New OSHA rule for respirable silica goes into effect beginning June 23
Overland Park, Kan.—It squishes between your toes, grittily yielding to the pressure of your bare feet. It’s the essence of a sunny, carefree day at the beach or youthful play in a sandbox. But much of what makes up sand can make workers sick — and even kill them, when it’s broken down into extremely fine particles and inhaled.
It’s silica, the main component of sand and the second-most common mineral in the world, found even in soil and household dust and present in a number of types of abrasive media. Workers breathing in respirable silica — dust particles small enough to be inhaled deeply into the lungs — can develop silicosis, a serious and irreversible lung disease. And according to a fact sheet from the Occupational Safety and Health Administration (OSHA), “The dust has also been linked to other serious illnesses, including cancer, and is known to aggravate other conditions, including tuberculosis, emphysema, and chronic obstructive pulmonary disease.”
OSHA has released its final rule regulating respirable silica, which goes into effect June 23, although affected industries have from between one and five years from that date to take corrective action. (Collision repair and restoration shops, which fall under general industry, will have until June 23, 2018, to meet the more stringent rule.)
The new rule cuts the permissible exposure limit (PEL) to 50 micrograms of respirable crystalline silica per cubic meter of air, averaged over an eight-hour work shift. Compared to the previous rule, in place since 1971, that figure is half of what was previously allowed for general industry, and is only 20 percent of what was previously allowed for construction and shipyards.
Colette Bruce, owner of Team Safety LLC, a consultant company that specializes in employee safety and environmental compliance for the collision repair industry, said the new regulation is focused more on the construction industry, unless a shop is blasting with a material that does contain crystalline silica. Crystalline silica is largely a non-issue for body repair sanding, as long as workers wear properly fitted respirators, she said. Collision repair, refinishing, and restoration shops using abrasive blasting should especially make sure they employ measures to protect their workers from exposure. Once it is determined the blasting material contains crystalline silica, the shop must undergo the proper exposure monitoring, according to the standard.
“I visit shops with sandblasting equipment, and some have that carbon black sandblasting media, glass, or other media that can be used for blasting. But a lot still use crystalline silica,” she said.
Bruce said she recommends that shops switch to a media that does not contain crystalline silica, although depending on what coatings are being removed or the surface profile desired, that may not always be a practical option. If the shop continues to use media with crystalline silica, it should have a company such as Team Safety measure the worker’s exposure through air sampling equipment consisting of a belt-worn pump and an intake cartridge placed on the worker’s collar, near his breathing zone and outside of any respiratory protection, she said.
“If OSHA walks in and sees sandblasting equipment and the materials in the shop, they’re going to inquire,” Bruce said. “So you can’t say, ‘We’re not using it,’ unless you lock it out or put a sign on it and get rid of the materials. They are going to expect the shop has established a baseline for exposure.”
Whether or not the media contains crystalline silica will be clearly noted on the bag’s label, as well as listed on the safety data sheet for the product, Bruce said.
Shops using engineering controls such as blasting cabinets are not necessarily exempt from the rule, Bruce said.
“It’s not open blasting, but to be on the proactive side, I would still conduct the analysis to make sure there’s nothing coming from any of those armhole glove inserts, because those do open up, to a certain degree,” she said. “I am being the devil’s advocate. One OSHA compliance officer may come up and say, ‘No, that’s self-contained.’ Another may say, ‘How do you know?’”
The rule also requires employers to limit worker access to high-exposure areas, develop a written exposure control plan as well as offer medical exams to highly exposed workers, and train workers on silica risks and how to limit exposures.
Respiratory protection essential
The type of respiratory protection required varies, depending on the exposure, Bruce said, although a powered air-purifying respirator or supplied air respirator will provide the best worker comfort and protection for prolonged exposure. Wearing a protective suit will keep the worker from wearing dusty clothes home and exposing family members to it, she added.
Safety Data Sheets deadline is June 1
In related news, Bruce said by June 1 all Safety Data Sheets on file, either paper or electronic, must be in the new SDS format, replacing the former Material Safety Sata Sheets (MSDS) format. The new format was designed to be easier to understand, and since Dec. 1, 2015, manufacturers, importers, distributors, and employers have been required to use product labeling conforming to the United Nations-developed Globally Harmonized System (GHS) of communication, which features pictograms depicting the hazards of that product.
Although Bruce said shops are free to use up products with the old labeling, she also gave a reminder that “secondary labels” should be used on spray bottles and paint cups to mimic what is on the bulk container.
“Shops need to make a complete list of their chemicals and have a corresponding SDS for each one of them,” she said, noting that although for the shops she serves, there are a few counties that insist on paper copies stored in a binder in the shop, OSHA is satisfied with either local electronic documents (on a shop’s computer, not accessed by Internet) or a fax-on-demand service, as supplied by Safety-Kleen.
Bruce recommends that shops create an icon with an SDS folder on the computer, the more accessible the better, such as in a parts room computer. The computer can be in the office, but signs directing personnel to where to find the SDS should be in the shop.
“OSHA will always ask the employees, ‘How do you find the SDS for this product?’” she said. “It’s good to test your employees by bringing them a product and asking them to ‘Find me the SDS for that.’”