• 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.

    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.

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    About Jeffrey Aran

    Sign law expert serving the sign industry and its customers for over 25 years, providing legal and consulting services to sign users, installers and manufacturers. Based in Sacramento, Practice Areas include Zoning; Land Use; Real Estate; Constitutional Law; Employment; & Business. Admitted to the Bar in 1989. Law Offices of Jeffrey L. Aran 1-888-SIGNLAW.

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