Understand The OSHA Respirable Crystalline Silica Rule In 4 Steps:
STEP 1:
GAIN A BASIC UNDERSTANDING OF OSHA AND WHY BREATHABLE SILICA DUST IS A HEALTH ISSUE:
The Occupational Safety and Health Administration (OSHA) is a national public health agency that is part of the United States Department of Labor. OSHA assures safe and healthful working conditions by setting and enforcing standards and by providing training, outreach, education, and assistance. The agency continuously seeks to rid workspaces of silica dust.
Silica is microscopic dust hidden inside visible dust clouds created by concrete and masonry work. Silica exposure can cause debilitating respiratory diseases like silicosis and lung cancer. In 2017, OSHA updated regulations to further limit worker exposure to silica to create cleaner and safer workspaces. According to OSHA.gov: “The standard provides flexible alternatives, which OSHA expects will be especially useful for small employers. Employers can either use the control methods laid out in Table 1 of the construction standard, or they can measure workers’ exposure to silica and independently decide which dust controls work best to limit exposures…”
Read the entire OSHA regulation here: https://www.osha.gov/dsg/topics/silicacrystalline/
By understanding the regulation’s “Table 1” guidelines, you’ll find information about using proper industrial vacuum systems, water, and/or following tool manufacturers’ instructions when working with surface preparation and sawing equipment that will help satisfy the new OSHA rules. See “Table 1” definition in Step 2.
STEP 2:
UNDERSTAND AND FOLLOW THE OSHA RESPIRABLE CRYSTALLINE SILICA RULE’S “TABLE 1”:
Accompanying the OSHA respirable crystalline silica rule is “Table 1,” which lists many Equipment/Tasks that commonly produce breathable silica dust. In every example, the information provided includes:
- Equipment/Task (The tool or the job being performed)
- Engineering and Work Practice Control Methods (what to do to limit exposure to breathable silica dust for the tool or the job being performed)
- Required Respiratory Protection (states if a respirator is required at any time during each Equipment/Task).
Essentially, Table 1 outlines how OSHA requires workers to eliminate silica.
Many of the Table 1 Engineering and Work Practice Control Methods contain this practice: “Operate and maintain tool in accordance with the manufacturer’s instructions to minimize dust emissions.” This broad statement basically directs Employers/Workers to follow what tool manufacturers instruct to contain dust when using their products. Employers/Workers/Rental Businesses who properly follow these directions, maintain clean workspaces, and follow any other Table 1 requirements should not have to monitor air and will be assumed to be below the permissible exposure limit.
OSHA requires manufacturers to offer products that minimize silica and to instruct users on how to use these products properly. It is the responsibility of workers to use the instructions properly and fill out Written Exposure Control Plans. See WECP definition and how EDCO instructs workers on how to minimize dust emissions in Step 3.
STEP 3:
UNDERSTAND AND USE AN OSHA WRITTEN EXPOSURE CONTROL PLAN:
Following Table 1 helps create safe workspaces, but it doesn’t prevent an OSHA inspector from visiting a job site where an equipment/task could produce breathable silica dust. If OSHA visits a job site, it will expect to see a completed Written Exposure Control Plan. The WECP is a simple OSHA form that documents a plan for all equipment being used or task being performed.
The document includes:
- Description of Task (The job being performed)
- Control Description Controls (Summary of equipment and dust control methods used)
- Work Practices (Ways to help equipment work properly)
- Respiratory Protection (Specifies if a respirator is needed, per Table 1)
- Housekeeping (Maintenance and Cleaning needs for the specific job)
Rental Companies: Offering the Written Exposure Control Plan with proper dust suppression equipment gives your business accountability, putting it within compliance. The WECP protects from liability and spreads respiratory education.
Contractors: Filling out the Written Exposure Control Plan and using proper dust suppression increases respiratory health and avoids job site shutdowns. Proper WECP documentation is needed for both rented and owned equipment.
EDCO Has Created Written Exposure Control Plans for its Products:To help rental companies, end-users, and contractors, EDCO has created WECP forms for every piece of EDCO equipment that has a dust port. In every specific WECP is all OSHA required information: A) Machine model number, B) Type of product, and C) The EDCO vacuum the manufacturer of that product recommends for that model (EDCO recommends either a Vortex-200 or Vortex-290 because they capture airborne contaminants at an OSHA acceptable level). Rental companies should give forms to their end-user customers. End-user customers need to simply add names, company, etc. EDCO recommends working wet with products that do not have dust ports.
STEP 4:
USE THESE EDUCATION RESOURCES ON SILICA PREVENTION:
Achieving steps 1, 2, and 3 will create a basic understanding of 1) how the OSHA Respirable Crystalline Silica Rule creates safer workspaces, 2) following Table 1, and 3) filling out the proper paperwork. A single webpage, however, cannot explain everything about the regulation. Use the below resources to gain a broader understanding of this topic. The resources include many details on the regulation — videos, audio, how EDCO vacuums meet and exceed the OSHA regulation — and advice for rental businesses on how to profit with industrial vacuum systems.
How EDCO Vacuum Systems Comply: EDCO Vacuums and Construction Products are designed to meet and exceed the OSHA regulation. This graph shows how EDCO is in compliance with each OSHA “Table 1” provision.
EDCOed.com Vacuum Systems Certification Track: EDCOed.com is our 24/7 training resource. Register for free to access a variety of training, including a vacuum systems course that supplies everything you need to know about complying with the silica regulation when working with EDCO-type equipment.
Video: Interview about Silica and OSHA: Conversation between EDCO Vice President of Operations Jason Stanczyk and Rental Management Magazine Editor Wayne Walley. They discussed the regulation, how manufacturers have updated products to comply, how workers should comply, and how rental businesses can profit from offering vacuum systems.
Podcast: RentalEquip Talk Radio Episode: Conversation between EDCO Vice President of Operations Jason Stanczyk and RentalEquip Talk Radio host Donald Charbonet. They discussed what the OSHA regulation contains, how rental businesses should comply, and how rental businesses can profit from offering vacuum systems.
Articles: When The Dust Settles and Protecting People From Silica Dust: Both of these Rental Management Articles combine advice from several equipment manufacturers on silica prevention and offer additional safety resources for rental businesses and workers using the tools. Articles begin on page 44
Video: Industrial Vacuum Systems vs Shop Vacs: A common misconception is that industrial vacuums systems and common shop vacs capture the same volume of dust and debris. This is misguided. Shop Vacs do not offer the kind of filtration needed to meet OSHA Silica regulations. Watch this video to see why.
EDCO & THE OSHA RESPIRABLE CRYSTALLINE SILICA RULE:
EDCO believes the updated OSHA Silica regulation creates safer workspaces and healthier work habits. OSHA pushes all manufacturers to provide safe products and educate users on safe work practices while pushing workers to follow those instructions. We support OSHA’s efforts and aim to help spread safety knowledge. EDCO dust shrouds and our industrial vacuum systems both exceed the OSHA standard. Please operate EDCO equipment per the instructions in the completed Written Exposure Control Plans provided in Step 3 and review the training information in Step 4.