Compliance with the new OSHA silica regulations does not stop with training and task modification.
Compliance with the new OSHA silica regulations has lots of front end requirements that center around training and changes in equipment and procedures, but it doesn’t stop there. There are also several requirements in respect to exposure assessments and monitoring, especially when alternative control methods are used.
CFR 1926.1153 (d) (2) Exposure Assessment
(d) (2) (ii) 8-hour TWA – performance option
(d) (2) (iii) scheduled monitoring 8-hour TWA
(d) (2) (iii) (C) - retesting
These assessment and monitoring methods traditionally require the use of an air sampling device attached to the employee for the duration of the work shift. The collected sample is then sent off to a laboratory, analyzed, and the results sent back to the company. This process takes days and weeks to complete. Such a sampling system is both time consuming and expensive.
A new sampling and assessment technology is offered by Elite Safety Companies Inc. This new technology is based on a laser photometer that simultaneously measures mass and size fraction of airborne dust particles, an advanced process that no other system can perform. In simple terms what this means to the employer is that having this system used to gather the required data provides;
1. On site data gathering.
2. Instant calibrated results.
3. Computer generated data profiles and charts.
4. Less expensive and less time-consuming assessment compliance.
This new technology offered by Elite Safety allows for the collection of air samples at the site and real time immediate results of respirable dust particulates provided in the micrograms per cubic meter of air measurements consistent with OSHA references.
CFR 1926.1153.(d) specifies the requirement to obtain such exposure assessments via monitoring and places the burden on the employer to perform the required monitoring, or, obtain representative data from other sources that can demonstrate that employee performed tasks or functions do not expose the employee to levels of respirable silica dust that exceed the PEL on a TWA basis.
The use of equipment manufacturer provided exposure data can be used in some cases to supplement the required exposure data such as the data the elite Safety system generates. The new air sampling technology used by Elite Safety to obtain site specific and device specific silica dust generation provides instant ug/m3 data readings and helps build the exposure data profile that OSHA requires in certain cases.
Employers should carefully read CFR 1926.1153 (d) or consult their health and safety consultants to ensure that the requirements are being met and the assessments and monitoring procedures are being done. Remember that these assessment and monitoring requirements are not just a onetime event but may be required on a reoccurring basis depending on circumstances and results.