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Crystalline Silica Member Update

Friday, September 29, 2017   (0 Comments)
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In August, MDOT released a document on crystalline silica and it was circulated as a safety topic, which has raised numerous questions with MITA members. After review, there are a few points, as representatives of the industry, we would like to address with you.


Respirable crystalline silica is 10 mm (microns) or smaller, the respirable fraction are the particles small enough to pass into the alveoli deep in the lungs and are 4 mm (microns) or smaller, these particles will cause the irreversible damage.


The two control methods are wet and vacuum, but depending on the contractor’s assessment and work practices, the standard would also allow for administrative controls. Administrative controls would be used when an employee who is performing a task from OSHA’s Table 1 would be able to replace that employee with another qualified employee before they reach the 4-hour threshold.


Types of work that can cause or create silica dust are numerous, while some cause more dust to be created than others, there are specific jobs like blasting concrete. While blasting concrete does create silica dust, OSHA’s rule 1926.57 and more specifically, MIOSHA Occupation and Health Part 523 outline an employer’s responsibility for protection. It is up to the employer to equally comply with all rules.


Housekeeping is another area where employers can create exposures to silica. Taking a closer look at how the MIOSHA standard reads, using compressed air and dry sweeping are allowed, as long as they do not contribute to employee exposure to respirable crystalline silica (MIOSHA OH Part 690, 1926.1153(f)(1).


On September 20, 2017 OSHA released a memorandum outlining the goal of using the next 30 days to evaluate the good faith efforts of contractors to meet the new silica rule. OSHA and MIOSHA will render compliance assistance for those making strong efforts to comply with the rule. If an employer does not appear to be making any efforts to comply, they will be considered for citation. MITA has been developing policy for the membership that will be ready for full implementation in the spring. Silica training programs are also in development with the goal of bringing all employees up to speed. Getting trained by MITA in the off season as well as implementing policy will go a long way in reducing this hazard concerning employees and your exposure to MIOSHA enforcement. We will keep pushing information to the membership as we learn more and get clarification to the many questions the MITA staff has asked of MIOSHA.


Click here for the Specified Exposure Control Methods When Working with Materials Containing Silica 


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