SILICA RESOURCE CENTER ABOUT THE STANDARD COMPLIANCE PROCESS TOOLS & CUTTING FAQ RESOURCES
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SILICA RESOURCE CENTER ABOUT THE STANDARD COMPLIANCE PROCESS TOOLS & CUTTING FAQ RESOURCES

Demonstrating Compliance with the OSHA Silica Rule

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

There are three options for employers to demonstrate compliance with the OSHA Permissible Exposure Limit (PEL) for respirable crystalline silica. 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 practices ("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 Overview for Fiber Cement
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To learn more about Table 1, please visit here.

Table 1 - Overview for Fiber Cement


Under 29 CFR 1926.1153(c), Table 1 lists several construction site tasks that generate silica dust and specified equipment and practices – called “engineering controls” – to keep dust below the PEL.

Under 29 CFR 1926.1153(c)(iii), OSHA provides a specific safe harbor practice for cutting for cutting fiber cement boards using a handheld power saw (with blade diameter of 8 inches or less)1:

For tasks performed outdoors only:
  • Use saw equipped with commercially-available 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.

OSHA has stated that “full and proper implementation” of the above Table 1 control does not require the use of respirators (dust masks) and satisfies the employer's duty to achieve the PEL without the need for additional exposure monitoring.2

1 OSHA Final Silica Rule 2016-04800: https://www.gpo.gov/fdsys/pkg/FR-2016-03-25/pdf/2016-04800.pdf
2 OSHA Standard §1926.1153, p 3: https://www.osha.gov/silica/SilicaConstructionRegText.pdf

 

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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 a combination of objective data and air monitoring data to show that employee exposure is below the PEL.

The combination of objective data and 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.

Objective Data


Objective data means information, such as air monitoring data from industry wide surveys or calculations based on the composition of a substance, demonstrating employee exposure to respirable crystalline silica associated with a particular product or material or a specific process, task, or activity.

 

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OSHA Silica FAQ
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*EMRS = Exposure Monitoring Report Summary

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 Action 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. Depending upon the results of the sampling, the standard may require additional sampling at set periods of time.

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 identifying a certified satefy professional or industrial hygienist who can conduct exposure monitoring.
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Watch our video to see how you can easily work with James Hardie products and the OSHA silica rule change.

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Questions

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