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What you need to know about the new respirable crystalline silica NEP

March 23, 2020
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If your employees are exposed to respirable crystalline silica, be aware — you’ll want to ensure that your safety program is in compliance with the OSHA Respirable Crystalline Silica Standard.

Nearly four years after the OSHA Respirable Crystalline Silica Standard for general industry and maritime (29 CFR 1910.1053) and construction (29 CFR 1926.1153) took effect, the agency has issued a revised National Emphasis Program (NEP). Here’s a review of what the NEP is and how your business can prepare for compliance and inspection.

What is the NEP?

The recently issued NEP clarifies and updates 2016 OSHA guidelines that lowered permissible exposure to respirable crystalline silica (RCS) for general industry, maritime and construction.

On Feb. 4, 2020, OSHA issued a revised NEP to identify and reduce or eliminate worker exposures to respirable crystalline silica in general industry, maritime and construction. The NEP targets specific industries expected to have the highest exposures to silica and focuses on enforcement of the new silica standards.

The former NEP for respirable crystalline silica was released in 2008 and was later canceled in 2017. The following changes were made to the 2020 NEP:

  • Application was revised to the lower permissible exposure limit for respirable crystalline silica of 50 micrograms per cubic meter (µg/m3) as an eight-hour time-weighted average.
  • The list of target industries was updated, as shown in the appendix of the NEP; from this list, area offices will develop randomized establishment lists of employers in their local jurisdictions for targeted inspections.
  • Compliance safety and health officers will refer to current enforcement guidance for RCS inspection procedures.
  • All OSHA regional and area offices must comply with this NEP, but they are not required to develop and implement corresponding regional or local emphasis programs.
  • State plans must participate because of the nationwide exposures to silica.

Before starting inspections, OSHA will conduct 90 days of compliance assistance for stakeholders.

How to prepare for compliance and inspection

OSHA is set to begin inspections under the NEP on May 5, 2020. If your business is in a targeted industry, you must ensure you are in compliance with the OSHA Respirable Crystalline Silica Standard and prepare for possible inspection. The OSHA Respirable Crystalline Silica Standard requires employers to:

  • For general industry, assess employee exposures to silica if it may be at or above an action level of 25 µg/m3, averaged over an eight-hour day, and protect workers from respirable crystalline silica exposures above the permissible exposure limit (PEL) of 50 µg/m3, averaged over an eight-hour day.
  • For the construction industry, employers can either use the control methods laid out in Table 1 of the construction standard, or they can measure workers' exposure to silica and independently decide which dust controls work best to limit exposures to the PEL in their workplaces.
  • A written exposure control plan must be established and implemented; it should identify tasks that involve exposure and methods used to protect workers, including limiting workers’ access to areas where they could be exposed above the PEL.
  • Medical exams must be offered — including chest X-rays and lung function tests — within 30 days of initial assignment and every three years for workers exposed at or above the action level for 30 or more days per year for general industry and for workers who are required by the standard to wear a respirator for 30 or more days per year for the construction industry.
  • Workers must be trained on work operations that result in silica exposure and ways to limit exposure.
  • Records must be kept of exposure measurements, objective data and medical exams.

Resources for respirable crystalline silica

Don’t forget that we have industrial hygienists on staff who can assess employee exposure to RCS at your job site. We also offer complimentary J.J.Keller training materials specific to crystalline silica for general industry and construction.

The Center for Construction Research and Training offers an online tool to create your own written exposure control plan. The site also contains training resources for hazard recognition, manuals and guides, presentations, toolbox talks, fact sheets, handouts, and videos.

For more information on protecting your employees from the hazards of respirable crystalline silica at your worksite, please contact us at safetyoncall@pinnacol.com.

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