OSHA Has Answers for Silica Rule FAQs

Ever since the U.S. Occupational Health and Safety Administration (OSHA) began enforcing its respirable crystalline silica standard for general industry in June 2018, employers have had questions about it. On Jan. 23, OSHA published a list of Frequently Asked Questions (FAQs) and answers developed in consultation with industry and union stakeholders. The silica standard establishes a permissible exposure limit (PEL) of 50 µg/m3 as an eight-hour time-weighted average (TWA), and an action level of 25 µg/m3, calculated as an eight-hour TWA. Employers must ensure that employees are not exposed to respirable crystalline silica (RCS) above the PEL. Employers must perform exposure assessments of each employee who is or may reasonably be expected to be exposed to RCS at or above the action level, and provide medical surveillance for employees who are exposed to RCS at or above the action level for 30 or more days per year. Employers also must establish regulated areas and provide respiratory protection, housekeeping, training, hazard communication, and medical surveillance. The standard also does not apply to employers who have objective data demonstrating that employee exposure will remain below the action level under foreseeable conditions. OSHA considers the failure of most controls to be a foreseeable condition, and thus employers should consider this when making their assessments.