Surveyors Need to Know About OSHA's Proposed Silica Standard
I was speaking with a surveyor a few weeks ago and I migrated to a comment on Occupational Safety and Health Administration’s proposed silica regulations. He commented that he didn’t see how that could affect the surveying profession. After I briefly explained the proposal and what it encompassed, he quickly changed his mind.
The Federal Register posted 230 pages of information on Sept. 12, 2013. Just more than 200 pages of the information is supporting data on why OSHA is developing these new regulations. Approximately 24 pages are the actual proposed regulations broken down into general industry, shipbuilding and construction. If you have ever read the Federal Register, you already know that each page is equal to two to three pages of normal text. OSHA tends to provide so much detail in any of its proposals that only safety nerds such as I are ever going to read everything.
At this point it is only a proposal. OSHA is in the comment stage where informational hearings are being held and comments are taken. At some point down the road OSHA will either adopt the proposals as written or make changes based upon comments received from the public. This process can take anywhere from a few months to years.
Once it is published as a final rule there will be a period of time to allow everyone to start their compliance efforts. There is also a strong possibility that if any trade associations or interested groups disagree with the final rule, they can take court action to make changes in the final rule. This proposal isn’t ready for enforcing and won’t be done quickly, but you need to understand what elements may apply to you in your daily activities.
Silica is a natural occurring material. It is found in many products. In surveying you may be exposed to silica when on construction sites, mining operations or when crews have to cut or drill for monuments or boundary markers. The most likely heavy exposure would be on a construction site or mining operation. If you encounter a cloud of white dust when any stone or concrete operations are present, it most likely contains silica.
The new regulations call for engineering controls or other methods to be used to reduce or eliminate workers’ exposure to airborne silica. The new standard would reduce exposure to a limit of 50 micrograms per cubic meter on a time weighted average of eight hours. There is no amount of silica that is good, so I recommend to all of my clients that some type of protection be used to reduce the levels as low as feasible. Wet methods and dust extraction are the best engineering controls while personal protective equipment (PPE) such as respiratory protection should be secondary in nature. The proposed standards outline some suggestions on how to protect workers. Medical evaluations are required at one-half the allowable exposure to any employees. These medical evaluations are on a periodic basis. All of the suggestions follow what are now standard industry practices. It would reduce the reliance on respiratory protection and emphasize the engineering controls. This gives more reliable protection.
I will follow the progress of the proposal and keep everyone informed either through my new blog or through my articles in POB. You will find a link to the proposed regulations in the Federal Register at https://federalregister.gov/a/2013-20997.
There is also a 1938 film, which now can be found on YouTube, that was put out by the Department of Labor long before OSHA came into existence. I use this 1938 video in many of my presentations because I think it shows how long we have known about some of these safety issues and still haven’t solved all of our issues.
Take a little time to become informed. Knowledge is power. Keep it safe!
To help everyone stay safe in the new year, Ron Koons of the consulting firm RoSaKo Safety will answer your questions about surveyor safety and OSHA compliance. Email your question to Ron Koons at firstname.lastname@example.org with the subject line, “POB Safety Q&A,” and he will address your question in an upcoming issue of POB.