OSHA's New Silica Rule: What manufacturers need to Know

OSHA’s New Silica Rule: What Manufacturing Facility Owners Need to Know

OSHA’s new silica rule will be felt by upstream for manufacturers planning new construction or expansions. Disclosure of known silica-containing materials must be part of any facility purchase, upfit or renovation. The presence of silica can pose a hazard to occupants of the facility and adjacent properties.

Silica may not sound like an issue that needs to be addressed by facility owners in the manufacturing industry. This ubiquitous mineral compound is a major component of the actual bricks and mortar that companies build with, and it has made news lately as a substance being targeted by the Occupational Safety and Health Administration (OSHA).

Construction companies will soon incur large costs as they strive to comply with OSHA’s new silica rule and mitigate risks for employees working in the presence of silica-containing materials. A ripple effect is predicted to be felt across many industries, as well as upstream for manufacturers that are planning new construction, expansion or retrofit projects. Of particular concern for facility owners will be the modifications or expansions of existing facilities. Simple activities like concrete saw cutting of slabs can have an impact on both the construction and maintenance groups performing the work, as well as on surrounding employees, if not addressed through the proper training, equipment and planning.

Moreover, like the disclosure of asbestos and lead, disclosure of known silica-containing materials must be part of any facility purchase, upfit or renovation.

What Will the Rule Require?

Silicon dioxide (aka silica) can be crystalline or noncrystalline with quartz, cristobalite and tridymite being examples of crystalline silica. Asphalt, concrete products, drywall, plaster, roofing pavers, fill dirt and top soil, various stones and stucco are some, but not all, of the silica-containing construction materials that may be on a manufacturing facility jobsite.

Workers across many trades are potentially exposed to silica. When silica-containing materials are cut, blasted, crushed or ground, particulates—respirable crystalline silica—become airborne and represent a serious hazard to workers.

OSHA updated its silica standards in 2016 for the first time in over 40 years. The construction industry was required to comply with the new rule (29 CFDR 1926.1153) and OSHA recently began enforcement.

These values represent a significant reduction in allowable exposure limits; a variety of construction processes will have to change in order to comply. This means owners and other stakeholders can expect to see quite a few adjustments and line-item additions to their construction projects in the future.

Contractors will have the option of developing their own methods of dust control, but this would involve placing monitors on the employees and then testing the samples collected.

To accomplish the measures outlined by the new standard, contractors will be purchasing new machinery, tools and equipment; incurring costs associated with ongoing training and education, medical surveillance and recordkeeping; and making other investments. These costs will be factored into their bids. An early report commissioned by OSHA pointed out that the “initial impact is to force affected industries to purchase equipment, supplies, and services to implement the new regulations. They also might need to divert workers towards compliance activities, thereby reducing overall labor productivity for the industry.”

Some experts on the new ruling have suggested that it qualifies as disruptive, just as certain technologies have come to be seen as disruptive. This is because it will drive changes across a broad range of goods-and-services providers. For example, tool companies have rolled out many new product lines that offer improved dust collection and disposal. OSHA’s requirement for increased employee monitoring is expected to incentivize companies to improve their adoption of technology, since digital filing and record-keeping is typically more efficient than paper-based filing.

Manufacturing facility owners will feel the impact of the new OSHA regulations and must shoulder some of the responsibility for compliance. They will need to address the presence of silica in all stages of project planning, take appropriate precautions, and engage qualified contractors that have taken a proactive approach to dealing with the silica mandates.