Prepped for Silica Compliance
In the Tidbits section of our last newsletter, we shared a little about OSHA’s then upcoming rules for construction workers to reduce contact with respirable crystalline silica. The goal being to greatly diminish lung cancer, silicosis, chronic obstructive pulmonary disease, and kidney disease in construction workers. The new rules started September 23rd and here is how the Rafn Company is keeping our workers and subcontractors safe.
OSHA’s New Rules:
- Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur (per OSHA Table 1 (Specified Exposure Control Methods When Working with Materials Containing Crystalline Silica)).
- Designate a competent person to implement the written exposure control plan.
- Restrict housekeeping practices that expose workers to silica where feasible alternatives are available.
- Medical exams - including chest X-rays and lung function tests – for workers who wear respirators more than 30 days in a 12 month period. A day of use is counted anytime a worker dons a respirator (this could be for 5 minutes, several hours, or for an entire day).
- Train workers on operations that result in silica exposure and ways to limit exposure.
- Keep records of workers’ silica exposure and medical exams.
Rafn’s Considerations for Silica Compliance:
- Have our program fully in place by the September 23rd start date (we did).
- Our silica program starts during preconstruction with planning, is implemented on the first day of the project, and doesn’t end until the last day of the project.
- We must build a consistent pattern of awareness and problem prevention, just like with asbestos.
- Proper tools and procedures can mitigate required respiratory wear and exposure elements.
- Amend project contracts to include new “site clean-up requirements” language. Sites should no longer be swept, instead they should be vacuumed.
Rafn’s Policy for Silica Compliance:
- Create a site-specific Silica Awareness and Remediation Program for each project.
- Determine which tools we need to purchase to make working in environments with silica safer (tools with vacuum and HEPA filter, air boxes, etc.)
- Follow Table 1 requirements established by OSHA.
- Determine type of protective suit (if required) for availability and disposal.
- Determine training needs and modality (in-house new hire orientations, Lunch & Learns, other awareness compliance training, etc.).
- Create new employee exposure tracking system:
- Provide a location on our electronic timecard to record the use of a respirator relating to silica.
- Provide a summary on our electronic timecards showing how many days in the last 12 months the employee has worn a respirator for silica.
- Provide an internal warning that is sent to the Human Resources department and the job’s superintendent when an employee reaches 25 days of respirator use for silica in a 12-month period, and again at 30 days of use in a 12-month period.
Silica awareness, from 1938 precautions for Miners to glass insulation ties later, has been ongoing for years and will only get more attention in the years to come. It’s a game changer for us with coring, drywall, demolition, and site clean-up activities on all of our projects. Our plan and tracking system is in place and operational, but will allow ongoing refinement as we learn and use our system moving forward to keep our workers and subcontractors safe.
Additional information on OSHA’s silica rules can be found at www.osha.gov/silica.