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WASHINGTON ALERT


Stephanie Salmon, AFS Washington Office; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C. OSHA Finalizes Crystalline Silica Rule


THE RULE, WHICH HAS BEEN ONE OF THE AGENCY’S TOP PRIORITIES, LOWERS THE PEL FROM THE CURRENT STANDARD OF 100 MICROGRAMS PER CUBIC METER TO 50 MICROGRAMS OF SILICA PER CUBIC METER, WITH AN ACTION LEVEL OF 25 OVER AN EIGHT-HOUR TIME PERIOD.


On March 24, the U.S. Department of


Labor’s Occupational Safety and Health Administration (OSHA) finalized its workplace exposure standard for crystal- line silica (quartz) for general industry that would sharply reduce the existing permissible exposure limit (PEL). Te rule, which has been one of


the agency’s top priorities, lowers the PEL from the current standard of 100 micrograms per cubic meter to 50 micrograms of silica per cubic meter, with an action level of 25 over an eight-hour time period. It provides two years to come into compliance. Te rule also requires metalcasting facilities to implement a wide variety of administration and engineering controls, including requirements for initial and periodic exposure assess- ments, regulated and restricted work areas, engineering and work practice exposure controls, respiratory protec- tion, employee medical surveillance, employee training and recordkeeping. Specifically, the rule requires em-


ployers to develop a written exposure control plan. In addition, OSHA’s final rule mandates a hierarchy of control measures requiring installation of en- gineering and workplace controls, even if not effective, over the use of personal protective equipment (PPE) such as respirators, and it continues to bar job rotation as a method of attaining compliance with the new PEL. Te new rule, which is effective


June 23, 2016 and must be fully imple- mented by June 23, 2018, has multiple provisions and requirements that are summarized here.


Housekeeping Prohibits use of compressed air,


dry sweeping, and dry brushing unless other methods are not feasible.


Methods of Compliance/ Engineering Controls


Engineering/work practice con-


trols must be used to reduce/maintain employee exposure to silica to or below


14 | MODERN CASTING April 2016


the PEL, unless the employer can demonstrate that such controls are not feasible. Wherever such feasible engineering/work practice controls are not sufficient to reduce employee exposure to or below the PEL, the employer must use the controls to reduce employee exposure to the low- est feasible level and supplement them with respiratory protection.


Air Monitoring Employers must assess the exposure


of each employee at or above the ac- tion level using the following options: • Performance Option: Assess the 8-hour TWA exposure for each employee on the basis of any combination of air monitoring data or objective data sufficient to characterize employee exposures to crystalline silica.


• Scheduled Monitoring Option • Perform initial monitoring to assess the 8-hour TWA exposure for each employee on each shift, for each job classification, in each work area. Where several employ- ees perform the same tasks on the same shift and in the same work area, the employer may sample a representative fraction of these employees by sampling the employee(s) who are expected to have the high- est exposure.


• If initial monitoring indicates employee exposures are below the action level, the employer may discontinue monitoring for those employees.


• Where employee exposures are at or above the action level but at or below the PEL, the employer shall repeat such monitoring within 6 months.


• Where employee exposures are above the PEL, the em- ployer shall repeat such moni- toring within three months. • Where the most recent (non-


initial) exposure monitoring indicates employee exposures are below the action level, the employer must repeat such monitoring within six months of the most recent monitor- ing until two consecutive measurements, taken seven or more days apart, are below the action level, at which time the employer may discontinue monitoring for those employ- ees, except in certain circum- stances. Current respirable dust sampling equipment (pumps and cyclones) can be used to assess exposures.


Respiratory Protection Respiratory protection is required


where exposures exceed the PEL during periods necessary to install or implement feasible engineering and work practice controls; where expo- sures exceed the PEL during tasks, such as certain maintenance/repair tasks, where engineering and work practice controls are not feasible; and during tasks for which an employer has implemented all feasible engi- neering and work practice controls and such controls are not sufficient to reduce exposures to or below the PEL. Respirators are also required in regulated areas.


Written Exposure Control Plan Employers must develop a written


exposure control plan. Te plan must contain the following elements: • Description of tasks in work- place that involve exposure to silica.


• Description of engineering controls, work practices, and respiratory protection used to limit employee exposure to silica for each task.


• Description of housekeeping measures used to limit employee exposure to silica.


• Employer must review and evalu-


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