OSHA has essentially outlined two control method options:
- Option 1: Follow the provided “Table 1” control procedures for the associated job activities and you do not have to comply with the air monitoring requirement section of the standard.
- Option 2: Do not follow “Table 1” and perform air sampling for all necessary job activities to prove your job specific control practice with factual documentation.
To further breakdown these options, below are the pros and cons for a realistic working construction environment:
Option 1 (Table 1):
- Best available practice for exposure control.
- OSHA compliance without the need for air sampling documentation.
- The activity and control is listed for you, no need to perform “guess and check” implementation of a control to see if it works.
- Unrealistic in an ever-changing construction environment.
- If an OSHA inspector found you out of “Table 1” compliance you would be in violation of numerous applicable air monitoring standards.
- “Cookie cutter” job activities listed. Any variation may put you out of compliance with “Table 1” in the eyes of an OSHA inspection.
- Full lab documentation to directly prove the reasoning behind your procedure and associated control method.
- Full job activity and control method customization if the OSHA PEL and standard is satisfied.
- Costly & time-consuming air sampling and lab analysis.
- Any variation will need to be sampled do have the documentation to prove exposure is controlled.
In the end the best control methodology would be to utilize option 1 (Table 1) as a starting point or best practice and follow up with option 2 as seen necessary. Air sampling should be performed for every “variation” or non-Table 1 listed job activity and control method out in the field. This way, If your job activity or control method diverges from “Table 1”, you have the documentation necessary to prove to an OSHA inspector that you are in compliance.
The other large change in control methodology, is the standard integration of the hierarchy of controls.
Engineering controls ▶ Administrative controls ▶ Personal Protective Equipment
Controlling respirable silica dust exposure will have to be done in this order.
For example, to use a cut-off saw to cut block in half, the operator would have to use water during the cutting operation before being able to use a respirator.
To further break this down this example:
Step one to controlling exposure (engineering control) – Water hook-up to the wet saw. This prevents the dust from becoming airborne.
Step two to controlling exposure (administrative control) – Employee hazard training specific to the material, tools, and controls. This includes worker changeover. Worker changeover prevents one worker from cutting all the block and receiving a potentially higher exposure.
Step three to controlling exposure (personal protective equipment control) – Respirator with respirable particulate cartridges will be used. This prevents particulate from entering the lungs (if properly used and in good working condition).
These approaches to controlling exposure would have to be used in that order. Even if the “higher control” does not bring the worker exposure below the OSHA PEL, it will have to be used in addition to the “lower control”. If the controls are not used in that order or the superintendent/foreman/worker deems an engineering control not feasible, they will have to justify “why” to an OSHA inspector. In this case, “there is no water source” or “the pump on my saw is broken” will not be reasonable excuses to not use engineering controls. This would correspondingly create a willful fine scenario; as the person(s) knew the control they needed to implement and instead purposely used a different (less satisfactory) control. In this case, the common excuse of “I didn’t know” would merely indicate that you have not had your respirable silica dust training required by the standard, resulting in a potentially higher fine.
While these new changes may seem excessive to those out in the field, the changes come after seeing years of workers permanently suffering due to inadequate controls. These standard changes are there for the worker’s safety. Respirable silica dust is an unforgiving health hazard. The consequences may not take effect immediately, but after repeated exposure it can be a crippling blow to a bright future.