Sweeping Changes in Wake of New OSHA Silica Guidelines
The brick, ceramic, advanced ceramic and glass industries are all going to be impacted by the aggressive new silica standard.
OSHA Standard 29 CFR 1910.1053 is not the first time that the U.S. Occupational Safety and Health Administration (OSHA) has set limits on crystalline silica. According to a U.S. Department of Labor (DOL) news release, current U.S. Secretary of Labor Thomas E. Perez noted, “‘More than 80 years ago, Labor Secretary Frances Perkins identified silica dust as a deadly hazard and called on employers to fully protect workers.’”
The first notable standard, according to DOL document RIN: 1218-AB70, was set in 1971 based on a 1962 American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value. This Permissible Exposure Level (PEL) has undergone few changes in the proceeding decades, but technology, increased monitoring capacity, and a more detailed understanding of health risks tied to silica have inspired the latest, more stringent standard.
The new PEL would halve the existing allowable PEL over the course of eight hours. A way to visualize this, according to Tom Slavin and Stephanie Salmon of the American Foundry Society, is to think about limiting silica to the size of a small sugar packet set in a football stadium that is 13 ft high. The standard comprises two parts: one for the construction industry (compliance required by June 23, 2017) and one for general industry/maritime (compliance required by June 23, 2018).
The brick, ceramic, advanced ceramic and glass industries are all going to be impacted by the aggressive new standard. For example, the new standard is so strict that facilities can no longer depend on brooms, air hoses or shovels for cleaning because these methodologies will simply move the particles around and continue to expose the labor force to crystalline silica.
The OSHA perspective on silica is fairly straightforward: Tighter regulations are actually life-saving measures. According to the OSHA Fact Sheet entitled “OSHA’s Crystalline Silica Rule: General Industry and Maritime,” 3,198 structural clay product workers are being exposed above the new PEL; 2,496 pottery workers, 1,654 porcelain enameling workers, and more are all at risk for lung cancer and silicosis. Again referring to RIN: 1218-AB70, the DOL specifically mentions glass and concrete product manufacturers, brick makers, and china and pottery manufacturers as laborers who are particularly at risk due to silica exposure.
Not surprisingly, many of the industries targeted by the new guidelines are fighting back. For industries like advanced ceramics, crystalline silica in powder form is often an integral part of the manufacturing process. Any industry that thrives on the use of quartz or sand would be similarly impacted by these new guidelines.
The Brick Industry Association (BIA) offers additional considerations regarding why OSHA should rethink these new standards. One letter that the BIA has set up for its members insists that clay brick operations in particular should be considered separately from other industries. The letter notes, “The brick industry has a significant body of data that has been previously submitted, and is being resubmitted during this rulemaking, that clearly demonstrates that there is little-to-no silicosis in our industry, despite historical exposures well above the current PEL. If there is little-to-no silicosis at the current PEL, there can be no improvement by lowering the PEL.”
A second BIA letter builds on the low prevalence of silicosis in the industry by suggesting that meeting the new PEL standard would significantly increase costs without any measurable ROI. The letter states, “It would, however, significantly and needlessly increase the numbers of our operations that would be subject to monitoring and other requirements under the rule and significantly and needlessly increase the operating costs at our operations.”
Sentiment is strong across several industries that the new OSHA standards will be particularly hard on smaller, family-owned companies and that, for this reason, companies should be considered based on size and capacity. Several companies in the construction industry are also planning to challenge the new guidelines.
Right now, we need to assume that OSHA is not going to overturn or revise the new standards. Subsequently, preparations for meeting the new PEL must begin. The amount of work that needs to be done over the next couple of years is daunting. Factors ranging from how your facility is cleaned to how you monitor your employees’ health are going to have to change. Brooms and shovels, which long have been used to maintain plants, can no longer be used because they expose the labor force to too many particulates and create dust clouds that can spread crystalline silica throughout the facility.
One easy and economical way to help lighten the burden is to purchase, lease or rent an industrial vacuum system. Several companies manufacture these types of products, and selecting the one that will best assist in removing silica particulates depends on two key criteria: vacuum performance and air-to-cloth filtration ratio.
The advantages of an industrial vacuum system are numerous. Employees will not require respirators, and the air circulated back into the plant will be cleaner than the existing air in the environment. What’s more, minimal human labor is required. These systems are far more effective than simple shop vacuums with HEPA filters and can be installed anywhere in the facility with an in-plant manifold piping system.
Once installed, the right industrial vacuum system will make an impact immediately, especially when using an industrial vacuum system with the best air-to-cloth ratio available. Bear in mind, if your facility chooses to vent pollutants outside of the plant, you will also have to adhere to the appropriate U.S. Environmental Protection Agency (EPA) regulations. Taking care of silica disposal will free your time for everything else that OSHA requires, including: constant monitoring; educating all of your employees; and beginning to track employee health records for incidents of silicosis, lung cancer, and exposure to silica in general.
OSHA, the EPA and the DOL will continue to strive for a 100% safe work environment for all employees in the U.S. That’s not necessarily a bad thing, but it means that manufacturers will probably need to meet additional, equally stringent guidelines in the future. Whether the issue is air quality or another factor tied to safety, businesses big and small will need to prepare to pivot quickly in order to keep ahead of the new standards.
Creating a solid system for handling these changes will be beneficial over the long haul. Do not wait for government organizations to teach you how to do that. The onus is and will always be on your company to stay ahead of what is required.
For additional information, visit www.hi-vacproducts.com.