Silica: Interim enforcement guidance issued

On June 25 2018, OSHA issued an interim enforcement guidance. Most of the standard’s requirements became enforceable two days earlier, with the exception of certain requirements related to hydraulic fracturing and medical surveillance.

Summary of the “Housekeeping Practices” section

  • Dry sweeping/brushing are prohibited unless wet sweeping, HEPA-filtered vacuuming, or other methods that minimize the likelihood of silica exposure are not feasible.
  • Sweeping compounds are acceptable as long as the compounds don’t create additional exposures.
  • Compressed air is not allowed for cleaning unless used in conjunction with a ventilation system or no alternative method is feasible.
  • If drivable powered industrial sweepers are equipped with HEPA filters, they are considered “HEPA-filtered vacuuming.”

Inspection process

  • Review the employer’s written exposure control plan.
  • Interview and/or observe employees who are cleaning up dust.
  • If necessary, collect a bulk sample and/or personal air samples to document that the dust contains crystalline silica.

Citations will be issued where:

  • An employer allows dry sweeping/brushing even though the employer can’t demonstrate that the preferred methods aren’t feasible.
  • An employer allows the use of compressed air without a ventilation system or the employer can’t demonstrate that the preferred methods aren’t feasible.

For details on other sections of the standard, read the whole memo.

Beryllium: Amendments in effect, certain provisions delayed

On May 4 2018, OSHA issued a new final rule that updated the definitions of “beryllium work area,” “emergency,” “skin contact,” and “contamination.” The agency also clarified that most of the requirements apply to materials containing at least 0.1% beryllium by weight.

On May 11, some provisions of the beryllium standard became enforceable:

  • General industry: PEL, exposure assessment, respiratory protection, medical surveillance, and medical removal
  • Construction: PEL only
  • Shipyard: PEL only
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