Demonstrating Compliance with the OSHA Silica Rule

Safety Isn't Just A Work Thing. It's An Every Thing.TM

Since the silica dust standard was updated, James Hardie continues to evaluate solutions for complying with OSHA requirements when cutting our products.

Today there are three options to satisfy the permissible exposure limit (PEL). While all options require some education, Option 2 and Option 3 require additional documentation or proof sources and recordkeeping on the employer’s part.
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Option 1
Presumed Compliance: Table 1
Controls (Safe Harbor)

Table 1 (view or download below), identifies 18 common construction tasks that generate respirable silica dust. For each task, Table 1 specifies tools, practices and respiratory protection that OSHA has deemed will keep exposures below the PEL when they are fully and properly implemented.

Employers using the tools and practies ("engineering controls") listed in Table 1 are not required to conduct exposure assessments for silica exposure.

OSHA provides a specific Table 1 engineering control for cutting fiber cement with a handheld circular saw.
Table 1 Engineering

Option 2
The Performance Option: for Tasks not on Table 1

Option 2, the "performance option" applies when employees are not using engineering controls listed in Table 1. Examples of engineering controls not listed in Table 1 include using miter saws or panel saws to cut the fiber cement, or using fans to disperse fiber cement dust.

Under the performance option, employers may rely on any combination of objective data and air monitoring data to show that employee exposure is below the PEL.

The combination of objective data or air monitoring data must reflect workplace conditions that closely resemble the employer's operation on their jobsite, or represent a "worst case" production of silica dust.

James Hardie has compiled a list of reports that may be used as objective data to support your written exposure plan.
OSHA Silica

Option 3
Scheduled Exposure Monitoring

If a control method is not listed on Table 1 and no objective data is available for the performance option, OSHA requires employers to assess exposure for each employee who may be exposed at or above the Active Level (AL). An exposure assessment is not required if the employer has made a reasonable determination that exposures will remain below the AL under all foreseeable circumstances.

Under the scheduled monitoring option, employers must perform initial monitoring to assess the 8-hour TWA exposure for each employee who may be exposed at or above the Action Level (AL). Depending upon the results of the sampling, the standard may require additional sampling at set intervals.

Employers do not need to monitor at each jobsite provided that the task and the workplace conditions in the new work area are substantially similar.

James Hardie can assist you with identofying a certified satefy professional or industrial hygienist who can conduct exposure monitoring.

James Hardie Silica
Training in Action

Watch our video to see how you can easily work with James Hardie products and the OSHA silica rule change.


Don’t hesitate to contact James Hardie. Complete this form or call James Hardie Technical Services at 800-942-7343.

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