Sources: Construction Industry Safety Coalition, Associated Builders & Contractors, Washington, D.C.; CP staff
The 26-member Construction Industry Safety Coalition (CISC) has formally requested the Occupational Safety and Health Administration revise the Occupational Exposure to Respirable Crystalline Silica – Specified Exposure Control Methods standard (silica rule), thereby expanding compliance options and recognizing sub-threshold dust levels typical of masonry sawing and mortar mixing.
Coalition members represent groups touching nearly every trade and include the Interlocking Concrete Pavement Institute, American Society for Concrete Contractors and Concrete Sawing & Drilling Association. CISC outlined a case for silica rule revisions in response to OSHA’s mid-August request for information surrounding potential changes to Table 1, which prescribes compliance actions for a range of conditions or tasks exposing construction and general industry workers to respirable crystalline silica.
“Expanding Table 1 and otherwise improving compliance with the rule is of paramount importance to member associations and contractors across the country,” CISC tells OSHA Principal Deputy Loren Sweatt. “Based upon feedback from contractors, both large and small, compliance with the rule remains challenging … Allowed controls are too limiting and the tasks included do not represent the wide range of activities that are commonplace on construction worksites.”
Excluding mortar mixing and drywall installation/finishing, both common tasks where data proves “exposures are consistently and reliably below the action level,” would position contractors to focus “resources where exposures to respirable crystalline silica are apparent and potentially significant,” writes CISC. The agency should consider adding to Table 1 “an ‘under one hour’ column/row or an ‘under one hour’ table that provides for 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. The Council also calls on OSHA to:
- Add masonry scrubbers, wire saws, and wall saws, plus dry cutting with vacuum attachments for stationary masonry saws and handheld power saws. Data for the latter two shows exposures with the attachments as controls are under the permissible exposure limit;
- Allow for the use of standard shop vacuums as part of engineering controls, based on recent National Institute for Occupational Safety and Health data; and,
- Consider an exception to the prohibition on dry sweeping and dry brushing for employees performing such work for less than 30 minutes and where the employees do not have any other exposure to respirable crystalline silica.
“The Agency should standardize a process, which establishes set criteria and relies on interim final rulemaking, to update and expand Table 1 in the future,” CISC concludes. “This proposed process will allow for expeditious changes to push and recognize technological improvements.”
After reviewing request for information responses, OSHA will potentially publish proposed silica rule revisions in the Federal Register, solicit public comment, and proceed with a rulemaking to support an expanded Table 1.