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ABC Submits Comments on OSHA’s Silica Standard for Construction

On Oct. 15, ABC submitted comments as part of the Construction Industry Safety Coalition on the Occupational Safety and Health Administration’s Request for Information on Table 1 of the agency’s Respirable Crystalline Silica Standard for Construction.

According to an OSHA news release, the agency is seeking feedback on its current and any additional engineering and work practice control methods to effectively limit exposure to silica for the equipment and tasks currently listed on Table 1 and other construction equipment and tasks that generate silica that it should consider adding to Table 1.

“CISC applauds the agency for issuing this RFI and has been pushing the agency to do so for more than two years. Expanding Table 1 and otherwise improving compliance with the rule is of paramount importance to CISC member associations and contractors across the country. Based upon the feedback the CISC has received from contractors—both large and small—compliance with the rule remains challenging. CISC encourages OSHA to move quickly with rulemaking to permit contractors additional compliance options and tools,” according to the comment letter.

Additionally, CISC urged OSHA to consider the following improvements to the respirable crystalline silica rule:

  • Exclude from coverage in the standard two common construction tasks where the data shows that exposures are consistently and reliably below the action level: mortar mixing and drywall installation/finishing.  Requiring contractors to focus compliance resources in these areas given the very low exposures detracts from focusing those same resources where exposures to respirable crystalline silica are apparent and potentially significant.
  • Expand Table 1 in three ways:

1. Add an “under one hour” column, row or table that provides equipment/tasks and controls for short-term activities. Such an allowance would provide contractors more flexibility and increase the number and types of control options available.

2. Add dry cutting with vacuum attachments to Table 1 for stationary masonry saws and handheld power saws, as the data shows that exposures to this equipment with these controls are under the PEL. OSHA should also allow for the use of standard shop vacuums as part of engineering controls, based on recent data from the National Institute for Occupational Safety and Health.  In addition, OSHA should explore the use of floor and pedestal fans and air scrubbers as simple compliance solutions either on their own or in conjunction with other control measures.

3. Add masonry scrubbers, wire saws and wall saws to Table 1 based on data showing low exposures when using this equipment.

  • Examine additional changes to the standard that will ease compliance while maintaining employee safety and health. This includes an exception to the hierarchy of controls for tile cutting on steep slope roofs, given the greater hazards posed by using engineering controls in this environment. In addition, OSHA should permit the use of respiratory protection in lieu of engineering and work practice controls for very short duration work (under 30 minutes) when isolated from other employees. Similarly, OSHA should consider an exception to the prohibition on dry sweeping and dry brushing for employees performing that work for less than 30 minutes and where the employees do not have any other exposure to respirable crystalline silica.

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