With OSHA’s full enforcement of the silica standard coming on 9/23/2017, it’s important to make sure your program is up to date and you are ready for potential compliance inspections! Hopefully you’ve already read the standard, but if not, go to www.osha.gov/silica and click around. There’s a lot of useful information there, including the standard itself, which is a pretty quick read.
Make sure you understand some of the lingo related to the standard, especially Table 1. This is the practical foundation of the standard, and a starting point for understanding your personnel’s exposure to respirable crystalline silica. If you have tasks that may involve silica exposure that are not listed on Table 1, you may need to engage with an industrial hygienist to have some air sampling conducted at your sites.
If you are in need of a written exposure control program, I have a template available at www.theferrigroup.co/resources.
Before this week is over, make sure you have provided training for all personnel who have potential for silica exposure. The training can best be described as “HAZCOM on steroids” as it should go in-depth on what silica is, how one can be exposed, the types of illnesses, and the synergistic effect of smoking and silica exposure.
Remember, other aspects of your company’s safety program may need to be refreshed to comply with the silica standard. The big one is your Respiratory Protection Program. If workers must wear respiratory protection and previously did not, you must follow your Respiratory Protection Program policies for the medical questionnaire, fit testing, and respirator training.
Make sure your designated Competent Person(s) are up to speed on the standard and your company’s program – they will most likely be involved in discussions with other trades’ Competent Persons and the General Contractor’s representative.
If you still need assistance, please reach out!
