1. Occupational Exposure to Respirable Crystalline Silica
Cal-OSHA’s Rule on
Occupational Exposure to
Respirable Crystalline Silica
Mariano Kramer, Associate Cal OSHA Safety Engineer
Cal OSHA Update
November 4, 2016

2. Status of Final Rule Horcher rulemaking procedure
Adopted by California Occupational Safety and Health Board – September 2016
Approved by Office of Administrative Law October 17, 2016
Effective Date October 17, 2016
Models Federal OSHA’s Silica Standard
The final rule was published on March 25, 2016, after an extensive process of stakeholder engagement.
The proposed rule was posted on OSHA’s website in August, 2013 and published in the Federal Register in September, 2013.
OSHA received more than 2000 written comments during a nearly year-long public comment period.
Over 200 stakeholders, representing over 70 organizations, including public health groups, trade associations, and labor unions, presented testimony during public hearings on the proposed rule.
OSHA considered all of this information in developing the final rule.

3. Scope of Coverage
Three forms of silica: quartz, cristobalite and tridymite
Exposures from chipping, cutting, sawing, drilling, grinding, sanding, and crushing of concrete, brick, block, rock, and stone products (such as in construction operations)
Exposures from using sand products (such as glass manufacturing, foundries, and sand blasting)
Crystalline silica is a common mineral that is found in natural materials such as sand, stone, and rock; it is also found in manmade materials such as concrete, brick, block, and mortar.
The most common form of crystalline silica is quartz.
Crystalline silica is a hazard in the workplace when silica-containing materials are handled in a manner that releases respirable silica dust.
Respirable silica particles are about 100 times smaller than grains of sand typically found on beaches or playgrounds.
Exposures to respirable silica dust occur when workers cut, grind, crush, or drill silica-containing materials such as concrete, masonry, tile, and rock, and in operations such as sandblasting.

4. Industries and Operations with Exposures
● Construction
● Glass manufacturing
● Pottery products
● Structural clay products
● Concrete products
● Foundries
● Dental laboratories
● Paintings and coatings
● Jewelry production
● Refractory products
● Asphalt products
● Landscaping
● Ready-mix concrete
● Cut stone and stone products
● Abrasive blasting in:
○ Maritime work
○ Construction
○ General industry
● Refractory furnace installation and repair
● Railroads
● Hydraulic fracturing for gas and oil
This slide lists some of the major industries and operations that are affected by the rule.

5. California’s Respirable Crystalline Silica Rule
Two standards:
One for General Industry
One for Construction
The final rule consists of two separate standards, one for general industry and maritime and one for construction, in order to tailor the standards to the circumstances in these sectors.
The standards are similar to other OSHA chemical-specific health standards.
The provisions of the standards are also roughly comparable to the provisions of industry consensus standards that many employers are already following to protect workers.
We are going to discuss the standard for general industry and maritime, and then describe the differences between the construction standard and the standard for general industry and maritime.

6. General Industry
(a) Scope (b) Definitions (c) Permissible exposure limit (PEL) (d) Exposure assessment (e) Regulated areas (f) Methods of compliance (1) Engineering and work practice controls (2) Written exposure control plan (g) Respiratory protection (h) Housekeeping (i) Medical surveillance (j) Communication of silica hazards (k) Recordkeeping (l) Dates
This slide shows the major provisions of the standard for the general industry and maritime.
Covered employers must comply with all of these provisions.
We will talk about each of these provisions in more detail.

7. General Industry Scope – 5204(a)
All occupational exposures to respirable crystalline silica are covered, except:
Agricultural operations covered by Section 3436
Construction Operations covered by Section
Exposures resulting from processing of sorptive clays.
If employer has objective data that exposures will be below 25 micrograms per cubic meter. (Action Level)
If employer complies with and
Task indistinguishable from construction task in Table 1 of
Task not performed regularly in same environment and conditions
The scope section indicates which employers are covered.
The phrase “any foreseeable conditions” refers to situations that can reasonably be anticipated, for example, failure of engineering controls. Therefore, employers who maintain exposures below 25 µg/m3 with engineering controls are covered. One reason is that employees need training to make sure controls remain effective.
Sorptive clays contain geologically ancient crystalline silica particles and are used in products such as pet litter and landfill absorbents. For sorptive clay exposures, employers only need to follow the formula PEL in the Z-3 table of 29 CFR
General industry employers can follow the construction standard in some circumstances – we will talk about this when we discuss the scope of the construction standard.

8. Permissible Exposure Limit (PEL)
PEL = 50 µg/m3 as an 8-hour TWA
Action Level = 25 µg/m3 as an 8-hour TWA
Employers in general industry must limit exposures to a new PEL of 50 µg/m3 as an 8-hour time-weighted average.
The new PEL significantly reduces, but does not eliminate, significant risk of developing silica-related disease.
The standard also establishes an action level of half the PEL, or 25 µg/m3 as an 8-hour time-weighted average.
The action level triggers requirements for exposure assessment and, in general industry and maritime, medical surveillance.

9. 5155-Airborne Contaminants Table AC-1 - PELs
Silica, crystalline, respirable dust(n)
Cristobalite, respirable dust – (see also Sections & 5204)
Quartz, respirable dust (see also Sections & 5204)
Quartz, total dust
Silica, fused, respirable dust
Tridymite, respirable dust – 0.05 (see also Sections & 5204)
Tripoli, (as quartz)respirable dust (see also Sections & 5204)

10. Exposure Assessment-5204(d)
Required if exposures are or may reasonably be expected to be at or above action level of 25 µg/m3
Exposures assessments can be done following:
The performance option
The scheduled monitoring option
The standard requires employers to assess the exposure of any worker who may be exposed at or above the action level of 25 µg/m3 as an 8-hour time-weighted average.
The standard allows for two different approaches to exposure assessment: The performance option, and the scheduled monitoring option.

11. Performance Option-5204(d)
Exposures assessed using any combination of air monitoring data or objective data sufficient to accurately characterize employee exposure to respirable crystalline silica
The performance option provides flexibility for employers by allowing them to assess worker exposure based on any air monitoring data and/or objective data that is sufficient to accurately characterize worker exposure.
For example, under this option an employer could determine that there is no meaningful difference between the exposure of an employee in a certain job classification who performs a task in a particular work area on one shift and the exposure of another employee in the same job classification who performs the same task in the same work area on a different shift. In that case, the employer could characterize the exposure of the second employee based on the characterization of the first employee’s exposure.

12. Objective Data-5204(b)
Air monitoring data from industry-wide surveys or calculations based on the composition of a substance
Demonstrates employee exposure associated with a particular product or material or a specific process, task, or activity
Must reflect workplace conditions closely resembling or with a higher exposure potential than the processes, types of material, control methods, work practices, and environmental conditions in the employer's current operations
Objective data can come from a variety of sources. Examples of objective data include:
- Monitoring data obtained before the effective date of the standard;
- Measurements of respirable dust by direct-reading instruments, along with information on the crystalline silica content of the material; and
- Data from area sampling or area exposure profile mapping approaches.
For example, an employer could assume that all respirable dust is respirable crystalline silica, and could then use measurements of respirable dust using direct-reading instruments to determine workers’ respirable crystalline silica exposures.
The burden is on the employer to show that the exposure assessment is sufficient to accurately characterize employee exposures to respirable crystalline silica.
Employers may rely on objective data for meeting their exposure assessment obligations, even where exposures may exceed the action level or PEL.

13. Scheduled Monitoring Option-5204(d)
Prescribes a schedule for performing initial and periodic personal monitoring
If monitoring indicates:
Initial below the AL: no additional monitoring
Most recent at or above the AL: repeat within 6 months
Most recent above the PEL: repeat within 3 months
When two consecutive non-initial results, taken 7 or more days apart, are below the AL, monitoring can be discontinued
Reassess if circumstances change
The scheduled monitoring option provides a structured approach to assessing worker exposures.
Any requirements for additional monitoring are determined based on the results of previous monitoring.
The employer must reassess exposures whenever a change may reasonably be expected to result in new or additional exposures at or above the action level, or when the employer has any reason to believe that new or additional exposures at or above the action level have occurred.

14. Appendix A – Methods of Sample Analysis
Employers must ensure that samples are analyzed by a laboratory that follows the procedures in Appendix A
Appendix A specifies methods of sample analysis
Allows for use of OSHA, NIOSH, or MSHA methods
Analysis must be conducted by accredited laboratories that follow specified quality control procedures
Where monitoring is performed to comply with the standard, the employer must have samples analyzed by a laboratory follows quality control procedures specified in Appendix A of the standard.
Requiring laboratories to follow the procedures in Appendix A is intended to enhance the accuracy and consistency of air sampling results.

15. General Industry – Regulated Areas-5204(e)
Required where exposures can reasonably be expected to exceed the PEL
Must be demarcated in any manner that limits workers in the area
Post warning signs at entrances per 5204(j)(2)
Respirator use required for employees and employee’s designated representatives
Employers must establish a regulated area wherever worker exposures may exceed the PEL.
The employer must demarcate the regulated area, and can use whatever means is appropriate for the workplaces (e.g., cones, stanchions).
The standard specifies wording that must be included on signs to warn of hazards and required respirator use when in the area.
Anyone in the regulated area must wear a respirator, even if their TWA exposure will not exceed the PEL.
In response to commenters who argued that regulated areas are impractical in many situations in construction, regulated areas are not required under the construction standard. Employers must instead follow procedures for restricting access in the written exposure control plan (addressed later).

16. Methods of Compliance – Hierarchy of Controls-5204(f)
Employers can use any engineering or work practice controls to limit exposures to the PEL
Respirators permitted where PEL cannot be achieved with engineering and work practice controls
Employers must use engineering and work practice controls, to the extent feasible, to limit worker exposures to the PEL.
Employers can choose any engineering controls and work practices that are effective in their workplace.

17. Engineering Controls Grinding stone without engineering controls
The next few slides show examples of engineering controls being used to limit worker exposure to respirable crystalline silica.
The most common methods of limiting silica exposures are wet methods, where water is used to keep silica-containing dust from getting into the air, and vacuum dust collection systems, which capture dust at the point it is made.
Polishing stone using water to control the dust

18. Engineering Controls (cont.)
Grinding without engineering controls
Grinding using a vacuum
dust collector

19. Engineering Controls (cont.)
Jackhammer use without engineering controls
Jackhammer use with water spray to control dust

20. General Industry – Written Exposure Control Plan-5204(f)
The plan must describe:
Tasks involving exposure to respirable crystalline silica
Engineering controls, work practices, and respiratory protection used to limit exposure for each task
Housekeeping measures used to limit exposure
A written exposure control plan is intended help employers consistently control exposure by describing tasks resulting in exposure and controls for those exposures, as well as housekeeping measures.
The plans must be reviewed annually and updated as needed, and must be made available to employees, their designated representatives, OSHA and NIOSH.

21. Respiratory Protection-5204(g)
Must comply with Title 8, CCR, Section 5144
Respirators required for exposures above the PEL:
While installing or implementing controls or work practices
For tasks where controls or work practices are not feasible
When feasible controls cannot reduce exposures to the PEL
While in a regulated area (General Industry)
When respirator use is required, the employer must comply with OSHA’s respiratory protection standard and implement a respiratory protection program.
Respiratory protection is required when engineering and work practice controls are not sufficient to limit worker exposures to the PEL.

22. Housekeeping-5204(h)
When it can contribute to exposure, employers must not allow:
Dry sweeping or brushing
Use of compressed air for cleaning surfaces or clothing, unless it is used with ventilation to capture the dust
Those methods can be used if no other methods like HEPA vacuums, wet sweeping, or use of ventilation with compressed air are feasible
Certain cleaning methods, such as dry sweeping and use of compressed air, can contribute to worker exposure to respirable crystalline silica.
The standard restricts use of these cleaning methods.
Dry sweeping, dry brushing, and use of compressed air for cleaning are only allowed if other methods such as wet sweeping and HEPA-vacuuming are not feasible, or if a ventilation system is used to capture the dust cloud created by the compressed air.

23. General Industry–Medical Surveillance-5204(i)
Employers must offer medical examinations to workers who will be exposed above the action level for 30 or more days a year
Employers must offer examinations every three years to workers who continue to be exposed above the trigger
Exam includes medical and work history, physical exam, chest X-ray, and pulmonary function test (TB test on initial exam only)
Workers with high exposures to respirable crystalline silica must be offered medical examinations.
Medical surveillance is intended to identify cases of silica-related disease; identify health conditions that may place a worker at increased risk from exposure to respirable crystalline silica; and determine a worker’s ability to use respiratory protection.
Any worker who will be exposed above the action level for 30 or more days a year must be offered an exam initially and at least every three years.
The standard specifies the content of the exams.

24. Medical Opinion
Worker receives report with detailed medical findings, any work restrictions, and recommendations concerning any further evaluation or treatment
Employer receives an opinion that only describes limitations on respirator use, and if the worker gives written consent, recommendations on:
Limitations on exposure to respirable crystalline silica, and/or
Examination by a specialist
The medical information provided to the employer is different from that provided in other OSHA chemical-specific health standards.
The worker receives a full report from the physician or other health care professional who provides the exam.
The employer receives a written medical opinion that describes limitations on respirator use – any recommended limitations on the worker’s exposure to respirable crystalline silica, or any referral to a specialist, are only provided to the employer if the worker provides his or her written consent.
Workers, unions, and doctors objected to giving this information to the employer because many workers would not participate in medical surveillance because they feared employers would discriminate or retaliate against them due to their medical condition.

25. Communication of Hazards-5204(j)
Employers required to comply with hazard communication standard (HCS) (T8,CCR,Sec. 5194)
Address: Cancer, lung effects, immune system effects, and kidney effects as part of HCS
Train workers on health hazards, tasks resulting in exposure, workplace protections, and medical surveillance.
Hazard communication requirements are similar to those of other OSHA chemical-specific health standards.
Employers are required to comply with the requirements of OSHA’s hazard communication standard for labels, safety data sheets, and training.
Workers must be able to demonstrate knowledge and understanding of the training subjects.

26. Recordkeeping-5204(k) Must maintain records for: Air monitoring data
Objective data
Medical records maintained and made available per Section 3204
Employers are required to keep records of the exposure assessments and medical exams provided under the standard.

27. General Industry – Compliance Dates-5204(l)
Effective date to be established by OAL pending approval
Employers must comply with all requirements of the standard by June 23, 2018, except:
Medical surveillance for those employees exposed above PEL 30 or more days/year – June 23, 2018
Medical surveillance for those employees exposed above Action Level 30 or more days/year – June 23, 2020
Hydraulic fracturing operations in the oil and gas industry
must implement engineering controls to limit exposures to new PEL by June 23, 2021.
Implement medical surveillance per above dates
Employers are required to comply with most provisions of the standard by June 23, 2018.
Requirements for medical surveillance are phased in – workers exposed above the PEL for 30 or more days per year must be offered medical exams beginning on June 23, 2018; workers exposed at or above the action level for 30 or more days per year must be offered medical exams beginning on June 23, 2020.
Hydraulic fracturing employers are given additional time to implement engineering controls to achieve the new PEL in order to take advantage of further development of emerging technologies in the industry.

28. Construction Standard-1532.3
(a) Scope (b) Definitions (c) Specified exposure control methods OR (d) Alternative exposure control methods (1) PEL (2) Exposure Assessment (3) Methods of Compliance (e) Respiratory protection (f) Housekeeping (g) Written exposure control plan (h) Medical surveillance (i) Communication of silica hazards (j) Recordkeeping (k) Dates
The construction standard follows a new approach to give construction employers more flexibility in addressing circumstances in their industry while offering workers protections that are as effective as those provided in general industry and maritime.
Conditions in the construction industry warrant a standard that is somewhat different due to the transient nature of work, changing environmental conditions, common tasks where exposures to respirable crystalline silica are significant, and evidence on the effectiveness of controls needed to reduce exposures.
The key difference is the specified exposure control methods approach—a flexible alternative to the traditional approach of assessing exposures and complying with the PEL using engineering and work practice controls to the extent feasible.
Construction employers can follow either the specified exposure control methods or alternative exposure control methods.
The specified exposure control methods approach involves following Table 1, which specifies effective controls, work practices, and respiratory protection for 18 construction tasks. Employers who fully and properly implement controls on Table 1 are not subject to the PEL and are not required to assess exposures for employees engaged in those tasks.
If employers follow the alternative exposure control methods approach, they must comply with the PEL and provisions for exposure assessment. They must also follow the hierarchy of controls under methods of compliance.
All construction employers, regardless of which approach they follow, are required to comply with all the other provisions of the standard including respiratory protection, housekeeping, written exposure control plan, medical surveillance, training, and recordkeeping.
Other differences between general industry/maritime and construction include scope, written exposure control plan, medical surveillance and dates provisions.

29. Construction – Scope 1532.3(a)
All occupational exposures to respirable crystalline silica are covered, unless employee exposure will remain below 25 μg/m3 as an 8-hr TWA under any foreseeable conditions.
The construction standard exempts workplaces where employee exposure will remain below 25 μg/m3 as an 8-hour time-weighted average under any foreseeable conditions.
A difference compared to the general industry/maritime standard is that objective data is not required.
Examples of construction tasks that are not likely to create exposures exceeding 25 μg/m3 as an 8-hour time-weighted average include mixing mortar; mixing concrete for post holes; pouring concrete footers, slab foundation, and foundation walls; removing concrete formwork; compacting pavers or an aggregate base; and sweeping sand into paver joints.
Tasks that involve exposure to respirable crystalline silica for a very short period of time are also unlikely to produce exposures at or above 25 μg/m3 as an 8-hour time-weighted average. For example, an exposure for a task performed over a 15-minute period would have to exceed 800 µg/m3 for that 15 minute period before the 8-hour time-weighted average exposure would exceed 25 μg/m3.
In some cases where general industry/maritime activities are indistinguishable from construction tasks, employers can be in compliance with the rule if they fully implement the provisions of the construction standard rather than the general industry/maritime standard.
For example, some maintenance and repair tasks that may be considered to fall under the requirements for general industry, such as repair of electrical power lines, can be indistinguishable from construction tasks.
However, tasks performed in the same environment or conditions (for example, chipping out drums of ready-mix concrete trucks) are subject to the general industry standard – not the construction standard.

30. Construction – Definitions – 1532.3(b)
Action Level
Competent Person
HEPA Filter
Objective Data
PLHCP
Respirable Crystalline Silica
PLHCP – Physician or Other Licensed Health Care Professional

31. Construction – Specified Exposure Control Methods 1532.3(c)
Table 1 in the construction standard matches 18 tasks with effective dust control methods and, in some cases, respirator requirements.
Employers that fully and properly implement controls on Table 1 do not have to:
Comply with the PEL
Conduct exposure assessments for employees engaged in those tasks
9 out of 18 tasks list only the wet method as an engineering control
Table 1 in the construction standard lists common construction tasks known to generate high exposures to respirable crystalline silica, and identifies effective engineering controls, work practices, and respiratory protection for each task.
When following this approach, employers must fully and properly implement the specifications listed on Table 1 for each employee engaged in the task.
If they do this, they do not have to comply with the PEL or conduct exposure assessments.
This approach simplifies compliance by avoiding the challenge of characterizing exposures and determining the effectiveness of controls in changing environments and conditions, while ensuring that employers are using controls that will adequately protect workers.

32. Example of a Table 1 Entry
Equipment / Task
Engineering and Work Practice Control Methods
Required Respiratory Protection and
Minimum APF
≤ 4 hr/shift
> 4 hr/shift
Stationary masonry saws
Use saw equipped with integrated water delivery system that continuously feeds water to the blade.
Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions.
None
This slide shows an example of an entry on table 1.
If an employer with employees using stationary masonry saws fully and properly implements the controls specified in the second column, no respiratory protection would be required for employees engaged in that task, regardless of the duration of exposure.

33. Example of a Table 1 Entry
Equipment / Task
Engineering and Work Practice Control Methods
Required Respiratory Protection and
Minimum APF
≤ 4 hr/shift
> 4 hr/shift
Handheld power saws
(any blade diameter)
Use saw equipped with integrated water delivery system that continuously feeds water to the blade.
Operate and maintain tool in accordance with manufacturers’ instruction to minimize dust
When used outdoors
When used indoors or in an enclosed area
None
APF 10
This slide shows an example of an entry on table 1 that includes requirements for respiratory protection.
If an employer with employees using handheld power saws fully and properly implements the controls specified in the second column, no respiratory protection would be required for employees engaged in that task outdoors for four hours or less.
If employees use handheld power saws outdoors for more than four hours per shift, or indoors for any length of time, a respirator with an assigned protection factor of 10 would be required.

34. List of Table 1 Entries
Stationary masonry saws
Handheld power saws
Handheld power saws for fiber cement board
Walk-behind saws
Drivable saws
Rig-mounted core saws or drills
Handheld and stand-mounted drills
Dowel drilling rigs for concrete
Vehicle-mounted drilling rigs for rock and concrete
Jackhammers and handheld powered chipping tools
Handheld grinders for mortar removal (tuckpointing)
Handheld grinders for other than mortar removal
Walk-behind milling machines and floor grinders
Small drivable milling machines
Large drivable milling machines
Crushing machines
Heavy equipment and utility vehicles to abrade or fracture silica materials
Heavy equipment and utility vehicles for grading and excavating
This slide shows the 18 entries on Table 1
The table covers the most common tasks in construction that involve exposure to respirable crystalline silica.
9 tools list wet method as only option for controlling dust
5 tools list vacuum or dry method as sole control method
4 tools list both wet and dry controls as control methods

35. Fully and Properly Implementing Controls Specified on Table 1
Presence of controls is not sufficient.
Employers are required to ensure that:
Controls are present and maintained
Employees understand the proper use of those controls and use them accordingly
Provide means of exhaust for tasks in indoor or enclosed areas
For wet methods, apply sufficient water flow to minimize dust
Specific measures for tasks performed in enclosed cabs or booths
Two critical components of this approach are: fully and properly implementing controls; and identifying employees engaged in the task.
In order for an employer to be in compliance, the specified controls, work practices, and respiratory protection must be fully and properly implemented.
Mere presence of controls is not sufficient—employers are required to ensure that controls are properly maintained and used.
For example—for vacuum dust collection systems—the shroud must be intact and installed according to the manufacturer’s instructions; the hose connecting the tool to the vacuum must be intact or without kinks of tight bends that would prevent vacuum from providing sufficient air flow; the filter must be cleared or changed as frequently as necessary; and dust collection bags must be emptied as frequently as necessary.
For water systems—an adequate water supply must be provided; spray nozzles must not be clogged; and water must be applied at the point of dust generation or other specified location.
Resources for understanding full and proper implementation include manufacturer’s instructions; industry best practices; and the competent person.

36. Employees Engaged in Table 1 Tasks
Employees are “engaged in the task” when operating the listed equipment, assisting with the task, or have some responsibility for the completion of the task
Employees are not “engaged in the task” if they are only in the vicinity of a task
Employees engaged in the task include the tool operator and other employees who are assisting with the task (for example, a worker helping the operator of a walk-behind saw by guiding the saw and making sure that the cutting is precise).
For employees not engaged in the task, access must be limited according to procedures described in the written exposure control plan (to be discussed later).

37. Respiratory Protection Requirements on Table 1
Respirators required where exposures above the PEL are likely to persist despite full and proper implementation of the specified engineering and work practice controls
Where respirators required, must be used by all employees engaged in the task for entire duration of the task
Provisions specify how to determine when respirators are required for an employee engaged in more than one task
In addition to specifying controls and work practices, Table 1 includes respiratory protection requirements for some equipment/tasks.

38. Alternative Exposure Control Methods-1532.3(d)
For Tasks not listed in Table 1 or where employer does not implement engineering controls, work practices and respiratory protection specified in Table 1
Employer shall assess employee when reasonably expected be exposed at or above Action Level – 25 micrograms per cubic meter.
Performance option – air monitoring and objective data
Scheduled monitoring option
In addition to specifying controls and work practices, Table 1 includes respiratory protection requirements for some equipment/tasks.

39. Construction - Respiratory Protection-1532.3(e)
Must comply with Title 8, CCR, Section 5144
Respirators required
Per Table 1
When task not listed in Table 1
Where PEL is exceeded while installing or implementing controls or work practices
For tasks where controls or work practices are not feasible
When feasible controls cannot reduce exposures to the PEL
In addition to specifying controls and work practices, Table 1 includes respiratory protection requirements for some equipment/tasks.

40. Construction - Housekeeping-1532.3(f)
When it can contribute to exposure, employers must not allow:
Dry sweeping or brushing
Use of compressed air for cleaning surfaces or clothing, unless it is used with ventilation to capture the dust
Those methods can be used if no other methods like HEPA vacuums, wet sweeping, or use of ventilation with compressed air are feasible
Certain cleaning methods, such as dry sweeping and use of compressed air, can contribute to worker exposure to respirable crystalline silica.
The standard restricts use of these cleaning methods.
Dry sweeping, dry brushing, and use of compressed air for cleaning are only allowed if other methods such as wet sweeping and HEPA-vacuuming are not feasible, or if a ventilation system is used to capture the dust cloud created by the compressed air.

41. Construction – Written Exposure Control Plan-1532.3(g)
The plan must describe:
Tasks involving exposure to respirable crystalline silica
Engineering controls, work practices, and respiratory protection for each task
Housekeeping measures used to limit exposure
Procedures used to restrict access, when necessary to limit exposures
In addition to the requirements for the Written Exposure Control Plan for general industry/maritime employers, the plan for construction also requires a description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed to respirable crystalline silica and their level of exposure, including exposures generated by other contractors.
In construction, there is no requirement to establish regulated areas.
This provision is intended to limit exposures to employees who might otherwise work adjacent to tasks that involve high exposures to respirable crystalline silica dust.
Limiting access is necessary when workers are required to use respiratory protection for a task.
Construction employers will not need to constantly update the plan for new locations, as long as the plan addresses the tasks, control measures, and procedures used to restrict access at the location.
Must evaluate effectiveness annually

42. Construction – Competent Person-1532.3(g)(4)
Construction employers must designate a competent person to implement the written exposure control plan
Competent person is an individual capable of identifying existing and foreseeable respirable crystalline silica hazards, who has authorization to take prompt corrective measures
Makes frequent and regular inspection of job sites, materials, and equipment
Another difference between the written exposure control plan in general industry/maritime and construction is that the construction standard requires the employer to designate a competent person to make frequent and regular inspections of job sites, materials, and equipment to implement the written exposure control plan.
The competent person definition is similar to that in other OSHA construction standards. The competent person must have the knowledge and ability to implement the written exposure control plan.

43. Construction – Medical Surveillance-1532.3(h)
Employers must offer medical examinations to workers who will be required to wear a respirator under the standard for 30 or more days a year.
Employers must offer examinations every three years to workers who continue to be exposed above the trigger
Exam includes medical and work history, physical exam, chest X-ray, and pulmonary function test (TB test on initial exam only)
The trigger for medical surveillance in the construction standard is different than in the general industry/maritime standard.
The requirement to offer medical exams is triggered by required respirator use for 30 or more days per year under the construction standard because most employers will be using Table 1 and will therefore not have exposure assessments to determine if workers are exposed above the action level.

44. Communication of Hazards-1532.3(i)
Employers required to comply with hazard communication standard (HCS) (T8,CCR,Sec. 5194)
Address: Cancer, lung effects, immune system effects, and kidney effects as part of HCS
Train workers on health hazards, tasks resulting in exposure, workplace protections, and medical surveillance.
Hazard communication requirements are similar to those of other OSHA chemical-specific health standards.
Employers are required to comply with the requirements of OSHA’s hazard communication standard for labels, safety data sheets, and training.
Workers must be able to demonstrate knowledge and understanding of the training subjects.

45. Recordkeeping-1532.3(j) Must maintain records for: Air monitoring data
Objective data
Medical records maintained and made available per Section 3204
Employers are required to keep records of the exposure assessments and medical exams provided under the standard.

46. Construction – Compliance Dates-1532.3(k)
Effective date established upon approval of OAL
Employers must comply with all requirements (except methods of sample analysis) by June 23, 2017
Compliance with methods of sample analysis required by June 23, 2018
Employers have until June 23, 2017 to comply with most provision of the construction standard.
Controls for most construction tools are readily available and can be quickly adopted.
Most construction employers are expected to use Table 1 and will not need to measure worker exposures to respirable crystalline silica.
Employers who measure employee exposures have until June 23, 2018, to use laboratories that follow the procedures for sample analysis in Appendix A of the standard.

47. Current Applicable Standard – Dust-Generating Operations-1530.1
Use of powered tools & equipment
Cutting, grinding, drilling, coring concrete or masonry materials
Specific requirements for dust reduction systems

48. Exception to Dust-Generating Operations-1530.1
Stucco, plastering material or similar products
Wall cladding, siding or similasr products
Downward drilling
Incidental jack-hammering or drilling
Using powder-actuated tools
Incidental work such as drilling holes for plumbing fixtures
Tile backer boards cut with powered shears or dust reduction blade with dust containment device

49. Guidance and Outreach
Hazards of Silica Construction etool:
Guidance and outreach materials are available on OSHA’s silica rule webpage.
An appendix to the standard provides guidance for physicians and other health care professional who provide medical examination for workers exposed to respirable crystalline silica under the standard.
OSHA also expects to publish small entity compliance guides for general industry/maritime and construction around the middle of this year.

50. Questions?