Breathing crystalline silica particles can cause silicosis, lung cancer, chronic obstructive pulmonary disease, and kidney disease, among other health effects. Is personal protective equipment sufficient to control the worker’s exposure?
Applicable OSHA regulations
1926.1153(d) - Alternative exposure control methods. For tasks not listed in Table 1, or where the employer does not fully and properly implement the engineering controls, work practices, and respiratory protection described in Table 1.
1926.1153(d)(1) - Permissible exposure limit (PEL). The employer shall ensure that no employee is exposed to an airborne concentration of respirable crystalline silica in excess of 50 μg/m3, calculated as an 8-hour TWA.
1926.1153(d)(2)(i) - General. The employer shall assess the exposure of each employee who is or may reasonably be expected to be exposed to respirable crystalline silica at or above the action level in accordance with either the performance option in paragraph (d)(2)(ii) or the scheduled monitoring option in paragraph (d)(2)(iii) of this section.
1926.1153(d)(3)(i) - Engineering and work practice controls. The employer shall use engineering and work practice controls to reduce and maintain employee exposure to respirable crystalline silica to or below the PEL, unless the employer can demonstrate that such controls are not feasible. Wherever such feasible engineering and work practice controls are not sufficient to reduce employee exposure to or below the PEL, the employer shall nonetheless use them to reduce employee exposure to the lowest feasible level and shall supplement them with the use of respiratory protection that complies with the requirements of paragraph (e) of this section.
Corrective actions required
- Perform an exposure assessment: When the controls specified in Table 1 of the respirable crystalline silica (RCS) standard are not followed, OSHA requires an exposure assessment to verify that the employees' exposure does not exceed the PEL.
- Follow the hierarchy of controls: Implement appropriate controls when exposures exceed the PEL. Utilizing feasible engineering and work practice controls is a requirement. Repeat the exposure assessment to identify the need for additional personal protective equipment. Respiratory protection is only supplementary to the continued use of engineering and work practice controls.
- Worker information: Inform employees of exposure results and provide training on hazards of exposure to crystalline silica, medical surveillance, new equipment use and process controls, and RCS standard.
Plan, surveillance, and improvement
Personal protective equipment is not sufficient. The RCS standard requirements expand beyond a respirator. The standard includes provisions for periodic exposure monitoring, medical surveillance, hazard communication, respiratory protection, an exposure control plan, a competent person, and recordkeeping.
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