The reporting requirements are complex.

An excellent article in California Construction Law Blog by Garret Murai outlines the compliance requirements established under OSHA’s Respirable Crystalline Silica in Construction Standard that went into effect on October 23, 2017.

The rules are designed to protect workers who work with “materials like sand, stone, concrete, and mortar [that] contain crystalline silica…Respirable crystalline silica–very small particles at least 100 times smaller than ordinary sand—is created when cutting, sawing, grinding, drilling, and crushing stone, rock, concrete, brick, block, and mortar.”

Testing has proven that inhaling crystalline silica can cause “silicosis, lung cancer, chronic obstructive pulmonary disease, and kidney disease.”

OSHA has created guidelines that explain the procedures contractors must implement to record and report employee exposure to respirable silica. They are complex.

“The Construction Silica Standard requires employers to limit exposure to respirable crystalline silica and provides two compliance alternatives:”

1. The control method requires employers to provide protection for employees doing specific tasks. OSHA has created a Table that lists “18 different tasks and equipment” and lists “work practice controls…and respiratory requirements broken down into shifts of less than 4 hours and more than 4 hours.”
2. The assessment method records the amount of exposure employees experience over given time periods. This method must be implemented if the control method is not used. Compliance using the assessment method is complicated and requires extensive testing and paperwork. Employers must establish testing procedures that allow them to record the amount of respirable crystalline silica employees are exposed to in given time periods.

Mr. Murai’s article explains these requirements in greater detail.

Workers should be protected from health hazards related to respirable crystalline silica. Unfortunately, this requires contractors to establish costly, time-consuming compliance procedures that increase the cost of construction.

Source—

OSHA Begins Enforcement of its Respirable Crystalline Silica in Construction Standard. Try Saying That Five Times Real Fast, Garret Murai, California Construction Law Blog, Nov. 1, 2107.