at the initial exam) and any other tests deemed necessary by a health- care professional will be taken. Tese exams must be completed within 30 days of initial assignment to a job with exposures over the action level or PEL, and at least every three years but even more frequently if a health- care professional recommends this.
Hazard Communication Information about the health
OSHA wants metalcasters to follow its hierarchy of controls.
hazards of respirable crystalline silica should already be provided through your company’s hazard communi- cation program but the respirable crystalline silica standard has some additional requirements. Training must include informa-
‘‘unless’’ clause indicates the employer bears the burden of show- ing a cleaning method is not feasible in a particular situation, and OSHA expects the vast majority of opera- tions will use HEPA vacuuming or wet methods that minimize the likelihood of airborne dust expo- sure. Similarly, where compressed air is used to clean clothing and surfaces without a ventilation system designed to capture the dust cloud created, the employer must be able to demonstrate no alternative cleaning method is feasible.
Written Exposure Control Plans
Tese plans are performance based and meant to establish and implement what a facility intends to do to control airborne respirable crystalline silica exposure. Te plans must be prepared even if there are no exposures exceed the action level or PEL. Plans must include a descrip- tion/identification of all tasks with respirable crystalline silica exposure, a description of controls and protec- tive measures (engineering, work practice and respiratory protection) used for each identified task, and a description of housekeeping mea- sures used to limit exposure. These must be annually
reviewed and updated, and met- alcasters need to make their plan readily available to employees and
34 | MODERN CASTING December 2016 their representatives and OSHA.
Medical Surveillance Medical surveillance will eventu-
ally apply to all employees working in jobs over the action level for more than 30 days per year. Te purpose of these programs is to identify silica related problems at early stages so intervention can be done, determine if employees can continue to be exposed to silica and determine an employee’s fitness to wear a respirator. Examinations must be offered at no cost and at a convenient time and place to the employee. Te exams will look into medical
and work history and include a physi- cal exam. Chest X-rays, pulmonary function tests, a tuberculosis test (only
tion about silica’s specific health effects. Signs must be posted at entrances to regulated areas. Employees exposed over the AL must demonstrate that they under- stand the hazards, the tasks where exposure occurs, measures to be taken to protect themselves, the provisions of the OSHA Standard, and the purposes and description of the medical surveillance program. Facilities must make a copy of the OSHA Respirable Crystalline Silica standard available to employees.
Tis article was adapted from a presentation given in November at an AFS silica compliance conference. Future seminars will be held January 9-10 in Arlington, Texas, and April 27-28 in Milwaukee. Go to
www.afsinc.org for more information.
Companies are required to
demarcate the area, post a sign with specific wording at entrances to the area, and limit access to these areas. Everyone entering the Regulated Area must wear a respirator.
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