Apparently this went into effect in September:
https://www.osha.gov/Publications/OSHA3681.pdf
While it is Contractor’s means and methods, does it seem like a good issue to address? Perhaps make mention of it in demolition specs and for masonry cleaning and restoration projects?
What does everyone here think?
Ken,
Good to meet you at ARC US in Miami.
I think I will leave this to the contractors’ means and methods, site safety, sequenceing, manufacturers installation instructions and their SDS sheets for worker safety.
I do not want to transfer the risks to the firm.
Wayne
I am looking for how this applies to silica in mineral fiber ceiling panels. Any thoughts?
In Table 1 - https://www.osha.gov/silica/SilicaConstructionRegText.pdf they address cutting fiber cement panels with handheld tools (item iii) and then in (vii) address handheld drills. Nothing specific to fiber ceiling panels that I see.
It does start off with “This section applies to all occupational exposures to respirable
crystalline silica in construction work, except where employee exposure will remain below 25
micrograms per cubic meter of air (25 g/m3) as an 8-hour time-weighted average (TWA) under
any foreseeable conditions.”
Perhaps the ceilings aren’t on OSHA’s radar yet.
Ken, thanks for the link.
The instruction to remain below “average… under
any foreseeable conditions” is especially delightful.
All of our mason contractors have been trained on how to comply with the silica rule. In fact, many of them have been using equipment that would be required under the new rule. So to me, this falls under means and methods and specifiers shouldn’t have to do anything. The government requires contractors to meet this so you don’t even have to specify that they meet it.
Might this affect any all-inclusive requirements for “managing” indoor air-quality…i.e., contaminating interior spaces, either still open to exterior or enclosed with HVAC operating? More so considering current So Cal wildfires and carbon soot/ashes/smoke being blown everywhere?
As Brian points out, the industry has been preparing for this for years, as the significant dangers have been known a long time. Going back as far as the mid-19th century, the relationship between work that creates silica dust - such as mining and rock-drilling - and silicosis was known. What I have read over the years suggests that silica dust is probably more lethal than asbestos. The big problems come from grinding and cutting concrete; I’m sure we’ve all seen those plumes of dust with some poor guy wearing a basic (inadequate) dust mask - if any.
Tool manufacturers have come up with various ways to comply. (Don’t know what they are.) I believe that the way the rule is written, if you take certain prescriptive steps you are assumed to comply, avoiding the need to regular onsite testing (a bit like lead abatement, I think). However, under the direction of the current administration, the effective date of the rule was pushed back from Sept to Oct. I’m not sure if there was another delay. There was also anticipated to be a lack of enforcement for a while, too. I believe some contractors had started to use new equipment and methods without waiting for the rule to be in effect.