employers must make sure that employees
the employee is required to wear a respirator receive a dated copy of the PLHCP’s written
at any time during a day, that counts as one medical opinion for the employer, and the
day of respirator use. employee can present that opinion to a
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 49
abnormal lung function. The standard gives The PLHCP’s Written Medical
the PLHCP the flexibility to order additional Report for the Employee
tests he or she deems appropriate. Employers
The employer must ensure that the
must make those tests ordered by the PLHCP
PLHCP explains the results of the medical
available to the employee.
examination to the employee and gives
the employee a written medical report
Information the Employer Must Provide to
within 30 days of each medical examination
the PLHCP
performed. Only the employee receives the
The employer must ensure that the written medical report, and the employer
examining PLHCP has a copy of the standard does not receive a copy of this report. The
and must provide the PLHCP with: report must contain:
■ A description of the employee’s past, ■ A description of the medical examination
current, and future duties as they relate to results, including any medical condition(s)
respirable crystalline silica exposure; that would place the employee at
■ The employee’s past, current, and future increased risk of material impairment
levels of exposure to respirable crystalline of health from exposure to respirable
silica (if the employer does not have crystalline silica (any health condition
information on the employee’s past or that might make the employee more
current exposure level because they are sensitive to exposure). The report must
following Table 1 and are not required to also describe any medical conditions that
measure exposures, the employer can require further evaluation or treatment;
indicate if the employee is likely exposed ■ Any recommended limitations on the
at or above the PEL, based on required employee’s use of respirators;
respirator use under Table 1); ■ Any recommended limitations on
■ A description of any personal protective respirable crystalline silica exposure; and
equipment used, or to be used, by the ■ A statement that the employee should be
employee, including when and for how examined by a specialist if the B-reader
long the employee has used or will use classifies the chest X-ray provided
that equipment; and under the silica standard as 1/0 or higher
■ Information from records of employment- (X-ray evidence of silicosis in employees
related medical examinations previously exposed to respirable crystalline silica),
provided to the employee and currently or if the PLHCP otherwise recommends
within the control of the employer. referral to a specialist.
The PLHCP needs this information to evaluate
The PLHCP’s Written Medical
the employee’s health in relation to assigned Opinion for the Employer
duties and fitness to use personal protective
equipment, such as respirators. The The employer must get a written medical
information provided to the PLHCP includes opinion from the PLHCP within 30 days of the
only that within the control of the employer; medical examination. The written opinion
the employer is not required to obtain must contain only the following information:
information from past employers.
■ The date of the examination;
■ A statement that the examination has
met the requirements of the silica
standard; and
■ Any recommended limitations on the
employee’s use of respirators.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 51
Small Entity Compliance Guide– Construction
Draft – Do not Quote or Cite 9/7/2016
Sample Form 1:
SAMPLE FORM 1: Written
WRITTEN Medical ReportFOR
MEDICAL REPORT forEMPLOYEE
Employee
EMPLOYEE NAME: Joe Smith DATE OF EXAMINATION: June 1, 2017
TYPE OF EXAMINATION:
[x] Initial examination [ ] Periodic examination [ ] Specialist examination
[ ] Other: _______________________________________________________________________________________
[x] Your health may be at increased risk from exposure to respirable crystalline silica due to the following:
Continued unprotected exposure to respirable crystalline silica may further damage your lungs.
RECOMMENDATIONS:
[ ] No limitations on respirator use
[x] Recommended limitations on use of respirator: A powered air purifying respirator (PAPR) is the only type of
respirator you can safely wear. A PAPR will give you higher protection from silica exposure and will decrease strain on
your heart and lungs.
[x] Recommended limitations on exposure to respirable crystalline silica: Ideally, you may want to consider a position
that doesn’t involve exposure to substances hazardous to your lungs, such as respirable crystalline silica. If that is not
possible, be sure to always wear a respirator when needed to protect your lungs.
Dates for recommended limitations, if applicable: Indefinitely unless otherwise indicated by a specialist.
[x] I recommend that you be examined by a Board Certified Specialist in Pulmonary Disease or Occupational Medicine
[x] Other recommendations*: See your personal physician about the mole on your neck
__________________________________________________________________________________________________
Your next periodic examination for silica exposure should be in: [ ] 3 years [x] Other: 1 year, June 1, 2018
*These findings may not be related to respirable crystalline silica exposure or may not be work-related, and therefore
may not be covered by the employer. These findings may necessitate follow-up and treatment by your personal
physician.
TYPE OF EXAMINATION:
[x] Initial examination [ ] Periodic examination [ ] Specialist examination
[ ] Other: _______________________________________________________________________________________
USE OF RESPIRATOR:
[ ] No limitations on respirator use
[x] Recommended limitations on use of respirator: A powered air purifying respirator (PAPR) is the only type of
respirator Mr. Smith can safely wear.
Dates for recommended limitations, if applicable: Indefinitely, unless otherwise recommended by specialist
The employee has provided written authorization for disclosure of the following to the employer (if applicable):
[x] This employee should be examined by an American Board Certified Specialist in Pulmonary Disease or Occupational
Medicine
[ ] Recommended limitations on exposure to respirable crystalline silica:_______________________________________
__________________________________________________________________________________________________
Office Address: _1111 Main Street, Washington, DC________ Office Phone: _123-456-7890_____________
[x] I attest that the results have been explained to the employee.
The following is required to be checked by the Physician or other Licensed Health Care Professional (PLHCP):
[x] I attest that this medical examination has met the requirements of the medical surveillance section of the OSHA
Respirable Crystalline Silica standard (§ 1910.1053(h) or 1926.1153(h)).
76
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 53
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This medical examination for exposure to crystalline silica could reveal a medical condition that results in
recommendations for (1) limitations on respirator use, (2) limitations on exposure to crystalline silica, or (3)
examination by a specialist in pulmonary disease or occupational medicine. Recommended limitations on
respirator use will be included in the written opinion to the employer. If you want your employer to know about
limitations on crystalline silica exposure or recommendations for a specialist examination, you will need to give
authorization for the written opinion to the employer to include one or both of those recommendations.
I hereby authorize the opinion to the employer to contain the following information, if relevant
(please check all that apply):
X
Recommendation for a specialist examination
OR
I do not authorize the opinion to the employer to contain anything other than recommended limitations on
respirator use.
X I understand that if I do not authorize my employer to receive the recommendation for specialist
examination, the employer will not be responsible for arranging and covering costs of a specialist
examination under the OSHA standard for respirable crystalline silica.
Joe Smith
Name (printed)
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SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 55
COMMUNICATION OF HAZARDS – PARAGRAPH (I)
OF THE STANDARD
Employers must train and inform limit their exposures to those hazards.
employees covered by the silica standard Employers must cover the cost of training
about respirable crystalline silica hazards and must pay employees for the time spent
and the methods the employer uses to in training.
See OSHA’s HAZARD COMMUNICATION: Small Entity Compliance Guide for Employers that Use
Hazardous Chemicals [OSHA Publication #3695] for more information on preparing a written hazard
communication program and employer requirements for labeling, SDSs, and training.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 57
Additional training must be provided as often This may mean, for example, providing
as necessary to ensure that employees know materials, instruction, or assistance in
and understand respirable crystalline silica Spanish rather than English for Spanish-
hazards and the protections available in their speaking employees who do not understand
workplace. Examples of when additional English, and using methods other than
training would be required include: printed reading materials if the employee is
not able to read.
■ When the employer asks an employee to
perform a task that is new to that employee; To ensure that employees understand the
■ When the employer introduces new material presented during training, it is
protections (for example, an employer critical that trainees have the opportunity
who was having employees use a to ask questions and receive answers if
handheld grinder with wet method they do not fully understand the material
controls decides to have employees use that is presented to them. When videotape
a handheld grinder with a dust collection presentations or computer-based programs
system); or are used, this requirement may be met by
■ When an employee is working in a manner having a qualified trainer available to address
that suggests he or she has forgotten what questions after the presentation, or providing
was learned in training. a telephone hotline so that trainees will have
direct access to a qualified trainer.
Training Methods
Employers can determine if employees know
The silica standard does not require the and understand the training topics through
employer to use any particular method discussion of the required training subjects,
for training employees. Employers could written tests, or oral quizzes.
use hands-on training, videotapes, slide
presentations, classroom instruction, Making a Copy of the Standard
informal discussions during safety meetings, Available
written materials, or any combination of
these methods to train employees. Employers must make a copy of the
respirable crystalline silica standard available
In order for employees to demonstrate at no cost to each employee covered by the
knowledge and understanding of the training standard. This could simply involve allowing
subjects, training must be done in a manner employees to view a printed or electronic
and language that employees understand. copy in a reasonable location.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 59
OSHA’s Access to Employee Exposure and Medical Records Regulation
A separate OSHA regulation (29 CFR 1910.1020, Access to Employee Exposure and Medical Records)
addresses requirements for maintaining exposure and medical records. In general, exposure records
(including air monitoring and objective data) must be kept for at least 30 years, and medical records must
be kept for at least the duration of employment plus 30 years. It is necessary to keep these records for
extended periods because silica-related diseases such as cancer often cannot be detected until several
decades after exposure. However, if an employee works for an employer for less than one year, the
employer does not have to keep the medical records after employment ends, as long as the employer
gives those records to the employee.
Director means the Director of the National Respirable crystalline silica means quartz,
Institute for Occupational Safety and Health cristobalite, and/or tridymite contained
(NIOSH), U.S. Department of Health and in airborne particles that are determined
Human Services, or designee. to be respirable by a sampling device
designed to meet the characteristics for
Competent person means an individual who is respirable-particle-size-selective samplers
capable of identifying existing and foreseeable specified in the International Organization
respirable crystalline silica hazards in the for Standardization (ISO) 7708:1995: Air
workplace and who has authorization to take Quality – Particle Size Fraction Definitions
prompt corrective measures to eliminate or for Health-Related Sampling.
minimize them. The competent person must
have the knowledge and ability necessary to Specialist means an American Board
fulfill the responsibilities set forth in paragraph Certified Specialist in Pulmonary Disease
(g) of this section. or an American Board Certified Specialist in
Occupational Medicine.
Employee exposure means the exposure
to airborne respirable crystalline silica that This section means this respirable crystalline
would occur if the employee were not using silica standard, 29 CFR 1926.1153.
a respirator.
(c) Specified exposure control methods. (1) For
High-efficiency particulate air [HEPA] filter each employee engaged in a task identified
means a filter that is at least 99.97 percent on Table 1, the employer shall fully and
efficient in removing mono-dispersed properly implement the engineering controls,
particles of 0.3 micrometers in diameter. work practices, and respiratory protection
specified for the task in Table 1, unless the
Objective data means information, such employer assesses and limits the exposure of
as air monitoring data from industry- the employee to respirable crystalline silica in
wide surveys or calculations based on the accordance with paragraph (d) of this section.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 61
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
(i) Stationary Use saw equipped with integrated water delivery None None
masonry saws system that continuously feeds water to the blade.
Operate and maintain tool in accordance
with manufacturer’s instructions to minimize
dust emissions.
(ii) Handheld power Use saw equipped with integrated water delivery
saws (any blade system that continuously feeds water to the blade.
diameter)
Operate and maintain tool in accordance
with manufacturer’s instructions to minimize dust
emissions.
• When used outdoors. None APF 10
• When used indoors or in an enclosed area. APF 10 APF 10
(iv) Walk-behind saws Use saw equipped with integrated water delivery
system that continuously feeds water to the blade.
Operate and maintain tool in accordance
with manufacturer’s instructions to minimize dust
emissions.
• When used outdoors. None None
• When used indoors or in an enclosed area. APF 10 APF 10
(vi) Rig-mounted core Use tool equipped with integrated water delivery
saws or drills system that supplies water to cutting surface.
Operate and maintain tool in accordance None None
with manufacturer’s instructions to minimize dust
emissions.
(vii) Handheld and Use drill equipped with commercially available None None
stand-mounted shroud or cowling with dust collection system.
drills (including
Operate and maintain tool in accordance
impact and rotary
with manufacturer’s instructions to minimize
hammer drills)
dust emissions.
Dust collector must provide the air flow
recommended by the tool manufacturer, or
greater, and have a filter with 99% or greater
efficiency and a filter-cleaning mechanism.
Use a HEPA-filtered vacuum when cleaning holes.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 63
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
(ix) Vehicle-mounted Use dust collection system with close capture None None
drilling rigs for rock hood or shroud around drill bit with a low-flow
and concrete water spray to wet the dust at the discharge point
from the dust collector.
OR
Operate from within an enclosed cab and use None None
water for dust suppression on drill bit.
(x) Jackhammers and Use tool with water delivery system that supplies
handheld powered a continuous stream or spray of water at the point
chipping tools of impact.
• When used outdoors. None APF 10
• When used indoors or in an enclosed area. APF 10 APF 10
OR
Use tool equipped with commercially available
shroud and dust collection system.
Operate and maintain tool in accordance
with manufacturer’s instructions to minimize dust
emissions.
Dust collector must provide the air flow
recommended by the tool manufacturer, or
greater, and have a filter with 99% or greater
efficiency and a filter-cleaning mechanism.
• When used outdoors. None APF 10
• When used indoors or in an enclosed area. APF 10 APF 10
(xi) Handheld Use grinder equipped with commercially available APF 10 APF 25
grinders for mortar shroud and dust collection system.
removal (i.e.,
Operate and maintain tool in accordance
tuckpointing)
with manufacturer’s instructions to minimize dust
emissions.
Dust collector must provide 25 cubic feet per
minute (cfm) or greater of airflow per inch of
wheel diameter and have a filter with 99% or
greater efficiency and a cyclonic pre-separator
or filter-cleaning mechanism.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 65
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
(xiii) Walk-behind Use machine equipped with integrated water None None
milling machines and delivery system that continuously feeds water to
floor grinders the cutting surface.
Operate and maintain tool in accordance
with manufacturer’s instructions to minimize
dust emissions.
OR
Use machine equipped with dust collection None None
system recommended by the manufacturer.
Operate and maintain tool in accordance
with manufacturer’s instructions to minimize dust
emissions.
Dust collector must provide the air flow
recommended by the manufacturer, or greater,
and have a filter with 99% or greater efficiency
and a filter-cleaning mechanism.
When used indoors or in an enclosed area, use
a HEPA-filtered vacuum to remove loose dust in
between passes.
(xiv) Small drivable Use a machine equipped with supplemental water None None
milling machines sprays designed to suppress dust. Water must be
(less than half-lane) combined with a surfactant.
Operate and maintain machine to minimize
dust emissions.
(xvi) Crushing Use equipment designed to deliver water spray None None
machines or mist for dust suppression at crusher and other
points where dust is generated (e.g., hoppers,
conveyers, sieves/sizing or vibrating components,
and discharge points).
Operate and maintain machine in accordance
with manufacturer’s instructions to minimize dust
emissions.
Use a ventilated booth that provides fresh,
climate-controlled air to the operator, or a remote
control station.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 67
TABLE 1: S
pecified Exposure Control Methods When
Working with Materials Containing Crystalline Silica
(xvii) Heavy Operate equipment from within an enclosed cab. None None
equipment and
When employees outside of the cab are engaged None None
utility vehicles
in the task, apply water and/or dust suppressants
used to abrade
as necessary to minimize dust emissions.
or fracture silica-
containing materials
(e.g., hoe-ramming,
rock ripping) or used
during demolition
activities involving
silica-containing
materials
(F) Has heating and cooling capabilities. (iii) Scheduled monitoring option. (A) The
employer shall perform initial monitoring
(3) Where an employee performs more to assess the 8-hour TWA exposure for
than one task on Table 1 during the course each employee on the basis of one or more
of a shift, and the total duration of all tasks personal breathing zone air samples that
combined is more than four hours, the reflect the exposures of employees on each
required respiratory protection for each task shift, for each job classification, in each work
is the respiratory protection specified for area. Where several employees perform
more than four hours per shift. If the total the same tasks on the same shift and in the
duration of all tasks on Table 1 combined is same work area, the employer may sample
less than four hours, the required respiratory a representative fraction of these employees
protection for each task is the respiratory in order to meet this requirement. In
protection specified for less than four hours representative sampling, the employer shall
per shift. sample the employee(s) who are expected
to have the highest exposure to respirable
crystalline silica.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 69
(B) If initial monitoring indicates that employee (vi) Employee notification of assessment
exposures are below the action level, the results. (A) Within five working days after
employer may discontinue monitoring for completing an exposure assessment in
those employees whose exposures are accordance with paragraph (d)(2) of this
represented by such monitoring. section, the employer shall individually notify
each affected employee in writing of the
(C) Where the most recent exposure results of that assessment or post the results
monitoring indicates that employee in an appropriate location accessible to all
exposures are at or above the action level affected employees.
but at or below the PEL, the employer shall
repeat such monitoring within six months of (B) Whenever an exposure assessment
the most recent monitoring. indicates that employee exposure is above
the PEL, the employer shall describe in the
(D) Where the most recent exposure written notification the corrective action
monitoring indicates that employee being taken to reduce employee exposure to
exposures are above the PEL, the employer or below the PEL.
shall repeat such monitoring within three
months of the most recent monitoring. (vii) Observation of monitoring. (A) Where air
monitoring is performed to comply with the
(E) Where the most recent (non-initial) requirements of this section, the employer
exposure monitoring indicates that employee shall provide affected employees or their
exposures are below the action level, the designated representatives an opportunity
employer shall repeat such monitoring within to observe any monitoring of employee
six months of the most recent monitoring exposure to respirable crystalline silica.
until two consecutive measurements, taken
seven or more days apart, are below the (B) When observation of monitoring requires
action level, at which time the employer may entry into an area where the use of protective
discontinue monitoring for those employees clothing or equipment is required for any
whose exposures are represented by such workplace hazard, the employer shall provide
monitoring, except as otherwise provided in the observer with protective clothing and
paragraph (d)(2)(iv) of this section. equipment at no cost and shall ensure
that the observer uses such clothing and
(iv) Reassessment of exposures. The equipment.
employer shall reassess exposures whenever
a change in the production, process, control (3) Methods of compliance—(i) Engineering
equipment, personnel, or work practices may and work practice controls. The employer
reasonably be expected to result in new or shall use engineering and work practice
additional exposures at or above the action controls to reduce and maintain employee
level, or when the employer has any reason exposure to respirable crystalline silica to
to believe that new or additional exposures at or below the PEL, unless the employer can
or above the action level have occurred. demonstrate that such controls are not
feasible. Wherever such feasible engineering
(v) Methods of sample analysis. The employer and work practice controls are not sufficient
shall ensure that all samples taken to satisfy to reduce employee exposure to or below
the monitoring requirements of paragraph (d) the PEL, the employer shall nonetheless use
(2) of this section are evaluated by a laboratory them to reduce employee exposure to the
that analyzes air samples for respirable lowest feasible level and shall supplement
crystalline silica in accordance with the them with the use of respiratory protection
procedures in Appendix A to this section. that complies with the requirements of
paragraph (e) of this section.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 71
(iii) A description of the housekeeping (i) A medical and work history, with emphasis
measures used to limit employee exposure to on: past, present, and anticipated exposure
respirable crystalline silica; and to respirable crystalline silica, dust, and other
agents affecting the respiratory system; any
(iv) A description of the procedures used history of respiratory system dysfunction,
to restrict access to work areas, when including signs and symptoms of respiratory
necessary, to minimize the number of disease (e.g., shortness of breath, cough,
employees exposed to respirable crystalline wheezing); history of tuberculosis; and
silica and their level of exposure, including smoking status and history;
exposures generated by other employers or
sole proprietors. (ii) A physical examination with special
emphasis on the respiratory system;
(2) The employer shall review and evaluate
the effectiveness of the written exposure (iii) A chest X-ray (a single posteroanterior
control plan at least annually and update it as radiographic projection or radiograph of the
necessary. chest at full inspiration recorded on either
film (no less than 14 x 17 inches and no more
(3) The employer shall make the written than 16 x 17 inches) or digital radiography
exposure control plan readily available for systems), interpreted and classified according
examination and copying, upon request, to to the International Labour Office (ILO)
each employee covered by this section, their International Classification of Radiographs
designated representatives, the Assistant of Pneumoconioses by a NIOSH-certified B
Secretary and the Director. Reader;
(4) The employer shall designate a (iv) A pulmonary function test to include
competent person to make frequent and forced vital capacity (FVC) and forced
regular inspections of job sites, materials, expiratory volume in one second (FEV1) and
and equipment to implement the written FEV1/FVC ratio, administered by a spirometry
exposure control plan. technician with a current certificate from a
(h) Medical surveillance—(1) General. (i) The NIOSH-approved spirometry course;
employer shall make medical surveillance (v) Testing for latent tuberculosis infection; and
available at no cost to the employee, and
at a reasonable time and place, for each (vi) Any other tests deemed appropriate by
employee who will be required under this the PLHCP.
section to use a respirator for 30 or more
days per year. (3) Periodic examinations. The employer shall
make available medical examinations that
(ii) The employer shall ensure that all medical include the procedures described in paragraph
examinations and procedures required by (h)(2) of this section (except paragraph (h)(2)(v))
this section are performed by a PLHCP as at least every three years, or more frequently if
defined in paragraph (b) of this section. recommended by the PLHCP.
(2) Initial examination. The employer shall (4) Information provided to the PLHCP. The
make available an initial (baseline) medical employer shall ensure that the examining
examination within 30 days after initial PLHCP has a copy of this standard, and
assignment, unless the employee has shall provide the PLHCP with the following
received a medical examination that meets information:
the requirements of this section within the last
three years. The examination shall consist of:
(iii) A description of any personal protective (B) A statement that the examination has met
equipment used or to be used by the employee, the requirements of this section; and
including when and for how long the employee
has used or will use that equipment; and (C) Any recommended limitations on the
employee’s use of respirators.
(iv) Information from records of employment-
related medical examinations previously (ii) If the employee provides written
provided to the employee and currently authorization, the written opinion shall also
within the control of the employer. contain either or both of the following:
(5) PLHCP’s written medical report for the (A) Any recommended limitations on
employee. The employer shall ensure that the the employee’s exposure to respirable
PLHCP explains to the employee the results crystalline silica;
of the medical examination and provides (B) A statement that the employee should
each employee with a written medical report be examined by a specialist (pursuant
within 30 days of each medical examination to paragraph (h)(7) of this section) if the
performed. The written report shall contain: chest X-ray provided in accordance with
(i) A statement indicating the results of the this section is classified as 1/0 or higher by
medical examination, including any medical the B Reader, or if referral to a specialist is
condition(s) that would place the employee otherwise deemed appropriate by the PLHCP.
at increased risk of material impairment to (iii) The employer shall ensure that each
health from exposure to respirable crystalline employee receives a copy of the written
silica and any medical conditions that require medical opinion described in paragraph (h)
further evaluation or treatment; (6)(i) and (ii) of this section within 30 days of
(ii) Any recommended limitations on the each medical examination performed.
employee’s use of respirators; (7) Additional examinations. (i) If the PLHCP’s
(iii) Any recommended limitations on the written medical opinion indicates that an
employee’s exposure to respirable crystalline employee should be examined by a specialist,
silica; and the employer shall make available a medical
examination by a specialist within 30 days
(iv) A statement that the employee should after receiving the PLHCP’s written opinion.
be examined by a specialist (pursuant
to paragraph (h)(7) of this section) if the (ii) The employer shall ensure that the
chest X-ray provided in accordance with examining specialist is provided with all of
this section is classified as 1/0 or higher by the information that the employer is obligated
the B Reader, or if referral to a specialist is to provide to the PLHCP in accordance with
otherwise deemed appropriate by the PLHCP. paragraph (h)(4) of this section.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 73
(iii) The employer shall ensure that the (D) The contents of this section;
specialist explains to the employee the results
of the medical examination and provides (E) The identity of the competent person
each employee with a written medical report designated by the employer in accordance
within 30 days of the examination. The with paragraph (g)(4) of this section; and
written report shall meet the requirements of (F) The purpose and a description of the
paragraph (h)(5) (except paragraph (h)(5)(iv)) medical surveillance program required by
of this section. paragraph (h) of this section.
(iv) The employer shall obtain a written (ii) The employer shall make a copy of this
opinion from the specialist within 30 days of section readily available without cost to each
the medical examination. The written opinion employee covered by this section.
shall meet the requirements of paragraph (h)
(6) (except paragraph (h)(6)(i)(B) and (ii)(B)) of (j) Recordkeeping—(1) Air monitoring
this section. data. (i) The employer shall make and
maintain an accurate record of all exposure
(i) Communication of respirable crystalline measurements taken to assess employee
silica hazards to employees—(1) Hazard exposure to respirable crystalline silica, as
communication. The employer shall include prescribed in paragraph (d)(2) of this section.
respirable crystalline silica in the program
established to comply with the hazard (ii) This record shall include at least the
communication standard (HCS) (29 CFR following information:
1910.1200). The employer shall ensure that
each employee has access to labels on (A) The date of measurement for each
containers of crystalline silica and safety data sample taken;
sheets, and is trained in accordance with the (B) The task monitored;
provisions of HCS and paragraph (i)(2) of this
section. The employer shall ensure that at (C) Sampling and analytical methods used;
least the following hazards are addressed:
Cancer, lung effects, immune system effects, (D) Number, duration, and results of
and kidney effects. samples taken;
(2) Employee information and training. (E) Identity of the laboratory that performed
(i) The employer shall ensure that each the analysis;
employee covered by this section can (F) Type of personal protective equipment,
demonstrate knowledge and understanding such as respirators, worn by the employees
of at least the following: monitored; and
(A) The health hazards associated with (G) Name, social security number, and job
exposure to respirable crystalline silica; classification of all employees represented by
(B) Specific tasks in the workplace that the monitoring, indicating which employees
could result in exposure to respirable were actually monitored.
crystalline silica; (iii) The employer shall ensure that exposure
(C) Specific measures the employer has records are maintained and made available in
implemented to protect employees from accordance with 29 CFR 1910.1020.
exposure to respirable crystalline silica,
including engineering controls, work
practices, and respirators to be used;
(ii) This record shall include at least the (3) Requirements for methods of sample
following information: analysis in paragraph (d)(2)(v) of this section
commence June 23, 2018.
(A) The crystalline silica-containing material
in question; Appendix A to § 1926.1153 – Methods of
Sample Analysis.
(B) The source of the objective data;
This appendix specifies the procedures
(C) The testing protocol and results of testing; for analyzing air samples for respirable
(D) A description of the process, task, or crystalline silica, as well as the quality control
activity on which the objective data were procedures that employers must ensure
based; and that laboratories use when performing an
analysis required under 29 CFR 1926.1153 (d)
(E) Other data relevant to the process, task, (2)(v). Employers must ensure that such a
activity, material, or exposures on which the laboratory:
objective data were based.
1. Evaluates all samples using the procedures
(iii) The employer shall ensure that objective specified in one of the following analytical
data are maintained and made available in methods: OSHA ID-142; NMAM 7500; NMAM
accordance with 29 CFR 1910.1020. 7602; NMAM 7603; MSHA P-2; or MSHA P-7;
(3) Medical surveillance. (i) The employer shall 2. Is accredited to ANS/ISO/IEC Standard
make and maintain an accurate record for each 17025:2005 with respect to crystalline silica
employee covered by medical surveillance analyses by a body that is compliant with ISO/
under paragraph (h) of this section. IEC Standard 17011:2004 for implementation of
quality assessment programs;
(ii) The record shall include the following
information about the employee: 3. Uses the most current National Institute
of Standards and Technology (NIST) or NIST
(A) Name and social security number; traceable standards for instrument calibration
(B) A copy of the PLHCPs’ and specialists’ or instrument calibration verification;
written medical opinions; and 4. Implements an internal quality control (QC)
(C) A copy of the information provided to the program that evaluates analytical uncertainty
PLHCPs and specialists. and provides employers with estimates of
sampling and analytical error;
(iii) The employer shall ensure that medical
records are maintained and made available in 5. Characterizes the sample material by
accordance with 29 CFR 1910.1020. identifying polymorphs of respirable
crystalline silica present, identifies the
(k) Dates. (1) This section shall become presence of any interfering compounds that
effective June 23, 2016. might affect the analysis, and makes any
corrections necessary in order to obtain
accurate sample analysis; and
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 75
6. Analyzes quantitatively for crystalline increased risk of a latent tuberculosis (TB)
silica only after confirming that the sample infection becoming active. Thus, medical
matrix is free of uncorrectable analytical surveillance of silica-exposed employees
interferences, corrects for analytical requires that PLHCPs have a thorough
interferences, and uses a method that meets knowledge of silica-related health effects.
the following performance specifications:
This Appendix is divided into seven
6.1 Each day that samples are analyzed, sections. Section 1 reviews silica-related
performs instrument calibration checks diseases, medical responses, and public
with standards that bracket the sample health responses. Section 2 outlines the
concentrations; components of the medical surveillance
program for employees exposed to
6.2 Uses five or more calibration standard silica. Section 3 describes the roles and
levels to prepare calibration curves and responsibilities of the PLHCP implementing
ensures that standards are distributed the program and of other medical specialists
through the calibration range in a manner and public health professionals. Section 4
that accurately reflects the underlying provides a discussion of considerations,
calibration curve; and including confidentiality. Section 5 provides
6.3 Optimizes methods and instruments to a list of additional resources and Section 6
obtain a quantitative limit of detection that lists references. Section 7 provides sample
represents a value no higher than 25 percent forms for the written medical report for the
of the PEL based on sample air volume. employee, the written medical opinion for the
employer and the written authorization.
Appendix B to § 1926.1153 – Medical
Surveillance Guidelines. 1. Recognition of Silica-related Diseases.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 77
1.3.3. Spirometry - restrictive or mixed 1.4.5. Clinical Course - employees with acute
restrictive/obstructive pattern. silicosis are at especially high risk of TB
activation, nontuberculous mycobacterial
1.3.4. Chest X-ray - small rounded and/ infections, and fungal superinfections. Acute
or irregular opacities bilaterally. Large silicosis is immediately life-threatening. The
opacities and lung abscesses may indicate employee should be urgently referred to
infections, lung cancer, or progression a Board Certified Specialist in Pulmonary
to complicated silicosis, also termed Disease or Occupational Medicine for
progressive massive fibrosis. evaluation and treatment. Although any
1.3.5. Clinical Course - accelerated silicosis case of silicosis indicates a breakdown in
has a rapid, severe course. Under the prevention, a case of acute or accelerated
respirable crystalline silica standard, the silicosis implies a profoundly high level
PLHCP can recommend referral to a Board of silica exposure and may mean that
Certified Specialist in either Pulmonary other employees are currently exposed to
Disease or Occupational Medicine, as dangerous levels of silica.
deemed appropriate, and referral to a 1.5. COPD. COPD, including chronic bronchitis
Specialist is recommended whenever the and emphysema, has been documented in
diagnosis of accelerated silicosis is being silica-exposed employees, including those who
considered. do not develop silicosis. Periodic spirometry
1.4. Acute Silicosis. Acute silicosis is a rare tests are performed to evaluate each employee
disease caused by inhalation of extremely for progressive changes consistent with
high levels of respirable crystalline silica the development of COPD. In addition to
particles. The pathology is similar to alveolar evaluating spirometry results of individual
proteinosis with lipoproteinaceous material employees over time, PLHCPs may want to
accumulating in the alveoli. Acute silicosis be aware of general trends in spirometry
develops rapidly, often, within a few months results for groups of employees from the same
to less than 2 years of exposure, and is workplace to identify possible problems that
almost always fatal. The clinical presentation might exist at that workplace. (See Section
of acute silicosis is as follows: 2 of this Appendix on Medical Surveillance
for further discussion.) Heart disease may
1.4.1. Symptoms - sudden, progressive, and develop secondary to lung diseases such as
severe shortness of breath. Constitutional COPD. A recent study by Liu et al. 2014 noted a
symptoms are frequently present and significant exposure-response trend between
include fever, weight loss, fatigue, productive cumulative silica exposure and heart disease
cough, hemoptysis (coughing up blood), and deaths, primarily due to pulmonary heart
pleuritic chest pain. disease, such as cor pulmonale.
1.4.2. Physical Examination - dyspnea at rest, 1.6. Renal and Immune System. Silica
cyanosis, decreased breath sounds, inspiratory exposure has been associated with
rales, clubbing of the digits, and fever. several types of kidney disease, including
glomerulonephritis, nephrotic syndrome, and
1.4.3. Spirometry - restrictive or mixed end stage renal disease requiring dialysis.
restrictive/obstructive pattern. Silica exposure has also been associated
1.4.4. Chest X-ray - diffuse haziness of the with other autoimmune conditions, including
lungs bilaterally early in the disease. As progressive systemic sclerosis, systemic
the disease progresses, the “ground glass” lupus erythematosus, and rheumatoid
appearance of interstitial fibrosis will appear. arthritis. Studies note an association between
employees with silicosis and serologic
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 79
(particularly a history of kidney disease, to TST (Mazurek et al. 2010; Slater et al.
cardiac disease, connective tissue disease, 2013). PLHCPs can consult the current CDC
and other immune diseases), medications, guidelines for acceptable tests for latent TB
hospitalizations and surgeries may uncover infection.
health risks, such as immune suppression,
that could put an employee at increased 2.3.2.3. The silica standard allows the PLHCP
health risk from exposure to silica. This to order additional tests or test at a greater
information is important when counseling frequency than required by the standard,
the employee on risks and safe work if deemed appropriate. Therefore, PLHCPs
practices related to silica exposure. might perform periodic (e.g., annual) TB
testing as appropriate, based on employees’
2.2. Physical Examination. risk factors. For example, according to
the American Thoracic Society (ATS), the
2.2.1. The respirable crystalline silica diagnosis of silicosis or exposure to silica for
standard requires the following: A physical 25 years or more are indications for annual
examination, with special emphasis on the TB testing (ATS 1997). PLHCPs should consult
respiratory system. The physical examination the current CDC guidance on risk factors for
must be performed at the initial examination TB (See Section 5 of this Appendix).
and every three years thereafter.
2.3.2.4. Employees with positive TB tests and
2.2.2. Additional guidance and those with indeterminate test results should
recommendations: Elements of the be referred to the appropriate agency or
physical examination that can assist the specialist, depending on the test results and
PHLCP include: an examination of the clinical picture. Agencies, such as local public
cardiac system, an extremity examination health departments, or specialists, such as a
(for clubbing, cyanosis, edema, or joint pulmonary or infectious disease specialist,
abnormalities), and an examination of other may be the appropriate referral. Active TB is a
pertinent organ systems identified during the nationally notifiable disease. PLHCPs should
history. be aware of the reporting requirements
2.3. TB Testing. for their region. All States have TB Control
Offices that can be contacted for further
2.3.1. The respirable crystalline silica standard information. (See Section 5 of this Appendix
requires the following: Baseline testing for TB for links to CDC’s TB resources and State TB
on initial examination. Control Offices.)
2.3.2. Additional guidance and 2.3.2.5. The following public health principles
recommendations: are key to TB control in the U.S. (ATS-CDC-
IDSA 2005):
2.3.2.1. Current CDC guidelines (See Section
5 of this Appendix) should be followed for the (1) Prompt detection and reporting of persons
application and interpretation of Tuberculin who have contracted active TB;
skin tests (TST). The interpretation and
documentation of TST reactions should (2) Prevention of TB spread to close contacts
be performed within 48 to 72 hours of of active TB cases;
administration by trained PLHCPs. (3) Prevention of active TB in people with
2.3.2.2. PLHCPs may use alternative TB tests, latent TB through targeted testing and
such as interferon-release assays (IGRAs), treatment; and
if sensitivity and specificity are comparable
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 81
2.6. Other Testing. Under the respirable The written medical report must contain
crystalline silica standards, the PLHCP has a statement indicating the results of the
the option of ordering additional testing he medical examination, including any medical
or she deems appropriate. Additional tests condition(s) that would place the employee
can be ordered on a case-by-case basis at increased risk of material impairment to
depending on individual signs or symptoms health from exposure to respirable crystalline
and clinical judgment. For example, if an silica and any medical conditions that
employee reports a history of abnormal require further evaluation or treatment. In
kidney function tests, the PLHCP may want addition, the PLHCP’s written medical report
to order a baseline renal function tests must include any recommended limitations
(e.g., serum creatinine and urinalysis). As on the employee’s use of respirators, any
indicated above, the PLHCP may order annual recommended limitations on the employee’s
TB testing for silica-exposed employees exposure to respirable crystalline silica, and
who are at high risk of developing active a statement that the employee should be
TB infections. Additional tests that PLHCPs examined by a Board Certified Specialist in
may order based on findings of medical Pulmonary Disease or Occupational medicine
examinations include, but is not limited to, if the chest X-ray is classified as 1/0 or higher
chest computerized tomography (CT) scan for by the B Reader, or if referral to a Specialist is
lung cancer or COPD, testing for immunologic otherwise deemed appropriate by the PLHCP.
diseases, and cardiac testing for pulmonary-
related heart disease, such as cor pulmonale. The PLHCP should discuss all findings and
test results and any recommendations
3. Roles and Responsibilities. regarding the employee’s health, worksite
safety and health practices, and medical
3.1. PLHCP. The PLHCP designation refers referrals for further evaluation, if indicated.
to “an individual whose legally permitted In addition, it is suggested that the PLHCP
scope of practice (i.e., license, registration, offer to provide the employee with a
or certification) allows him or her to complete copy of their examination and
independently provide or be delegated the test results, as some employees may want
responsibility to provide some or all of the this information for their own records or to
particular health care services required” by provide to their personal physician or a future
the respirable crystalline silica standard. The PLHCP. Employees are entitled to access their
legally permitted scope of practice for the medical records.
PLHCP is determined by each State. PLHCPs
who perform clinical services for a silica Under the respirable crystalline silica
medical surveillance program should have a standard, the employer must ensure that
thorough knowledge of respirable crystalline the PLHCP provides the employer with a
silica-related diseases and symptoms. written medical opinion within 30 days of
Suspected cases of silicosis, advanced COPD, the employee examination, and that the
or other respiratory conditions causing employee also gets a copy of the written
impairment should be promptly referred to medical opinion for the employer within 30
a Board Certified Specialist in Pulmonary days. The PLHCP may choose to directly
Disease or Occupational Medicine. provide the employee a copy of the written
medical opinion. This can be particularly
Once the medical surveillance examination helpful to employees, such as construction
is completed, the employer must ensure employees, who may change employers
that the PLHCP explains to the employee frequently. The written medical opinion can
the results of the medical examination and be used by the employee as proof of up-
provides the employee with a written medical to-date medical surveillance. The following
report within 30 days of the examination.
3.1.1. The written medical report for the (1) Any recommended limitations on the
employee must include the following employee’s exposure to respirable crystalline
information: silica; and
3.1.1.1. A statement indicating the results (2) A statement that the employee should be
of the medical examination, including any examined by a Board Certified Specialist in
medical condition(s) that would place the Pulmonary Disease or Occupational Medicine
employee at increased risk of material if the chest X-ray provided in accordance with
impairment to health from exposure to this section is classified as 1/0 or higher by
respirable crystalline silica and any medical the B Reader, or if referral to a Specialist is
conditions that require further evaluation or otherwise deemed appropriate.
treatment; 3.1.2.5. In addition to the above referral for
3.1.1.2. Any recommended limitations upon abnormal chest X-ray, the PLHCP may refer
the employee’s use of a respirator; an employee to a Board Certified Specialist in
Pulmonary Disease or Occupational Medicine
3.1.1.3. Any recommended limitations on the for other findings of concern during the medical
employee’s exposure to respirable crystalline surveillance examination if these findings are
silica; and potentially related to silica exposure.
3.1.1.4. A statement that the employee should 3.1.2.6. Although the respirable crystalline
be examined by a Board Certified Specialist in silica standard requires the employer to
Pulmonary Disease or Occupational Medicine, ensure that the PLHCP explains the results of
where the standard requires or where the the medical examination to the employee, the
PLHCP has determined such a referral is standard does not mandate how this should
necessary. The standard requires referral be done. The written medical opinion for
to a Board Certified Specialist in Pulmonary the employer could contain a statement that
Disease or Occupational Medicine for a chest the PLHCP has explained the results of the
X-ray B reading indicating small opacities in medical examination to the employee.
a profusion of 1/0 or higher, or if the PHLCP
determines that referral to a Specialist is 3.2. Medical Specialists. The silica standard
necessary for other silica-related findings. requires that all employees with chest X-ray B
readings of 1/0 or higher be referred to a Board
3.1.2. The PLHCP’s written medical opinion Certified Specialist in Pulmonary Disease or
for the employer must include only the Occupational Medicine. If the employee has
following information: given written authorization for the employer
to be informed, then the employer shall
3.1.2.1. The date of the examination; make available a medical examination by a
3.1.2.2. A statement that the examination has Specialist within 30 days after receiving the
met the requirements of this section; and PLHCP’s written medical opinion.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 83
3.2.1. The employer must provide the 3.2.4. The Specialist’s written medical report
following information to the Board Certified for the employee must include the following
Specialist in Pulmonary Disease or information:
Occupational Medicine:
3.2.4.1. A statement indicating the results
3.2.1.1. A description of the employee’s of the medical examination, including any
former, current, and anticipated duties as medical condition(s) that would place the
they relate to the employee’s occupational employee at increased risk of material
exposure to respirable crystalline silica; impairment to health from exposure to
respirable crystalline silica and any medical
3.2.1.2. The employee’s former, current, and conditions that require further evaluation
anticipated levels of occupational exposure to or treatment;
respirable crystalline silica;
3.2.4.2. Any recommended limitations upon
3.2.1.3. A description of any personal the employee’s use of a respirator; and
protective equipment used or to be used by
the employee, including when and for how 3.2.4.3. Any recommended limitations
long the employee has used or will use that on the employee’s exposure to respirable
equipment; and crystalline silica.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 85
written authorization and its consequences. for employees who do abrasive blasting
The discussion should include the risk of with silica because of the high exposures
ongoing silica exposure, personal risk factors, associated with that operation.
risk of disease progression, and possible
health and economic consequences. For ACOEM’s Code of Ethics and discussion is a
instance, written authorization is required good resource to guide PLHCPs regarding the
for a PLHCP to advise an employer that an issues discussed in this section (See Section
employee should be referred to a Board 5 of this Appendix).
Certified Specialist in Pulmonary Disease 5. Resources.
or Occupational Medicine for evaluation of
an abnormal chest X-ray (B-reading 1/0 or 5.1. American College of Occupational and
greater). If an employee does not sign an Environmental Medicine (ACOEM):
authorization, then the employer will not
know and cannot facilitate the referral to a ACOEM Code of Ethics. Accessed at: http://
Specialist and is not required to pay for the www.acoem.org/codeofconduct.aspx
Specialist’s examination. In the rare case Raymond, L.W. and Wintermeyer, S. (2006)
where an employee is diagnosed with acute ACOEM evidenced-based statement on
or accelerated silicosis, co-workers are likely medical surveillance of silica-exposed
to be at significant risk of developing those workers: medical surveillance of workers
diseases as a result of inadequate controls in exposed to crystalline silica. J Occup Environ
the workplace. In this case, the PLHCP and/or Med, 48, 95-101.
Specialist should explain this concern to the
affected employee and make a determined 5.2. Center for Disease Control and
effort to obtain written authorization from the Prevention (CDC)
employee so that the PLHCP and/or Specialist
can contact the employer. Tuberculosis webpage: http://www.cdc.gov/
tb/default.htm
Finally, without written authorization from
the employee, the PLHCP and/or Board State TB Control Offices web page: http://
Certified Specialist in Pulmonary Disease www.cdc.gov/tb/links/tboffices.htm
or Occupational Medicine cannot provide Tuberculosis Laws and Policies webpage:
feedback to an employer regarding control of http://www.cdc.gov/tb/programs/laws/
workplace silica exposure, at least in relation default.htm
to an individual employee. However, the
regulation does not prohibit a PLHCP and/ CDC. (2013). Latent Tuberculosis Infection:
or Specialist from providing an employer A Guide for Primary Health Care Providers.
with general recommendations regarding Accessed at: http://www.cdc.gov/tb/
exposure controls and prevention programs publications/ltbi/pdf/targetedltbi.pdf
in relation to silica exposure and silica-
related illnesses, based on the information 5.3. International Labour Organization
that the PLHCP receives from the employer International Labour Office (ILO).
such as employees’ duties and exposure (2011) Guidelines for the use of the ILO
levels. Recommendations may include International Classification of Radiographs
increased frequency of medical surveillance of Pneumoconioses, Revised edition 2011.
examinations, additional medical surveillance Occupational Safety and Health Series No. 22:
components, engineering and work practice http://www.ilo.org/safework/info/publications/
controls, exposure monitoring and personal WCMS_168260/lang--en/index.htm
protective equipment. For instance, more
frequent medical surveillance examinations 5.4. National Institute of Occupational Safety
may be a recommendation to employers and Health (NIOSH)
NIOSH Hazard Review (2002), Health Effects OSHA/NIOSH (2011) Spirometry: OSHA/
of Occupational Exposure to Respirable NIOSH Spirometry Worker Info. (OSHA
Crystalline Silica. NIOSH publication number 3418-3-11). Accessed at http://www.osha.gov/
2002-129: Accessed at http://www.cdc.gov/ Publications/osha3418.pdf
niosh/docs/2002-129
5.7. Other
NIOSH Health Hazard Evaluations Programs.
(Information on the NIOSH Health Hazard Steenland, K. and Ward E. (2014). Silica: A
Evaluation (HHE) program, how to request lung carcinogen. CA Cancer J Clin, 64, 63-69.
an HHE and how to look up an HHE report). (This article reviews not only silica and lung
Accessed at: http://www.cdc.gov/niosh/hhe cancer but also all the known silica-related
health effects. Further, the authors provide
5.5. National Industrial Sand Association: guidance to clinicians on medical surveillance
of silica-exposed workers and worker
Occupational Health Program for Exposure counselling on safety practices to minimize
to Crystalline Silica in the Industrial silica exposure.)
Sand Industry. National Industrial Sand
Association, 2nd ed. 2010. Can be ordered 6. References.
at: http://www.sand.org/silica-occupational-
health-program American Thoracic Society (ATS). Medical
Section of the American Lung Association
5.6. Occupational Safety and Health (1997). Adverse effects of crystalline silica
Administration (OSHA) exposure. Am J Respir Crit Care Med, 155,
761-765.
Contacting OSHA: http://www.osha.gov/html/
Feed_Back.html American Thoracic Society (ATS), Centers for
Disease Control (CDC), Infectious Diseases
OSHA’s Clinicians webpage. (OSHA Society of America (IDSA) (2005). Controlling
resources, regulations and links to help Tuberculosis in the United States. Morbidity
clinicians navigate OSHA’s web site and aid and Mortality Weekly Report (MMWR),
clinicians in caring for workers.) Accessed at: 54(RR12), 1-81. Accessed at: http://www.cdc.
http://www.osha.gov/dts/oom/clinicians gov/mmwr/preview/mmwrhtml/rr5412a1.htm
OSHA’s Safety and Health Topics webpage Brown, T. (2009). Silica exposure, smoking,
on Silica. Accessed at: http://www.osha.gov/ silicosis and lung cancer – complex
dsg/topics/silicacrystalline interactions. Occupational Medicine, 59, 89-95.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 87
Halldin, C. N., Petsonk, E. L., and Laney, Mazurek, G. H., Jereb, J., Vernon, A., LoBue,
A. S. (2014). Validation of the International P., Goldberg, S., Castro, K. (2010). Updated
Labour Office digitized standard images for guidelines for using interferon gamma
recognition and classification of radiographs release assays to detect Mycobacterium
of pneumoconiosis. Acad Radiol, 21,305-311. tuberculosis infection – United States.
Morbidity and Mortality Weekly Report
International Agency for Research on (MMWR), 59(RR05), 1-25.
Cancer. (2012). Monographs on the
evaluation of carcinogenic risks to humans: Miller, M. R., Hankinson, J., Brusasco, V.,
Arsenic, Metals, Fibers, and Dusts Silica Burgos, F., Casaburi, R., Coates, A., Crapo, R.,
Dust, Crystalline, in the Form of Quartz Enright, P., van der Grinten, C. P., Gustafsson,
or Cristobalite. A Review of Human P., Jensen, R., Johnson, D. C., MacIntyre,
Carcinogens. Volume 100 C. Geneva, N., McKay, R., Navajas, D., Pedersen, O. F.,
Switzerland: World Health Organization. Pellegrino, R., Viegi, G., and Wanger, J. (2005).
Laney, A. S., Petsonk, E. L., and Attfield, M. Occupational Safety and Health
D. (2011). Intramodality and intermodality Administration/National Institute for
comparisons of storage phosphor computed Occupational Safety and Health (OSHA/
radiography and conventional film-screen NIOSH) (2012). Hazard Alert. Worker exposure
radiography in the recognition of small to silica during hydraulic fracturing.
pneumonconiotic opacities. Chest, 140,
1574‑1580. Occupational Safety and Health Administration/
National Institute for Occupational Safety and
Liu, Y., Steenland, K., Rong, Y., Hnizdo, E., Health (OSHA/NIOSH) (2015). Hazard alert.
Huang, X., Zhang, H., Shi, T., Sun, Y., Wu, Worker exposure to silica during countertop
T., and Chen, W. (2013). Exposure-response manufacturing, finishing, and installation.
analysis and risk assessment for lung cancer (OSHA- HA-3768-2015).
in relationship to silica exposure: a 44-year
cohort study of 34,018 workers. Am J Epi, Redlich, C. A., Tarlo, S. M., Hankinson, J. L.,
178,1424-1433. Townsend, M. C, Eschenbacher, W. L., Von
Essen, S. G., Sigsgaard, T., Weissman, D. N.
Liu, Y., Rong, Y., Steenland, K., Christiani, D. (2014). Official American Thoracic Society
C., Huang, X., Wu, T., and Chen, W. (2014). technical standards: spirometry in the
Long-term exposure to crystalline silica and occupational setting. Am J Respir Crit Care
risk of heart disease mortality. Epidemiology, Med; 189, 984-994.
25, 689-696.
Shtraichman, O., Blanc, P. D., Ollech, J. E., Steenland, K. and Ward E. (2014). Silica: A
Fridel, L., Fuks, L., Fireman, E., and Kramer, lung carcinogen. CA Cancer J Clin, 64, 63-69.
M. R. (2015). Outbreak of autoimmune
disease in silicosis linked to artificial stone. Townsend, M. C. ACOEM Guidance
Occup Med, 65, 444-450. Statement. (2011). Spirometry in the
occupational health setting – 2011 Update. J
Slater, M. L., Welland, G., Pai, M., Parsonnet, Occup Environ Med, 53, 569-584.
J., and Banaei, N. (2013). Challenges with
QuantiFERON-TB gold assay for large-scale, 7. Sample Forms.
routine screening of U.S. healthcare workers. Three sample forms are provided. The first
Am J Respir Crit Care Med, 188,1005-1010. is a sample written medical report for the
Steenland, K., Mannetje, A., Boffetta, P., employee. The second is a sample written
Stayner, L., Attfield, M., Chen, J., Dosemeci, medical opinion for the employer. And
M., DeKlerk, N., Hnizdo, E., Koskela, R., and the third is a sample written authorization
Checkoway, H. (2001). International Agency form that employees sign to clarify what
for Research on Cancer. Pooled exposure- information the employee is authorizing to be
response analyses and risk assessment for released to the employer.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 89
Small Entity Compliance Guide for Construction
Draft – Do not Quote or Cite 5/25/2016
WRITTEN MEDICAL REPORT FOR EMPLOYEE
TYPE OF EXAMINATION:
[ ] Initial examination [ ] Periodic examination [ ] Specialist examination
[ ] Other: _______________________________________________________________________________________
[ ] Your health may be at increased risk from exposure to respirable crystalline silica due to the following:
_________________________________________________________________________________________________
RECOMMENDATIONS:
[ ] No limitations on respirator use
[ ] Recommended limitations on use of respirator: ________________________________________________________
[ ] Recommended limitations on exposure to respirable crystalline silica: ______________________________________
_________________________________________________________________________________________________
[ ] I recommend that you be examined by a Board Certified Specialist in Pulmonary Disease or Occupational Medicine
[ ] Other recommendations*:
__________________________________________________________________________
__________________________________________________________________________________________________
Your next periodic examination for silica exposure should be in: [ ] 3 years [ ] Other: ___________________
MM/DD/YYYY
Examining Provider: ________________________________________ Date: _____________________
(signature)
Provider Name: ___________________________________________
Office Address: ____________________________________________ Office Phone: ___________________
*These findings may not be related to respirable crystalline silica exposure or may not be work-related, and therefore
may not be covered by the employer. These findings may necessitate follow-up and treatment by your personal
physician.
117
EMPLOYER: ____________________________________________
TYPE OF EXAMINATION:
[ ] Initial examination [ ] Periodic examination [ ] Specialist examination
[ ] Other: _______________________________________________________________________________________
USE OF RESPIRATOR:
[ ] No limitations on respirator use
[ ] Recommended limitations on use of respirator:_________________________________________________________
The employee has provided written authorization for disclosure of the following to the employer (if applicable):
[ ] This employee should be examined by an American Board Certified Specialist in Pulmonary Disease or Occupational
Medicine
[ ] Recommended limitations on exposure to respirable crystalline silica:_______________________________________
__________________________________________________________________________________________________
The following is required to be checked by the Physician or other Licensed Health Care Professional (PLHCP):
[ ] I attest that this medical examination has met the requirements of the medical surveillance section of the OSHA
Respirable Crystalline Silica standard (§ 1910.1053(h) or 1926.1153(h)).
118
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 91
Small Entity Compliance Guide for Construction
Draft – Do not Quote or Cite 5/25/2016
This medical examination for exposure to crystalline silica could reveal a medical condition that
results in recommendations for (1) limitations on respirator use, (2) limitations on exposure to
crystalline silica, or (3) examination by a specialist in pulmonary disease or occupational
medicine. Recommended limitations on respirator use will be included in the written opinion to
the employer. If you want your employer to know about limitations on crystalline silica exposure
or recommendations for a specialist examination, you will need to give authorization for the
written opinion to the employer to include one or both of those recommendations.
I hereby authorize the opinion to the employer to contain the following information, if relevant
(please check all that apply):
OR
I do not authorize the opinion to the employer to contain anything other than recommended
limitations on respirator use.
___ I understand that if I do not authorize my employer to receive the recommendation for
specialist examination, the employer will not be responsible for arranging and covering
costs of a specialist examination.
________________________________
Name (printed)
________________________________ ______________________
Signature Date
119
Visit www.osha.gov/complianceassistance/cas
or call 1-800-321-OSHA (6742) to contact your
local OSHA office.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 93
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Region 2 Region 4
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(NJ*, NY*, PR*, VI*) (AL, FL, GA, KY*, MS, NC*, SC*, TN*)
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