• SILICA ALERT

    Silica Resource Packet

    Dear CSA Member:

    We are pleased to provide you this Silica Resource Packet.

    As you are aware, both California and Federal OSHA have issued new warnings and regulatory guidelines pertaining to silica and the hazards it presents in the construction trades.

    Employer obligations under the new Respirable Crystalline Silica standard for construction, found in the California Code of Regulations, Title 8, section 1532.3, commenced on June 23, 2017. Effective October 23, 2017, Cal/OSHA is fully enforcing all appropriate provisions of the standard. This follows federal OSHA’s approach regarding enforcement of their corresponding standard.

    Sign contractors who engage in activities that create silica dust, such as by cutting, grinding or blasting materials like concrete, stone and brick, must meet a stricter standard for how much of that dust workers inhale. The same goes for employers of tradespeople working around such activities. The new standard also specifies what services employers must make available to workers who are exposed to high levels of silica dust and the training required of those who are at risk.

    This new standard has been under development for almost 20 years and supersedes OSHA’s first silica standard, issued in 1971. The old standard required that silica dust particles, which are 100 times smaller than sand granules, be limited to 250 micrograms per cubic meter of air over an average of eight hours — the hours of a typical work shift. The new standard reduces that to 50 micrograms over the same time period.

    In addition to the exposure limits, the new rules require contractors to:

    1. Develop a written silica exposure control plan.
    2. Designate someone to implement the plan.
    3. Adjust housekeeping practices to maximize control of silica dust.
    4. Provide medical exams every three years to employees who are exposed to silica to the point of having to wear a respirator for 30 days or more each year. The exams must include lung-function tests and chest X-rays.
    5. Train workers on how to limit exposure to silica.
    6. Keep records of workers’ silica exposure and related medical treatment.

    Implementing the new rules requires an initial assessment of how much silica dust a company’s operations generate.

    EXCEPTION:  If an exposure reading falls below the level of 25 micrograms, then the company is not required to provide medical tests, develop a written plan or undertake any of the suggested engineering controls (such as wearing respirators, wetting work down with tools like a wet saw, or using a vacuum device to reduce the volume of dust).

    However, workers should nonetheless be aware of and take precaution from potential jobsite exposure caused by other onsite construction activities unrelated to their trade, such as demolition work, concrete, asphalt, stucco, drywall, gunite, etc, performed by other contractors.

    Q: What about plastics or acrylics?
    A: Federal Heath recently conducted a silica audit test at one of its facilities. Dennis Lytle, Federal Heath’s Safety Manager (and current CSA president), reports, “The sample was taken for 8 hours while all variety of acrylics/plastics were cut on our router. The levels were barely detectable, much less measurable. As such the readings were well below the permissible levels outlined in the Silica Standard.”

    Nonetheless, CSA members are reminded that results will be different for each shop, depending on the methods and machinery utilized. Each contractor is responsible for making its own determination — and maintaining proper documentation is mandatory.

    THESE RESOURCES, including the California Department of Industrial Relations silica assessment online e-tools, should be consulted for further guidance:

    https://www.dir.ca.gov/dosh/dosh_publications/P08-019V3s.pdf

    • Cal/OSHA “Hazards of Silica in Construction” e-tool

    https://www.dir.ca.gov/dosh/etools/08-019/index.htm

    • Guidance on How to Control the Hazard

    https://www.dir.ca.gov/dosh/etools/08-019/EP08-019All.pdf

    > ISA weblinks to Silica management best practices. ISA Silica Resources

    • “Silica in Construction” Training Kit – weblink from the State of Washington

    http://www.lni.wa.gov/SAFETY/TRAININGPREVENTION/TRAININGKITS/SILICAINCONSTRUCTION/DEFAULT.ASP

    > Preparing a Silica Control Plan. This is an easy online free program:  https://plan.silica-safe.org/

    DISCLAIMER.  This information is general in nature and provided as a member service from sources believed to be reliable, including ISA and the California Dept of Industrial Relations.  However, it should not be construed as legal advice or regulatory guidance from CSA about your particular operations.  Members are encouraged to consult legal counsel with any questions.

  • BREAKING: US Supreme Court Ruling is Good News for Sign Industry

    US Supreme Court Rules Against City in Church Sign Case

    “Far reaching decision will affect sign codes throughout the country.” ~ Jeff Aran, The Sign Lawyer

    In Reed v. Town of Gilbert, the Good News Community Church was cited for exceeding the time limits for displaying temporary directional signs and failing to include an event date on the signs.  Their website includes this friendly message, “On the south side of Elliot, Just west of Gilbert Road. Signs will direct you to the room where we meet.

    Reversing the 9th Circuit Court of Appeals in a much anticipated decision, the US Supreme Court ruled June 17 that the city of Gilbert, AZ sign code was an unconstitutional restriction on speech. The court held, among many other points, that the code is an example of content-based discrimination, which “singles out specific subject matter for differential treatment, even if it does not target viewpoints within that subject matter.” The court also ruled that a code which is content-based on its face is nonetheless subject to “strict scrutiny” analysis, regardless of the government’s motive, content-neutral justification, or lack of disagreement with the ideas contained in the regulated speech.

    As a result, sign codes which include provisions favoring certain messages based on who is “speaking” will be subject to constitutional attack.  CSA will provide a full analysis shortly.

    Complete decision: http://www.supremecourt.gov/opinions/14pdf/13-502_9olb.pdf

    To review the Signage Foundation assessment by Professor Alan Weinstein, “Drafting and Enforcing Sign Codes after Reed v Town of Gilbert,” click here — 
    Signage Research Review (PDF)

  • Magnetic Ballast Phase Out Imminent

    Manufacturing of magnetic-type ballasts for fluorescent signs will be phased out on November 14, 2014.

    This is the effective date previously established by the U.S. Department of Energy (DOE) to implement its new metric for efficacy testing applicable to these products. As of November 14, 2014 all High Output Ferromagnetic Sign Ballast will no longer be produced by any ballast manufacturers. DOE had previously investigated the sign ballast product category and found that very few sign ballasts do not have the capability to operate 8-foot HO lamps either in single- or multiple-lamp combinations. Thus, the only ballasts not covered by the DOE rulemaking are those which cannot operate F96T12HO lamps in any combination. This phase-out is applicable to a majority of the commonly-used, fluorescent sign ballasts.

    The rulemaking creates a new metric for measuring ballast efficiency and establishes a higher standard of efficiency that will impact many of today’s fluorescent T5, T8 and T12 ballasts.

    The DOE rulemaking, however, does not prohibit sales or use of existing inventory of magnetic sign ballasts after the November compliance date and until inventories are depleted.

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  • Progress on Bill for Tax Extenders

    U.S. House of Representatives recently passed d H.R. 4457, the “America’s Small Business Tax Relief Act of 2014”. This bill would make permanent Section 179 expensing at the levels that had expired at the end of 2013, i.e., a $500,000 expensing allowance and a $2,000,000 investment cap. Continue Reading

  • Federal Highway Study Confirms Digital Billboard Safety

    The U.S. Department of Transportation Federal Highway Administration has released a landmark study declaring that digital billboards do not pose a safety risk to passing motorists. Within the sign industry, the results of this study come as no surprise. Numerous traffic studies and analyses performed in the last couple of decades have reached similar conclusions. 
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