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Small Entity

Compliance Guide

for the Respirable

Crystalline Silica Standard for

General Industry and Maritime

OSHA 3911-07 2017

Occupational Safety and Health Act of 1970

“To assure safe and healthful working conditions for working men

and women; by authorizing enforcement of the standards developed

under the Act; by assisting and encouraging the States in their

efforts to assure safe and healthful working conditions; by providing

for research, information, education, and training in the ﬁeld

of occupational safety and health.”

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requested but not required.

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upon request. Voice phone: (202) 693-1999; teletypewriter (TTY) number:

1-877-889-5627.

This publication provides a general overview of a particular standards-

related topic. This publication does not alter or determine compliance

responsibilities which are set forth in OSHA standards and the

Occupational Safety and Health Act. Moreover, because interpretations

and enforcement policy may change over time, for additional guidance

on OSHA compliance requirements the reader should consult current

administrative interpretations and decisions by the Occupational Safety

and Health Review Commission and the courts.

Cover photo courtesy of NIOSH.

Small Entity

Compliance Guide

for the Respirable Crystalline Silica Standard

for General Industry and Maritime

Occupational Safety and Health Administration

U.S. Department of Labor

OSHA 3911-07 2017

This guidance document provides an

overview of OSHA’s Respirable Crystalline

Silica Standard for General Industry and

Maritime. It is advisory in nature and

informational in content. It is not a standard

or regulation, and it neither creates new legal

obligations nor alters existing obligations

created by the Occupational Safety and

Health Administration (OSHA) standards or

the Occupational Safety and Health Act of

1970 (OSH Act). Pursuant to the OSH Act,

employers must comply with safety and

health standards and regulations issued and

enforced either by OSHA or by an OSHA-

approved state plan. In addition, the Act’s

General Duty Clause, Section 5(a)(1), requires

employers to provide their workers with a

workplace free from recognized hazards that

are causing or likely to cause death or serious

physical harm.

In addition, Section 11(c)(1) of the Act

provides that “No person shall discharge

or in any manner discriminate against any

employee because such employee has ﬁled

any complaint or instituted or caused to be

instituted any proceeding under or related

to this Act or has testiﬁed or is about to

testify in any such proceeding or because

of the exercise by such employee on behalf

of himself or others of any right afforded by

this Act.” Reprisal or discrimination against

an employee for reporting an incident, injury,

or workplace violation, for participating

in medical surveillance, or because of

the results of medical surveillance would

constitute a violation of Section 11(c) of the

OSH Act.

TABLE OF CONTENTS

INTRODUCTION .......................................................................................................................................1

SCOPE – PARAGRAPH (A) OF THE STANDARD...................................................................................1

Exposures from Sorptive Clay Processing ..................................................................................... 2

Exposures Below 25 μg/m

Under Any Foreseeable Conditions ................................................2

General Industry and Maritime Work Indistinguishable from Table 1 Construction Work ......2

DEFINITIONS – PARAGRAPH (B) OF THE STANDARD ........................................................................3

PERMISSIBLE EXPOSURE LIMIT (PEL) – PARAGRAPH (C) OF THE STANDARD ............................. 3

EXPOSURE ASSESSMENT – PARAGRAPH (D) OF THE STANDARD ................................................4

REGULATED AREAS – PARAGRAPH (E) OF THE STANDARD ...........................................................8

METHODS OF COMPLIANCE – PARAGRAPH (F) OF THE STANDARD .............................................9

RESPIRATORY PROTECTION – PARAGRAPH (G) OF THE STANDARD ...........................................14

HOUSEKEEPING – PARAGRAPH (H) OF THE STANDARD ................................................................14

MEDICAL SURVEILLANCE – PARAGRAPH (I) OF THE STANDARD .................................................15

COMMUNICATION OF HAZARDS – PARAGRAPH (J) OF THE STANDARD ...................................23

RECORDKEEPING – PARAGRAPH (K) OF THE STANDARD ..............................................................25

DATES – PARAGRAPH (L) OF THE STANDARD .................................................................................26

APPENDIX I: OSHA RESPIRABLE CRYSTALLINE SILICA STANDARD

FOR GENERAL INDUSTRY AND MARITIME.......................................................................................27

WORKERS’ RIGHTS ...............................................................................................................................52

OSHA ASSISTANCE, SERVICES AND PROGRAMS ..........................................................................52

OSHA REGIONAL OFFICES ................................................................................................................... 54

HOW TO CONTACT OSHA ....................................................................................................................55

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

INTRODUCTION

This guide is intended to help small businesses

understand and comply with the Occupational

Safety and Health Administration’s (OSHA)

Respirable Crystalline Silica standard for

General Industry and Maritime. Employees

exposed to respirable crystalline silica are at

increased risk of developing serious adverse

health effects including silicosis, lung cancer,

chronic obstructive pulmonary disease, and

kidney disease. This guide describes the steps

that employers are required to take to protect

employees in general industry and maritime

from the hazards associated with exposure

to respirable crystalline silica. Employers

in the construction industry should refer

to the Small Entity Compliance Guide

for Occupational Exposure to Respirable

Crystalline Silica in Construction.

This document provides guidance only,

and does not alter or determine compliance

responsibilities, which are laid out in OSHA

standards and the Occupational Safety and

Health Act. This guide does not replace the

ofﬁcial Respirable Crystalline Silica standard for

general industry and maritime. The employer

must refer to the standard to ensure that it is in

compliance. Moreover, because interpretations

and enforcement policy may change over time,

for additional guidance on OSHA compliance

requirements the reader should consult current

administrative interpretations and decisions

by the Occupational Safety and Health Review

Commission and the courts.

What is Respirable Crystalline Silica?

Crystalline silica is a common mineral found in

naturally occurring and man-made materials

like stone or artiﬁcial stone countertops and

sand. Amorphous silica, such as silica gel, is

not crystalline silica.

Employees can be exposed to respirable

crystalline silica – very small particles typically

at least 100 times smaller than ordinary sand

found on beaches or playgrounds – during the

manufacturing of products like glass, pottery,

ceramics, brick, concrete, and artiﬁcial stone.

They can also be exposed during abrasive

blasting with sand and during the use of

industrial sand in operations such as foundry

work and hydraulic fracturing.

SCOPE – PARAGRAPH (A) OF THE STANDARD

The standard applies to all occupational

exposures to respirable crystalline silica,

except for the following:

■ Construction work as deﬁned by 29

CFR 1910.12(b), which is covered by the

respirable crystalline silica construction

standard (29 CFR 1926.1153);

■ Agricultural operations, which are covered

by OSHA’s occupational safety and health

standards for agriculture and,

■ Exposures that result from the processing

of sorptive clays.

The standard also does not apply to the

following:

■ Where the employer has objective data that

employee exposure to respirable crystalline

silica will remain below 25 micrograms per

cubic meter of air (25 μg/m

) as an 8-hour

time-weighted average (TWA) under any

foreseeable conditions;

■ Where the employer chooses to comply with

the construction standard (29 CFR 1926.1153)

for tasks performed that are indistinguishable

from a construction task listed on Table 1 of

the construction standard, provided the tasks

are not performed regularly in the same

environment and conditions.

Occupational Safety and Health Administration

Exposures from Sorptive Clay

Processing

Exposures from the processing of sorptive

clays are excluded from this standard.

Sorptive clays such as bentonite are speciﬁc

types of clay found in a few geologic

deposits in the country that are used in a

range of consumer products and industrial

applications, such as pet litter and sealants

for landﬁlls. The occluded quartz found in

sorptive clays is considerably less toxic than

unoccluded quartz, and there is insufﬁcient

evidence for its inclusion in the standard.

However, the processing of sorptive clays

remains subject to the permissible exposure

limit (PEL) in 29 CFR 1910.1000 Table Z-3 (i.e.,

the formula that is approximately equivalent

to 100 μg/m

Exposures Below 25 μg/m

Under

Any Foreseeable Conditions

Exposures that will not exceed 25 μg/m

averaged over an 8-hour day under any

foreseeable conditions are excluded from

the standard. Employers must have objective

data demonstrating employee exposure to

respirable crystalline silica associated with

a particular product or material or a speciﬁc

process, task, or activity will remain below

this level.

When using the phrase “any foreseeable

conditions” OSHA is referring to situations

that can reasonably be anticipated. OSHA

considers failure of engineering controls to

be a situation that is reasonably foreseeable.

It is foreseeable that controls could

breakdown and lead to over exposures.

Although engineering controls are usually

a reliable means for controlling employee

exposures, equipment does occasionally

fail. Thus, the standard applies where

exposures below 25 μg/m

as an 8-hour TWA

are expected or achieved, but only because

engineering controls are being used to limit

exposures.

General Industry and Maritime

Work Indistinguishable from

Table 1 Construction Work

For general industry and maritime work that

is indistinguishable from work covered by

Table 1 in the construction silica standard, the

employer may comply with the construction

standard, including the speciﬁed exposure

control methods in Table 1 for that task. The

task must not be performed regularly in the

same environment and conditions.

For example, an employee repairing or

maintaining existing power delivery lines

(considered a general industry task) uses

a handheld drill that is the same as that

used while installing new power delivery

lines (considered a construction task).

This maintenance task is the same as the

construction task and would occur in a

variety of locations. The employer could

protect the employee doing the maintenance

task by following the entire construction

standard, including the Table 1 entry for the

speciﬁc task.

Conversely, the construction standard

could not be used by a general industry and

maritime employer for sanding or cutting

of concrete blocks in a concrete block

manufacturing plant, because that is a task

performed regularly in the same environment

and conditions. Such an employer would

not require the accommodation of Table 1,

which is intended in part to address tasks

performed in different environments and

conditions. Similarly, an employer whose

business includes chipping out concrete from

inside the drums of ready-mixed concrete

trucks using pneumatic chipping tools

may not follow the construction standard

because that task will be performed regularly

and in a relatively stable and predictable

environment.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

DEFINITIONS – PARAGRAPH (B) OF THE STANDARD

Deﬁnitions are included in the standard to

describe the meaning of terms used. Some of

these terms are further explained as follows:

Action level means an airborne concentration

of 25 μg/m

calculated as an 8-hour TWA.

Exposures at or above the action level trigger

requirements for exposure assessment and

medical surveillance.

Employee exposure means the exposure

to airborne respirable crystalline silica that

would occur if the employee were not using

a respirator.

High-efﬁciency particulate air (HEPA) ﬁlter

means a ﬁlter that is at least 99.97 percent

efﬁcient in removing mono-dispersed particles

of 0.3 micrometers in diameter. HEPA-ﬁltered

vacuuming is an example of a housekeeping

method that minimizes employee exposure to

respirable crystalline silica.

Objective data means information, such as air

monitoring data from industry-wide surveys

or calculations based on the composition of a

substance, demonstrating employee exposure

to respirable crystalline silica associated with

a particular product or material or a speciﬁc

process, task, or activity. The data must reﬂect

workplace conditions closely resembling or

with a higher exposure potential than the

processes, types of material, control methods,

work practices, and environmental conditions

in the employer’s current operations.

Physician or other licensed health care

professional [PLHCP] is an individual whose

legally permitted scope of practice (i.e.,

license, registration, or certiﬁcation) allows

him or her to independently provide or be

delegated the responsibility to provide some

or all of the particular health care services

required by this standard.

Specialist means an American Board

Certiﬁed Specialist in Pulmonary Disease

or an American Board Certiﬁed Specialist in

Occupational Medicine.

PERMISSIBLE EXPOSURE LIMIT (PEL) – PARAGRAPH (C) OF

THE STANDARD

Employers must ensure that their employees’

exposures to respirable crystalline silica do not

exceed the PEL, which is 50 μg/m

as an 8-hour

TWA. This means that over the course of any

8-hour work shift, exposures can ﬂuctuate, but

the average exposure to respirable crystalline

silica cannot exceed 50 μg/m

. The PEL applies

to the three forms of respirable crystalline

silica that are covered by the standard: quartz,

cristobalite, and trydimite. Quartz is by far the

most common form of crystalline silica found

in general industry and maritime workplaces,

and in most cases, quartz will be the only form

of respirable crystalline silica analyzed in air

samples used to measure employee exposures.

Occupational Safety and Health Administration

Calculation of TWA Exposures

Both the PEL and the action level are expressed as TWA exposures. TWA measurements account

for variable exposure levels over the course of a work shift by averaging periods of higher and lower

exposures. The TWA exposure for an 8-hour work shift is calculated using a simple formula:

TWA = (Ca Ta + Cb Tb . . . Cn Tn) ÷ 8

Where:

TWA is the time-weighted average exposure for the work shift

C is the concentration during any period of time (T) where the concentration remains constant; and

T is the duration in hours of the exposure at the concentration (C)

For example, assume that an employee is exposed to respirable crystalline silica in an 8-hour workday

as follows:

Two hours exposure at 100 µg/m

Two hours exposure at 50 µg/m

Four hours exposure at 10 µg/m

Entering this information in the formula, we get:

(2 x 100 + 2 x 50 + 4 x 10) ÷ 8 = 42.5 µg/m

Because 42.5 µg/m

is higher than 25 µg/m

, this employee’s TWA exposure would be above the action

level, but below the PEL of 50 µg/m

EXPOSURE ASSESSMENT – PARAGRAPH (D) OF THE STANDARD

Employers must assess the 8-hour TWA

exposure for each employee who is or may

reasonably be expected to be exposed

to respirable crystalline silica at or above

the action level of 25 μg/m

as an 8-hour

TWA. The purposes of assessing employee

exposures include: identifying where

exposures are occurring; helping the

employer select control methods and make

sure those methods are effective; preventing

employees from being exposed above the

PEL; providing employees with information

about their exposure levels; and allowing

the employer to give the PLHCP performing

medical examinations information about

employee exposures.

Employers can choose between two options

for assessing exposures:

■ The performance option; or

■ The scheduled monitoring option.

Performance Option

The performance option gives employers

ﬂexibility to determine the 8-hour TWA

exposure for each employee based on

any combination of air monitoring data

or objective data that can accurately

characterize employee exposures to

respirable crystalline silica.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Air monitoring data are any results of air

monitoring (analyzed according to the

procedures and requirements in Appendix

A) that the employer has done to meet the

requirements of the standard.

Objective data is information that

demonstrates employee exposure to

respirable crystalline silica associated with

a particular product or material or a speciﬁc

process, task, or activity. The data must reﬂect

workplace conditions that closely resemble

or could result in higher exposures than the

processes, types of material, control methods,

work practices, and environmental conditions

in the employer’s current operations.

Examples of objective data are information

such as:

■ Air monitoring data from industry-wide

surveys;

■ Calculations based on the composition of

a substance;

■ Area sampling results and exposure

mapping proﬁle approaches; and

■ Historical air monitoring data collected by

the employer.

Employers choosing the performance

option must:

■ Conduct the exposure assessment before

work begins;

■ Reassess exposures whenever a change

in production, process, control equipment,

personnel, or work practices may

reasonably be expected to result in new

or higher exposures at or above the action

level, or when the employer has any reason

to believe that new or additional exposures

at or above the action level have occurred;

■ Be able to demonstrate that employee

exposures have been accurately

characterized; and

■ Make sure that the exposure assessment

reﬂects the exposures of employees on

each shift, for each job classiﬁcation, in

each work area.

The performance option may be especially

useful when measuring employee exposures

is challenging, such as when tasks are

performed only occasionally.

The performance option gives employers

ﬂexibility for characterizing the exposures

of all employees. For example, instead of

Examples of Using Objective Data to Conduct Exposure Assessments

under the Performance Option

1. Industry-wide surveys of typical tasks or operations, which include well-documented procedures for

measuring exposures and methods for controlling dust, could be used by employers to characterize

employee exposures where employees perform tasks consistent with those described in the survey.

2. Employers can use direct-reading instruments to measure real-time levels of respirable dust in the

air. If the employer has information on the percentage of respirable crystalline silica in that dust (for

example, from the analysis of a bulk sample or information from a safety data sheet), he or she can

then calculate the level of respirable crystalline silica in air.

3. Historical air monitoring data collected by the employer could be used to assess employee exposures

if the employer can show that the data were collected during work operations and conditions that are

consistent with the processes, types of material, control methods, work practices, and environmental

conditions in the employer’s current operations.

Occupational Safety and Health Administration

conducting air monitoring on two employees

who perform the same job on different shifts,

the employer could determine that there are

no differences in exposure between those

two employees, and characterize the exposure

of the second employee based on the air

monitoring results of the ﬁrst employee.

Under the performance option, employers

can characterize employee exposure within

a range to account for exposure variability.

Employers can also use that option to show

that exposures exceed the PEL by a certain

level, such as less than 10 times the PEL, after

using all feasible controls. The employer

would then know that he or she must provide

respiratory protection with an assigned

protection factor (APF) of at least 10.

Scheduled Monitoring Option

The scheduled monitoring option lets

employers know when and how often

they must perform exposure monitoring

to measure employee exposures. When

following the scheduled monitoring option,

employers must make sure that:

■ Results represent the employee’s TWA

exposure to respirable crystalline silica

over an eight-hour workday;

■ Samples are collected from the

employee’s breathing zone; and

■ Samples are collected outside respirators

so that they represent the exposure

that would occur without the use of the

respirator.

OSHA intends for employers using the

scheduled monitoring option to conduct

initial monitoring as soon as work begins so

that they are aware of exposure levels and

where control measures are needed.

Under the scheduled monitoring option, just

as under the performance option, employers

must correctly characterize each employee’s

exposure to respirable crystalline silica.

Exposure monitoring must include, at a

minimum, one full-shift sample taken for each

job function in each job classiﬁcation, in each

work area, and on each shift. Characterizing

each employee’s exposure may involve

monitoring all exposed employees or a smaller

number of employees whose exposures can

then represent those of other employees.

Representative sampling involves monitoring

the employee or employees reasonably

expected to have the highest exposure to

respirable crystalline silica (for example, the

employee closest to an exposure source).

This exposure is then assigned to the other

employees in the group who perform the

same tasks on the same shift and in the same

work area.

Representative monitoring is allowed when

several employees perform the same job on

the same shift and under the same conditions.

How Often Employers Must

Monitor under the Scheduled

Monitoring Option

Under the scheduled monitoring option, how

often monitoring must be done depends

on the results of initial monitoring and,

thereafter, any required further monitoring,

as follows:

■ If the initial monitoring indicates that

employee exposures are below the action

level, no further monitoring is required.

■ If the most recent exposure monitoring

reveals employee exposures at or above

the action level but at or below the PEL, the

employer must repeat monitoring within

six months of the most recent monitoring.

■ If the most recent exposure monitoring

reveals employee exposures above the

PEL, the employer must repeat monitoring

within three months of the most recent

monitoring.

■ When two non-initial monitoring results

taken consecutively, at least 7 days

apart but within 6 months of each other,

are below the action level, employers

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

may stop monitoring for employees

represented by those results, as long as

no changes occur that could reasonably

be expected to result in new or additional

exposures at or above the action level.

Reassessment of Exposures

The employer must reassess exposures

whenever a change in production, process,

control equipment, personnel, or work

practices may reasonably be expected to

result in new or additional exposures to

respirable crystalline silica at or above the

action level, or when the employer has any

reason to believe that new or additional

exposures at or above the action level have

occurred. For example, reassessment would

be required when a material used in a process

is replaced by a material with a higher silica

content because the change could reasonably

be expected to result in higher exposures to

respirable crystalline silica.

Employers do not have to conduct additional

monitoring simply because a change has

occurred, so long as the change is not

reasonably expected to result in new or

additional exposures to respirable crystalline

silica at or above the action level. For

example, reassessment is not required when

a task is moved from an enclosed space

to a larger location, or when a product is

replaced with another product that has lower

crystalline silica content in the same process.

Methods of Sample Analysis

(Appendix A of the Standard)

Appendix A of the silica standard lists

laboratory procedures for measuring

respirable crystalline silica in air samples.

Employers must make sure that all air

samples taken to meet the requirements

of the silica standard are analyzed by a

laboratory that follows the procedures in

Appendix A. If employers hire an outside

laboratory to do the analyses for respirable

crystalline silica, they can rely on a

statement from that laboratory that it follows

Appendix A. For example, the laboratory

could indicate that it analyzes samples

according to Appendix A of the standard in

the laboratory report or on its website.

Employee Notiﬁcation

Employers must notify each affected

employee of the results of the exposure

assessment within 15 working days

of completing it. “Affected” means all

employees whose exposures were assessed,

including employees whose exposures were

represented by other employees’ exposure

measurements, and those whose exposure

assessments were based on objective data.

The 15-day period for notiﬁcation starts when:

■ An employer following the performance

option ﬁnishes the exposure assessment;

■ An employer following the scheduled

monitoring approach receives the

laboratory results.

Employers must either notify each employee in

writing or post the results in a location that all

affected employees can access. In cases where

an employee might have moved onto another

job or jobsite, the assessment results could be

included with the employees’ ﬁnal paycheck.

Exposures can be characterized and reported

as a range (for example, between the action

level and the PEL), but must reﬂect exposures

that would occur if the employee were not

using a respirator.

When an exposure assessment reveals

exposures above the PEL, the written

notiﬁcation must also describe the corrective

action the employer is taking to reduce

employee exposures to or below the PEL.

Corrective actions include engineering

controls. However, if engineering controls

are not feasible or the employer needs more

than 15 days to identify the right engineering

controls, respiratory protection is the

corrective action that would be described in

the written notiﬁcation.

Occupational Safety and Health Administration

Observation of Monitoring

The employer must let affected employees

or their designated representatives

observe any air monitoring of employee

exposure to respirable crystalline silica.

When observation of monitoring requires

entry into an area where use of protective

clothing or equipment, such as a respirator,

is required, the employer must provide the

observer with that protective clothing or

equipment. The employer must provide the

protective clothing and equipment at no

cost, and make sure that the observer uses

such clothing or equipment.

However, if the observer does not need to

enter an area requiring the use of protective

clothing or equipment in order to effectively

observe monitoring (for example, if

monitoring can be viewed from outside the

hazardous areas), no protective clothing or

equipment would be needed.

REGULATED AREAS – PARAGRAPH (E) OF THE STANDARD

Regulated areas are workplace areas where

exposures to respirable crystalline silica are,

or can reasonably be expected to be, above

the PEL. The standard for general industry

and maritime requires employers to establish,

demarcate, and limit access to regulated

areas. The employer must also provide

respirators and make sure they are used by

those who must enter regulated areas.

The purpose of a regulated area is to:

■ Ensure that employees know that silica

levels are likely to exceed the PEL within

the regulated area;

■ Restrict the number of employees who

could be exposed above the PEL by

requiring the employer to mark areas

where exposures are or are likely to be

higher than the PEL; and

■ Ensure that all who enter are properly

protected with an appropriate respirator.

Establishing Regulated Areas

Employers must establish regulated areas

where exposures to airborne concentrations

of respirable crystalline silica are, or can

reasonably be expected to be, greater

than the PEL. Information used to measure

employees’ exposures can be used to

determine where regulated areas are

required and identify the boundaries of

these areas. For example, employers can

use any combination of personal samples

(air samples collected near the employee’s

breathing zone), or objective data such

as exposure mapping and real-time

measurements to establish regulated areas.

Demarcating Regulated Areas

Employers must demarcate (mark off)

regulated areas from the rest of the

workplace in a manner that decreases the

number of employees exposed to respirable

crystalline silica within the regulated area.

Cones, stanchions, tape, barricades, lines,

or textured ﬂooring are some of the ways of

marking the boundaries of regulated areas.

Employers must post a sign at each entrance

to regulated areas that reads:

DANGER

RESPIRABLE CRYSTALLINE SILICA

MAY CAUSE CANCER

CAUSES DAMAGE TO LUNGS

WEAR RESPIRATORY PROTECTION IN THIS AREA

AUTHORIZED PERSONNEL ONLY

The signs show employees that they are

entering a regulated area, and the content of

the sign ensures the employee will know the

hazards associated with the area, as well as

the need for respiratory protection.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Limiting Access to Regulated Areas

Employers must limit access to regulated

areas to:

■ Persons authorized by the employer and

required by work duties to be present in

the regulated area. This includes persons

whose work is with or near the respirable

crystalline silica-producing materials,

but may also include maintenance and

repair personnel, management, quality

control engineers, or other employees if

their job duties require them to be in the

regulated area;

■ Any person entering the area as a

designated representative of employees to

observe silica exposure monitoring; or

■ Any person authorized by the Occupational

Safety and Health Act or regulations issued

under it to be in a regulated area (e.g.,

OSHA enforcement personnel).

Access restrictions limit the number of

persons who may enter into or walk or drive

vehicles through areas where exposures

exceed the PEL. Therefore, it protects

employees who would otherwise be exposed

when needlessly spending time in or passing

through the regulated area.

Providing Respirators to those

Entering Regulated Areas

The employer must:

■ Provide each employee and the employee’s

designated representative entering

a regulated area with an appropriate

respirator that meets the requirements

for respiratory protection under the

Respiratory Protection standard; and,

■ Require the employee and representative to

use the respirator while in the regulated area.

Persons must put on respirators before

entering, and take off respirators after exiting

the regulated area. The employer must

provide and ensure the use of the appropriate

respirator to any employees or representatives

who enter these areas, regardless of their

work activities or the amount of time they

spend inside. Requiring all employees and

representatives to wear respirators in a

regulated area ensures that they are protected.

METHODS OF COMPLIANCE – PARAGRAPH (F) OF THE STANDARD

The methods of compliance section of the

standard requires employers to protect

employees following the hierarchy of controls,

which relies on engineering and work

practice controls for reducing exposures and

allows for respirator use, in addition to those

controls, only when feasible engineering

controls cannot reduce exposures to

acceptable levels. The methods of compliance

section also requires employers to prepare a

written exposure control plan, and it cross-

references other OSHA standards that apply

to abrasive blasting.

Engineering and Work

Practice Controls

Employers must use engineering and

work practice controls to reduce and keep

employee exposure to respirable crystalline

silica to or below the PEL of 50 μg/m

unless the employer can demonstrate that

such controls are not feasible. If feasible

engineering and work practice controls are

not able to reduce employee exposures to

or below the PEL, employers must still use

feasible controls to reduce exposures to the

lowest possible level and then use respiratory

protection along with those controls.

Occupational Safety and Health Administration

The main types of engineering controls for

silica are wet methods and local exhaust

ventilation. Wet methods involve applying

water or foam at the point of dust generation to

keep dust from getting into the air. An example

is a grinder that delivers water at the point of

contact. Local exhaust ventilation removes dust

by capturing it at or near the point where it is

created. An example is an exhaust hood that

captures dust at the point where it is created.

Another engineering control is isolation.

Isolation separates employees from the dust

source by containing the dust or isolating

employees. An example is a properly

ventilated control booth.

Work practice controls involve performing a

task in a way that reduces the likelihood or

levels of exposure. Work practice controls

are often used with engineering controls

to protect employees. Employees must

know the appropriate work practices for

maximizing the effectiveness of controls and

minimizing exposures. Examples of work

practice controls include:

■ Inspecting and maintaining controls to

prevent or ﬁx malfunctions that would

result in increased exposures;

■ Ensuring that tools with wet controls spray

water at the point of dust generation;

■ Positioning local exhaust hoods directly

over the exposure source and not opening

windows near the local exhaust source;

■ Wetting down silica dust before sweeping

it up; and

■ Scheduling work so that tasks that involve

high exposures are performed when no

other employees are in the area.

Reducing exposures through the primary use

of engineering and work practice controls is

known as the hierarchy of controls, and it is

a long-standing OSHA policy. Advantages of

engineering controls are that they:

■ Control crystalline silica-containing

dust particles at the source, thus

minimizing exposures to all persons in the

surrounding work area;

■ Are reliable, predictable, and provide

consistent levels of protection to a large

number of employees;

■ Can be monitored; and

■ Are generally less prone to human error than

is the use of personal protective equipment.

Under the hierarchy of controls, respirators

can be another effective way to protect

employees. However, respirators may be

less practical or effective than engineering

controls for the following reasons:

■ They must be selected for each worker,

ﬁtted, occasionally reﬁtted, and regularly

maintained (including replacing ﬁlters and

other parts as necessary).

■ Employees have to consistently and

correctly use properly ﬁtted respirators

but may resist wearing them because

respirators can be uncomfortable,

especially in hot weather.

■ Respirators may put a physical strain

on employees’ bodies, as a result of the

respirator’s weight and because they

increase breathing resistance. Employees

with some health conditions cannot wear

respirators because the physical strain of

wearing the respirator increases their risk

of illness, injury, and even death.

■ Respirators can create safety concerns

because they interfere with workers’ ability

to hear, see, smell, and communicate.

■ Respirators only protect the employees

wearing them.

Even when engineering and work practice

controls cannot reduce exposure levels

to or below the PEL, those controls must

be used to reduce exposures as low as

possible. This reduction in exposure levels

beneﬁts employees by reducing the required

protection factor of the respirator, and thus

increasing the choices of respirators that can

be used. For example, if feasible engineering

controls reduce exposures from 50 times to

less than 10 times the PEL, employers could

provide approved half-mask respirators with

an APF of 10 that may be lighter and easier to

use compared to full-facepiece respirators.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Written Exposure Control Plan

All employers covered by the standard must

develop and implement a written exposure

control plan. Written exposure control

plans describe workplace exposures and

ways to reduce those exposures, such as

engineering controls, work practices, and

housekeeping methods. The plans improve

employee protections by making sure

that employers identify all exposures and

controls to prevent overexposures. Such

plans are also useful for letting employees

know what kind of protections they should

expect to see on the job.

What Must be Included in a Written

Exposure Control Plan

Below is a list of what the employer must

include in each section of the written

exposure control plan, with general examples

of the types of information that could be

included and sample entries for tasks

conducted at a glass manufacturing plant.

The plan must include a description of

workplace tasks involving exposures to

respirable crystalline silica. Employers must

list all tasks that employees perform that could

expose them to respirable crystalline silica dust.

Example:

Raw Material Handling: Sand is delivered

from rail cars or trucks to storage silos through

enclosed, pneumatic conveyor systems.

Batch Operations: Sand is transferred from

storage facilities to weigh stations, mixers

and furnaces through enclosed pneumatic

conveyor systems.

The plan must include a description of

engineering controls, work practices, and

respiratory protection used to limit employee

exposure to respirable crystalline silica for

each task. For each task that employees

perform, employers must describe types of

controls used, like:

■ Enclosures,

■ Effective work practices, as in checking

the enclosure for leaks, and

■ If required, appropriate respiratory

protection, like a respirator with an APF

of 10.

Employers could also describe signs that

controls are not working effectively, such as

an increase in visible dust or no water being

delivered to the material.

Example:

Controls:

 For raw material handling and batch

operating tasks, pneumatic conveyor

systems are enclosed and maintained at

negative pressure.

 Water is misted onto sand before it is mixed

in batch operations.

Work practices:

 Check that connections between rail cars

or trucks and storage silos are effectively

sealed before transferring sand.

 Apply water mist to sand before batch

operations.

 Check to make sure sand is not released from

any point of the pneumatic transfer system. If

sand is being released, have a supervisor or

engineer inspect the system.

 Inspect enclosures and seals on the

pneumatic transfer system for damage

weekly.

 Measure pressure in the pneumatic system

daily.

Respiratory protection:

 No respirators are required during normal

operations.

 See respiratory protection program for

information on respirator requirements for

situations such as spills or maintenance.

The plan must include a description of

the housekeeping methods used to limit

employee exposure to respirable crystalline

silica. While employees are cleaning, dust

Occupational Safety and Health Administration

can become airborne and expose them to

silica. In this part of the written exposure

control plan, employers must list acceptable

cleaning methods that will be used to

prevent employees from being exposed and

any protections that are needed if certain

cleaning methods have to be used.

The Housekeeping section of the standard

requires that, when cleaning up dust that

can contribute to employee exposures to

respirable crystalline silica, employers must:

■ Not allow cleaning by dry brushing and

sweeping, unless methods such as wet

sweeping and HEPA-ﬁltered vacuuming

are not feasible;

■ Not allow cleaning of surfaces or

clothing with compressed air, unless the

compressed air is used together with

a ventilation system that effectively

captures the dust cloud or no other

cleaning method is feasible.

This section of the written plan would include

cleaning methods that are acceptable (e.g.,

wet sweeping), cleaning methods that are

unacceptable because acceptable cleaning

methods are feasible (e.g., dry sweeping),

and special instructions (e.g., use local

exhaust ventilation if compressed air must

be used). Hygiene-related subjects, such as

not using compressed air to clean clothing,

could also be addressed in this section of the

written exposure control plan.

Example:

 Use the central vacuum system for cleaning.

 Use a HEPA-ﬁltered vacuum for cleaning spills.

 Do not dry sweep.

Yearly Review of Written Exposure

Control Plans

The Respirable Crystalline Silica standard

requires employers to review and evaluate

the effectiveness of the written exposure

control plan at least once a year and update

it as necessary. A yearly review is needed

to make sure that all information in the plan

is up-to-date. For example, the employer

might have bought a new type of equipment

or asked employees to conduct a new task

involving exposure, and that information

needs to be described in the written plan.

Availability of the Written Exposure

Control Plan

Employers must allow the written exposure

control plan to be viewed or copied by

each employee covered by the standard,

their designated representative, and

representatives from OSHA or NIOSH,

upon request. Making the written exposure

control plan available to employees and

their designated representatives empowers

and protects employees by letting them

and their representatives know the silica

hazards the employer identiﬁed and controls

for those hazards. This allows employees

and representatives to question employers

if controls are not fully and properly

implemented or maintained. Likewise,

making written exposure control plans

readily available to OSHA or NIOSH allows

them to verify that employee protections

are effective. If OSHA inspects a workplace,

the OSHA Compliance Safety and Health

Ofﬁcer will ask to see the employer’s written

exposure control plan.

Sample Written Exposure Control Plans

To help employers develop written exposure

control plans, a sample plan is included

below. This sample shows an easy-to-use

format that can be changed to address the

speciﬁc tasks performed by each employee.

The sample plan meets the requirements of

the standard and contains the level of detail

that OSHA considers useful for employers

in helping them protect their employees.

As the sample shows, the plan can contain

useful information without being long or

complicated.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Unions, trade associations or professional

groups may offer sample written exposure

control plans or other assistance to

employers, which might be helpful, especially

if written exposure control plans are tailored

to a particular type of work performed.

Although such general guidance may be

helpful, employers must make sure that any

plan they use is tailored to address all the

information required by the standard and

all tasks, tools, and controls used by the

employer.

Some sample plans might call for more

information than is required by the silica

standard (for example, information about

exposure assessments, medical surveillance,

and training). Employers can include this

information in the plan if it is useful to them,

but they are not required to do so under the

silica standard.

Written Exposure Control Plan

Company: Countertops, Inc.

Person Completing the Plan, Title: Mary Smith, Owner

Description of Task:

 Stone or engineered stone slabs are cut using a gantry saw.

 Stone or engineered stone slabs are ground using an electric, handheld angle-grinder.

 Stone or engineered stone slabs are polished using a high-speed polisher.

Task/Control Description

 The gantry saw is operated with recirculated water in an enclosed, ventilated booth.

 The handheld grinders and polishers are operated using water, except for specialty cuts that are

performed dry, in which case the grinder is equipped with a shroud attached to a HEPA-ﬁltered vacuum.

Work Practices (for tasks described above that use wet method controls):

 Use a hose to wet the slab off before cutting, grinding, or polishing each section.

 Make sure the slab is positioned underneath the local exhaust hood when sawing, and check ﬂow rate

of that local exhaust hood daily.

 Make sure that water is continuously delivered to the point of cutting, grinding, or polishing.

 Change recirculated water if silt build-up occurs.

 Check for proper function of controls by making sure water is ﬂowing to the blade.

Work Practices for Dry Grinding and Polishing:

 Check that shroud is intact and properly installed. Keep shroud ﬂush with working surface,

whenever possible.

 Check that vacuum hosing is intact and not kinked or bent.

 Clean or change ﬁlters as needed to prevent clogging.

 Check for proper function of controls by making sure visible dust does not increase.

Respiratory protection:

 Respirators are not needed if controls are working and proper work practices are being followed.

Housekeeping:

 Hose down ﬂoor frequently and at the end of each work shift.

 Clean up wet slurry to prevent it from drying and becoming airborne.

Occupational Safety and Health Administration

Abrasive Blasting

In addition to complying with requirements to

use engineering controls and work practices

according to the hierarchy of controls,

employers that conduct abrasive blasting

operations using crystalline silica-containing

blasting agents or conduct abrasive blasting

on substrates that contain crystalline silica

must also comply with other relevant

standards. These standards include the

ventilation standard for general industry (29

CFR 1910.94), the mechanical paint removers

standard for shipyards (1915.34), and the

personal protective equipment standard for

shipyards (29 CFR 1915 Subpart I). This is

simply a cross-reference to other standards

that employers must comply with when

conducting abrasive blasting.

RESPIRATORY PROTECTION – PARAGRAPH (G) OF THE STANDARD

Employers must provide employees with

appropriate respirators where required by the

silica standard. The respirators must comply

with requirements of the silica standard and

with OSHA’s Respiratory Protection standard

(29 CFR 1910.134).

Employers must provide respiratory protection:

■ Where exposures exceed the PEL during

periods necessary to install or implement

feasible engineering and work practice

controls;

■ Where exposures exceed the PEL during

tasks, such as some maintenance and

repair tasks, for which engineering and

work practice controls are not feasible;

■ During tasks in which the employer has

implemented all feasible engineering

and work practice controls but exposures

remain above the PEL; and

■ While the employee is in a regulated area.

Where respirator use is required, employers

must implement a respiratory protection

program in accordance with the Respiratory

Protection standard. The respiratory protection

program ensures that respirators are properly

used in the workplace and are effective in

protecting employees. See the Small Entity

Compliance Guide for the Respiratory

Protection Standard for information on the

requirements of that standard.

Voluntary Use of Respirators

Employers may provide respirators at the

request of employees or let employees use

their own respirators when respirators are not

required under the silica standard.

See

the

Small

Entity Compliance Guide for the Respiratory

Protection Standard

for information about

employer responsibilities when employees

voluntarily wear respirators.

HOUSEKEEPING – PARAGRAPH (H) OF THE STANDARD

The Respirable Crystalline Silica standard

requires all employers covered by the

standard to avoid certain housekeeping

practices. When cleaning up dust that

could contribute to employee exposure to

respirable crystalline silica, employers must:

■ Not allow dry brushing or dry sweeping,

unless methods such as wet sweeping and

HEPA-ﬁltered vacuuming are not feasible;

■ Not allow cleaning of surfaces or

clothing with compressed air, unless the

compressed air is used together with

a ventilation system that effectively

captures the dust cloud or no other

cleaning method is feasible.

Cleaning methods such as dry sweeping,

dry brushing, and use of compressed air can

cause respirable crystalline silica dust to get

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

into the air and be inhaled by employees.

Therefore, the silica standard limits the

use of these cleaning methods to prevent

unnecessary exposures to employees.

Employers are required to use other cleaning

methods such as wet sweeping and HEPA-

ﬁltered vacuums, whenever feasible, because

such methods reduce employee exposures

by preventing silica-containing dust from

getting into the air.

Feasibility of Cleaning Methods

In a very limited number of cases, cleaning

methods such as wet sweeping or HEPA-

ﬁltered vacuums may not be safe or effective.

When wet methods or HEPA-ﬁltered

vacuuming would not be effective, would

cause damage, or would create a hazard in

the workplace, the employer is not required to

use these cleaning methods. However, even

in cases where one of those cleaning methods

may not be safe or effective, employers could

often use another acceptable method for

cleaning. For example, if it is not feasible to

wet sweep near electrical equipment, a HEPA-

ﬁltered vacuum could be used for cleaning.

Therefore, situations in which no acceptable

cleaning methods can be used are expected to

be very rare.

In those rare cases where the employer

needs to use cleaning methods such as dry

sweeping, dry brushing, or compressed air,

the employer must be able to show why

cleaning methods that decrease employee

exposures are not feasible.

When Employers Must Follow

Housekeeping Practices

The housekeeping requirements in the

silica standard apply only where cleaning

“could contribute to employee exposure

to respirable crystalline silica”. This phrase

clariﬁes that employers have to follow the

housekeeping requirements of the silica

standard only where employees could

be exposed to the very small (respirable)

crystalline silica particles as are found in

industrial sand or are created by high-energy

tasks such as grinding stone countertops.

MEDICAL SURVEILLANCE – PARAGRAPH (I) OF THE STANDARD

Medical surveillance is intended to (1) identify

respirable crystalline silica-related diseases

so that employees with those diseases

can take actions to protect their health; (2)

determine if an employee has any condition,

such as a lung disease, that might make him

or her more sensitive to respirable crystalline

silica exposure; and (3) determine the

employee’s ﬁtness to use respirators.

The standard speciﬁes which employees

must be offered medical surveillance, when

and how often the examinations must

offered, and the tests that make up medical

examinations. The standard also speciﬁes

the information that the employer must give

to the physician or other licensed health

care professional (PLHCP) who conducts

the examinations and the information that

the employer must ensure that the PLHCP

provides to the employee and employer.

All medical examinations and procedures

required by the standard must be performed

by a PLHCP. Medical surveillance must

be provided at no cost to employees, and

at a reasonable time and place. If getting

the medical examination requires the

employee to travel away from the worksite,

the employer is required to cover the cost

of travel. The employer must also pay

employees for time spent traveling and taking

medical examinations.

Occupational Safety and Health Administration

Which Employees Must be Offered

Medical Surveillance

Employers must make an initial or periodic

medical examination available to employees

who meet the exposure trigger. The triggers

for medical surveillance are:

1. Exposures above the PEL for 30 or more

days a year from June 23, 2018 through

June 22, 2020;

2. Exposures at or above the action level

for 30 or more days a year beginning

June 23, 2020.

Frequency of Medical Examinations

Employers must offer medical examinations:

■ Within 30 days of initial assignment (the

day the employee starts working in a job/

task in which he or she will be exposed at

the trigger point for 30 or more days per

year), unless the employee has had an

examination that meets the requirements

of the silica standard within the last

three years.

■ Every three years from the employee’s last

examination that met the requirements

of the silica standard, or more frequently

if recommended by the PLHCP, if the

employee will continue to perform tasks

that result in exposures at the trigger for

30 or more days per year.

A PLHCP might recommend more frequent

medical examinations based on factors such

as high exposure levels or a medical ﬁnding,

such as an X-ray suggesting silicosis.

Employers must make sure that employees

receive a dated copy of the PLHCP’s written

medical opinion for the employer, and the

employee can present that opinion to a

new employer as proof of a current medical

examination. Employers can determine when

they must offer an employee the next periodic

medical examination based on the examination

date on the written medical opinion.

Tests that Must be Included in the

Examination

An initial medical examination provided

under the silica standard must consist of:

■ A medical and work history that focuses

on: past, present, and anticipated

exposure to respirable crystalline

silica, dust, and other agents affecting

the respiratory system; any history of

respiratory system dysfunction, including

signs and symptoms of respiratory

disease (for example, shortness of breath,

cough, wheezing); history of tuberculosis;

and smoking status and history;

■ A physical examination that focuses on

the respiratory system;

■ A digital or ﬁlm chest X-ray interpreted

according to the International Labour

Ofﬁce (ILO) International Classiﬁcation

of Radiographs of Pneumoconioses by a

National Institute for Occupational Safety

and Health (NIOSH)-certiﬁed B Reader

(this involves a certiﬁed physician reading

the X-ray according to certain procedures

to determine if it shows signs of diseases

such as silicosis);

■ A lung function (spirometry) test that

includes forced vital capacity (the total

amount of air that is forcefully blown

out after taking a full breath), forced

expiratory volume in one second (the

amount of air forcefully blown out in the

ﬁrst second), and FEV1/FVC ratio (the

speed of air that is forcefully blown out),

administered by a spirometry technician

with a current certiﬁcate from a NIOSH-

approved spirometry course;

■ Testing for latent tuberculosis infection;

■ Any other tests deemed appropriate

(medically necessary and related to

respirable crystalline silica exposure) by

the PLHCP.

Periodic examinations include all these

tests, with the exception of testing for latent

tuberculosis, which is required only for the

initial examination.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Employees who must be offered medical

surveillance are at risk of developing

respirable crystalline silica-related diseases,

and the required tests are the minimum tests

needed to look for those diseases. More tests

may also be needed to address an employee’s

medical complaint or a ﬁnding related to

respirable crystalline silica exposure, such as

abnormal lung function. The standard gives

the PLHCP the ﬂexibility to order additional

tests he or she deems appropriate. Employers

must make those tests ordered by the PLHCP

available to the employee.

Information the Employer Must

Provide to the PLHCP

The employer must ensure that the

examining PLHCP has a copy of the standard

and must provide the PLHCP with:

■ A description of the employee’s past,

current, and future duties as they relate to

respirable crystalline silica exposure;

■ The employee’s past, current, and

future levels of exposure to respirable

crystalline silica;

■ A description of any personal protective

equipment used, or to be used, by the

employee, including when and for how

long the employee has used or will use

that equipment; and

■ Information from records of employment-

related medical examinations previously

provided to the employee and currently

within the control of the employer.

The PLHCP needs this information to evaluate

the employee’s health in relation to assigned

duties and ﬁtness to use personal protective

equipment, such as respirators. The

information provided to the PLHCP includes

only that within the control of the employer;

the employer is not required to obtain

information from past employers.

The PLHCP’s Written Medical

Report for the Employee

The employer must ensure that the PLHCP

explains the results of the medical examination

to the employee and gives the employee a

written medical report within 30 days of each

medical examination performed. Only the

employee receives the written medical report,

and the employer does not receive a copy of

this report. The report must contain:

■ A description of the medical examination

results, including any medical condition(s)

that would place the employee at increased

risk of material impairment of health from

exposure to respirable crystalline silica

Medical Evaluation Requirements under

the Respiratory Protection Standard

Employees who are required to wear respirators

must receive medical evaluations required by

the Respiratory Protection standard before they

are ﬁt tested for a respirator or wear a respirator

in the workplace. The medical evaluation for

the Respiratory Protection standard can be

combined with the medical examination for

silica, and employers could have the PLHCP

conduct both the evaluation for respirator use

and examination for silica at the same time.

They could also have employees evaluated for

respirator use before they wear a respirator and

then offer the silica examination later, according

to the required time limits of the silica standard.

Also note that under the Respiratory Protection

standard, employers are required to provide

another medical evaluation if employees report

medical signs or symptoms related to the

ability to wear a respirator.

(

see

29 CFR 1910.134, Respiratory Protection,

and OSHA’s

Small Entity Compliance Guide

for the Respiratory Protection Standard

Publication #3384).

Occupational Safety and Health Administration

(any health condition that might make the

employee more sensitive to exposure).

The report must also describe any medical

conditions that require further evaluation or

treatment;

■ Any recommended limitations on the

employee’s use of respirators;

■ Any recommended limitations on

respirable crystalline silica exposure; and

■ A statement that the employee should be

examined by a specialist if the B-reader

classiﬁes the chest X-ray provided under

the silica standard as 1/0 or higher

(X-ray evidence of silicosis in employees

exposed to respirable crystalline silica),

or if the PLHCP otherwise recommends

referral to a specialist.

The PLHCP’s Written Medical

Opinion for the Employer

The employer must get a written medical

opinion from the PLHCP within 30 days of the

medical examination. The written opinion

must contain only the following information:

■ The date of the examination;

■ A statement that the examination has met

the requirements of the silica standard; and

■ Any recommended limitations on the

employee’s use of respirators.

If the employee gives written authorization,

the written medical opinion to the employer

must also contain one or both of the following:

■ Any recommended limitations on the

employee’s exposure to respirable

crystalline silica;

■ A statement that the employee should

be examined by a specialist if the B

reader classiﬁes the chest X-ray provided

under the silica standard as 1/0 or higher

(X-ray evidence of silicosis in employees

exposed to respirable crystalline silica),

or if the PLHCP otherwise recommends

referral to a specialist.

The purpose of the employee written

authorization requirement is to enhance

employee privacy and encourage employees

to participate in medical surveillance

by minimizing fears about retaliation or

discrimination based on medical ﬁndings.

Employers must make sure that each employee

receives a copy of the written medical opinion

within 30 days of each medical examination.

The PLHCP can give a copy of the opinion

directly to the employee, so long as the time

deadline is met. As indicated above, employees

can show this opinion to future employers as

proof that medical surveillance requirements

under the silica standard are current.

Sample Medical Forms in

Appendix B of the Standard

Appendix B contains guidelines for PLHCPs

and blank sample forms for the medical

report for the employee, the medical opinion

for the employer, and an authorization form

to allow limitations on respirable crystalline

silica exposure or recommendations for

a specialist examination to be reported to

the employer. Employers must make sure

that PLHCPs who will conduct medical

examinations required by the silica standard

have a copy of the standard, including

Appendix B. The purpose of Appendix B

is to give PLHCPs medical information and

guidance to help them conduct medical

examinations that meet the requirements of

the silica standard.

Examples of completed forms are included in

this guide. Sample Form 1 is a sample of the

written medical report that the PLHCP provides

to the employee. The employer does not

receive a copy of the written medical report.

Sample Form 2 is a sample of the written

medical opinion that the PLHCP provides to

the employer. The PLHCP indicates the type

of examination and recommendations on

use of a respirator. If the employee signs the

written authorization (Sample Form 3) allowing

the PLHCP to release further information

to the employer, the PLHCP must include

any recommend limitations on exposure to

respirable crystalline silica and/or any referral

to a specialist.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Small Entity Compliance Guide for General Industry and Maritime

Draft – Do not Quote or Cite 2/22/2017

SAMPLE FORM 1: WRITTEN MEDICAL REPORT FOR EMPLOYEE

EMPLOYEE NAME: Joe Smith DATE OF EXAMINATION: July 1, 2018

TYPE OF EXAMINATION:

[x] Initial examination [ ] Periodic examination [ ] Specialist examination

[ ] Other: _______________________________________________________________________________________

RESULTS OF MEDICAL EXAMINATION:

Physical Examination – [x] Normal [ ] Abnormal (see below) [ ] Not performed

Chest X-Ray – [x] Normal [ ] Abnormal (see below) [ ] Not performed

Breathing Test (Spirometry) – [ ] Normal [x] Abnormal (see below) [ ] Not performed

Test for Tuberculosis – [x] Normal [ ] Abnormal (see below) [ ] Not performed

Other:___________________ [ ] Normal [ ] Abnormal (see below) [ ] Not performed

Results reported as abnormal: Breathing test (Spirometry) shows an obstructive pattern.

__________________________________________________________________________________________________

[x] Your health may be at increased risk from exposure to respirable crystalline silica due to the following:

Continued unprotected exposure to respirable crystalline silica may further damage your lungs.

RECOMMENDATIONS:

[ ] No limitations on respirator use

[x] Recommended limitations on use of respirator: A powered air purifying respirator (PAPR) is the only type of

respirator you can safely wear. A PAPR will give you higher protection from silica exposure and will decrease strain on

your heart and lungs.

[x] Recommended limitations on exposure to respirable crystalline silica: Ideally, you may want to consider a position

that doesn’t involve exposure to substances hazardous to your lungs, such as respirable crystalline silica. If that is not

possible, be sure to always wear a respirator when needed to protect your lungs.

Dates for recommended limitations, if applicable: Indefinitely unless otherwise indicated by a specialist.

[x] I recommend that you be examined by a Board Certified Specialist in Pulmonary Disease or Occupational Medicine

[x] Other recommendations*: See your personal physician about the mole on your neck.

__________________________________________________________________________________________________

Your next periodic examination for silica exposure should be in: [ ] 3 years [x] Other: 1 year, July 1, 2019

Examining Provider: Dr. Jones Date: July 1, 2018

(signature)

Provider Name: Dr. Jones Health Clinic

Office Address: _1111 Main Street, Washington, DC Office Phone: _123-456-7890__________________

*These findings may not be related to respirable crystalline silica exposure or may not be work-related, and therefore

may not be covered by the employer. These findings may necessitate follow-up and treatment by your personal

physician.

Respirable Crystalline Silica standard (§ 1910.1053 or 1926.1153)

Occupational Safety and Health Administration

Small Entity Compliance Guide for General Industry and Maritime

Draft – Do not Quote or Cite 2/22/2017

SAMPLE FORM 2: WRITTEN MEDICAL OPINION FOR EMPLOYER

EMPLOYER: _Glass, Inc.___________________________________________

EMPLOYEE NAME: __Joe Smith_________________ DATE OF EXAMINATION: July 1, 2018________

TYPE OF EXAMINATION:

[x] Initial examination [ ] Periodic examination [ ] Specialist examination

[ ] Other: _______________________________________________________________________________________

USE OF RESPIRATOR:

[ ] No limitations on respirator use

[x] Recommended limitations on use of respirator: A powered air purifying respirator (PAPR) is the only type of

respirator Mr. Smith can safely wear.

Dates for recommended limitations, if applicable: Indefinitely, unless otherwise recommended by specialist

The employee has provided written authorization for disclosure of the following to the employer (if applicable):

[x] This employee should be examined by an American Board Certified Specialist in Pulmonary Disease or Occupational

Medicine

[ ] Recommended limitations on exposure to respirable crystalline silica:_______________________________________

__________________________________________________________________________________________________

Dates for exposure limitations noted above: _______________ to _______________

MM/DD/YYYY MM/DD/YYYY

NEXT PERIODIC EVALUATION: [ ] 3 years [x] Other: _1 year, July 1, 2019

Examining Provider: __Dr. Jones____________________________ Date: July 1, 2018

(signature)

Provider Name: _Dr. Jones Health Clinic Provider’s specialty: None, general practitioner

Office Address: _1111 Main Street, Washington, DC________ Office Phone: _123-456-7890_____________

[x] I attest that the results have been explained to the employee.

The following is required to be checked by the Physician or other Licensed Health Care Professional (PLHCP):

[x] I attest that this medical examination has met the requirements of the medical surveillance section of the OSHA

Respirable Crystalline Silica standard (§ 1910.1053(h) or 1926.1153(h)).

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Small Entity Compliance Guide for General Industry and Maritime

Draft – Do not Quote or Cite 2/22/2017

SAMPLE FORM 3: AUTHORIZATION FOR CRYSTALLINE SILICA OPINION TO EMPLOYER

This medical examination for exposure to crystalline silica could reveal a medical condition that results in

recommendations for (1) limitations on respirator use, (2) limitations on exposure to crystalline silica, or (3)

examination by a specialist in pulmonary disease or occupational medicine. Recommended limitations on

respirator use will be included in the written opinion to the employer. If you want your employer to know about

limitations on crystalline silica exposure or recommendations for a specialist examination, you will need to give

authorization for the written opinion to the employer to include one or both of those recommendations.

I hereby authorize the opinion to the employer to contain the following information, if relevant

(please check all that apply):

Recommendations for limitations on crystalline silica exposure

Recommendation for a specialist examination

I do not authorize the opinion to the employer to contain anything other than recommended limitations on

respirator use.

Please read and initial:

_X_ I understand that if I do not authorize my employer to receive the recommendation for specialist

examination, the employer will not be responsible for arranging and covering costs of a specialist

examination under the OSHA standard for respirable crystalline silica.

__Joe Smith_______

Name (printed)

__Joe Smith______________________________ July 1, 2018______________________

Signature Date

Occupational Safety and Health Administration

Additional Examinations

by a Specialist

The employer must make the specialist

examination available within 30 days of

receiving the written medical opinion that

includes the PLHCP’s recommendation for

a specialist examination. The specialists

must be either an American Board Certiﬁed

Specialist in Pulmonary Disease or an

American Board Certiﬁed Specialist in

Occupational Medicine.

The employer must ensure the specialist:

■ Receives the same information that the

employer is required to provide the PLHCP

(see above);

■ Explains the results of the medical

examination to the employee and provides

each employee with a written medical

report within 30 days of the examination;

and

■ Provides the employer a written medical

opinion within 30 days of the examination.

The specialist’s written medical report to

the employee must contain the following

information:

■ A description of the medical examination

results, including any medical condition(s)

that may make an employee more

sensitive to respirable crystalline silica

exposure and any medical conditions that

require further evaluation or treatment;

■ Any recommended limitations on the

employee’s use of respirators; and

■ Any recommended limitations on

respirable crystalline silica exposure.

The specialist’s written medical opinion

for the employer must include only the

following:

■ The date of the examination; and

■ Any recommended limitations on the

employee’s use of respirators.

If the employee gives written authorization,

the written opinion to the employer must

also contain any recommended limitations

on the employee’s exposure to respirable

crystalline silica.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

COMMUNICATION OF HAZARDS – PARAGRAPH (J) OF

THE STANDARD

Employers must train and inform employees

covered by the silica standard about

respirable crystalline silica hazards and the

methods the employer uses to limit their

exposures to those hazards. Employers

must cover the cost of training and must pay

employees for the time spent in training.

OSHA’s Hazard Communication Standard

Employers must also comply with OSHA’s Hazard Communication standard (HCS) (29 CFR 1910.1200). HCS

requires employers to inform employees about hazardous chemicals in the workplace, such as respirable

crystalline silica, through their written hazard communication programs. Written hazard communication

programs must describe how requirements for container labels, safety data sheets (SDSs), and employee

training will be met. As part of their hazard communication program for respirable crystalline silica,

employers must address at least these health hazards: cancer, lung effects, immune system effects, and

kidney effects.

Under the HCS, employers must:

 Inform employees about the general requirements of HCS, as well as where and how they can view the

written hazard communication program, lists of hazardous chemicals, and SDSs.

 Train employees on how the presence or release of hazardous chemicals in the work area is detected;

in the case of respirable crystalline silica, this could include methods the employer uses to measure

exposures, such as air sampling or objective data. Employers can train employees to recognize that an

increase in visible dust is a sign that a control may not be working properly.

 Train employees on the details of the workplace-speciﬁc hazard communication program developed

by the employer, such as container labels, the workplace labeling system, SDSs (including the order in

which the information is presented), and how employees can get and use hazard information.

See

OSHA’s

HAZARD COMMUNICATION: Small Entity Compliance Guide for Employers that Use

Hazardous Chemicals [OSHA Publication # 3695]

for more information on preparing a written hazard

communication program and employer requirements for labeling, SDSs, and training.

Signs at Entrances to

Regulated Areas

The employer must post a sign at each

entrance to regulated areas. The sign must

include the following wording:

DANGER

RESPIRABLE CRYSTALLINE SILICA

MAY CAUSE CANCER

CAUSES DAMAGE TO LUNGS

WEAR RESPIRATORY PROTECTION IN THIS AREA

AUTHORIZED PERSONNEL ONLY

Training Topics

The employer must ensure that employees

trained under the silica standard can

demonstrate knowledge and understanding

of at least:

1. Health hazards associated with respirable

crystalline silica exposure. For respirable

crystalline silica, the health hazards

include: cancer, lung effects, immune

system effects, and kidney effects.

2. Speciﬁc workplace tasks that could expose

employees to respirable crystalline silica.

Occupational Safety and Health Administration

3. Speciﬁc measures the employer is

implementing to protect employees from

respirable crystalline silica exposure,

including engineering controls, work

practices, and respirators to be used. This

training must be speciﬁc for the workplace

and task that each employee performs. In

general industry and maritime, training

subjects would commonly include:

■ Signs that the controls may not be

working effectively (e.g., visible dust

emission).

■ Work practices needed for the controls

to function effectively (e.g., not opening

windows near local exhaust sources,

positioning the local exhaust hood

directly over the exposure source).

If employees covered by the general

industry and maritime standard operate

equipment with built-in controls that are

under their control, those employees

are required to demonstrate knowledge

and understanding of the full and proper

implementation of those controls.

4. The contents of the Respirable Crystalline

Silica standard. This would involve a

description of the standard’s requirements.

5. The purpose and a description of the

medical surveillance program required

under the standard. Topics that employers

could communicate to their employees as

part of this training include:

■ That employers must offer medical

examinations to employees who meet

the exposure trigger for 30 or more

days a year;

■ That employers must offer medical

examinations at no cost to the

employee, including additional silica-

related tests or specialist examinations

recommended by the PLHCP;

■ The types of tests included in the

medical examinations;

■ Symptoms associated with respirable

crystalline silica-related diseases;

■ Information that must be included

in the written medical report for the

employee versus the written medical

opinion for the employer;

■ Information that must not be included

in written medical opinion to the

employer without written authorization

from the employee (recommendations

for limitations on exposures to silica

and for specialist referrals);

■ The importance of keeping a copy of

the written medical opinion to the

employer as proof of a current medical

examination to avoid unnecessary

testing; and

■ That employers cannot retaliate or

discriminate against employees for

participating in medical surveillance.

The employer is not required to provide

all required training if an employee is

already able to demonstrate knowledge and

understanding of training topics such as health

hazards, the contents of the silica standard, or

medical surveillance requirements. However,

some site-speciﬁc or employer-speciﬁc

training is always necessary, such as training

on speciﬁc tasks that could result in exposures

in that workplace and speciﬁc controls or work

practices that the employer is using.

When Employees Must be Trained

Employees must be trained at the time they

are assigned to a position involving exposure

to respirable crystalline silica.

Additional training must be provided as often

as necessary to ensure that employees know

and understand respirable crystalline silica

hazards and the protections available in their

workplace. Examples of when additional

training would be required include:

■ When the employer asks an employee to

perform a task that is new to that employee;

■ When the employer introduces new

protections;

■ When an employee is working in a manner

that suggests he or she has forgotten

what was learned in training.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Training Methods

The silica standard does not require the

employer to use any particular method

for training employees. Employers could

use hands-on training, videotapes, slide

presentations, classroom instruction,

informal discussions during safety meetings,

written materials, or any combination of

these methods to train employees.

In order for employees to demonstrate

knowledge and understanding of the training

subjects, training must be done in a manner

and language that employees understand.

This may mean, for example, providing

materials, instruction, or assistance in Spanish

rather than English for Spanish-speaking

employees who do not understand English,

and using methods other than printed reading

materials if the employee is not able to read.

To ensure that employees understand the

material presented during training, it is

critical that trainees have the opportunity

to ask questions and receive answers if

they do not fully understand the material

that is presented to them. When videotape

presentations or computer-based programs

are used, this requirement may be met by

having a qualiﬁed trainer available to address

questions after the presentation, or providing

a telephone hotline so that trainees will have

direct access to a qualiﬁed trainer.

Employers can determine if employees know

and understand the training topics through

discussion of the required training subjects,

written tests, or oral quizzes.

Making a Copy of the

Standard Available

Employers must make a copy of the

Respirable Crystalline Silica standard

available at no cost to each employee

covered by the standard. This could simply

involve allowing employees to view a printed

or electronic copy in a reasonable location.

RECORDKEEPING – PARAGRAPH (K) OF THE STANDARD

Records can demonstrate employer

compliance with the standard, and can assist

in diagnosing and identifying workplace-

related illnesses. Therefore, employers

are required to make and keep accurate

records of air monitoring data and objective

data used to assess employee exposures

to respirable crystalline silica under the

standard, as well as records of medical

surveillance provided under the standard.

Air Monitoring Data

Employers must make and keep an accurate

record of all air monitoring performed to comply

with the standard. The record must indicate:

■ The date of the measurement for each

sample taken;

■ The task monitored;

■ Sampling and analytical methods used;

■ The number, duration, and results of

samples taken;

■ The identity of the laboratory that

performed the analysis;

■ The type of personal protective equipment

used (e.g., type of respirators worn); and

■ The name, social security number, and job

classiﬁcation of all employees represented

by the monitoring, indicating which

employees were actually monitored.

Objective Data

When an employer relies on objective data

to comply with the silica standard, the

employer must make and keep an accurate

record of the objective data. The record

must include at least:

■ The crystalline silica-containing material

in question;

■ The source of the objective data;

■ The testing protocol and results of testing;

■ A description of the process, task, or activity

on which the objective data were based; and

■ Any other data relevant to the process,

task, activity, material, or exposures on

which the objective data are based.

Occupational Safety and Health Administration

Medical Surveillance

The employer must make and keep an

accurate record for each employee provided

medical surveillance under the standard.

The record must include the following

information about the employee:

■ Name and social security number;

■ A copy of the PLHCPs’ and specialists’

written opinions; and

■ A copy of the information that the employer

is required to provide to the PLHCPs

and specialists (i.e., a description of the

employee’s former, current, and anticipated

duties as they relate to crystalline silica

exposure; a description of the employee’s

former, current, and anticipated respirable

crystalline silica exposure levels; a

description of the personal protective

equipment used by the employee; and

information from previous employment-

related medical examinations that is

currently within the control of the employer).

Keeping and Making Medical

Records Available

Exposure and medical records must be

kept and made available to employees, their

representatives, and OSHA in accordance

with OSHA’s access to employee exposure

and medical records regulation.

OSHA’s Access to Employee Exposure and Medical Records Regulation

A separate OSHA regulation (29 CFR 1910.1020, Access to Employee Exposure and Medical Records)

addresses requirements for maintaining exposure and medical records. In general, exposure records (including

air monitoring and objective data) must be kept for at least 30 years, and medical records must be kept for at

least the duration of employment plus 30 years. It is necessary to keep these records for extended periods

because silica-related diseases such as cancer often cannot be detected until several decades after exposure.

However, if an employee works for an employer for less than one year, the employer does not have to keep the

medical records after employment ends, as long as the employer gives those records to the employee.

DATES – PARAGRAPH (L) OF THE STANDARD

General industry and maritime employers must

comply with all requirements of the standard

by June 23, 2018, except for phase-in dates

for medical surveillance and for engineering

controls in the oil and gas industry.

■ The obligation for employers to offer

medical surveillance begins on June 23,

2018 for employees who will be exposed

above the PEL of 50 μg/m

for 30 or more

days per year and on June 23, 2020 for

employees who will be exposed at or

above the action level of 25 μg/m

for

30 or more days per year. This schedule

initiates medical surveillance efforts for

those employees who are at greatest risk

and provides most employers time to fully

evaluate installed engineering controls

and determine which employees meet the

action level trigger for medical surveillance.

■ The obligation for engineering controls for

hydraulic fracturing operations in the oil

and gas industry begins on June 23, 2021.

In the period between June 23, 2018 and

June 23, 2021, employers must comply

with all other requirements of the standard

for hydraulic fracturing operations,

including requirements for respiratory

protection to protect employees exposed

to respirable crystalline silica at levels that

exceed the PEL of 50 μg/m

Prior to June 23, 2018, the previous PEL (a

formula that is approximately equivalent to

100 μg/m

of respirable crystalline silica as

an 8-hour TWA) remains in effect for general

industry employers.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

APPENDIX I: OSHA RESPIRABLE CRYSTALLINE SILICA

STANDARD FOR GENERAL INDUSTRY AND MARITIME

§1910.1053 Respirable

crystalline silica

(a) Scope and application. (1) This section

applies to all occupational exposures to

respirable crystalline silica, except:

(i) Construction work as deﬁned in 29 CFR

1910.12(b) (occupational exposures to

respirable crystalline silica in construction

work are covered under 29 CFR 1926.1153);

(ii) Agricultural operations covered under 29

CFR part 1928; and

(iii) Exposures that result from the processing

of sorptive clays.

(2) This section does not apply where the

employer has objective data demonstrating

that employee exposure to respirable

crystalline silica will remain below 25

micrograms per cubic meter of air (25 μg/m

)

as an 8-hour time-weighted average (TWA)

under any foreseeable conditions.

(3) This section does not apply if the

employer complies with 29 CFR 1926.1153

and:

(i) The task performed is indistinguishable

from a construction task listed on Table 1 in

paragraph (c) of 29 CFR 1926.1153; and

(ii) The task will not be performed regularly in

the same environment and conditions.

(b) Deﬁnitions. For the purposes of this

section the following deﬁnitions apply:

Action level means a concentration of

airborne respirable crystalline silica of 25 μg/

, calculated as an 8-hour TWA.

Assistant Secretary means the Assistant

Secretary of Labor for Occupational Safety

and Health, U.S. Department of Labor, or

designee.

Director means the Director of the National

Institute for Occupational Safety and Health

(NIOSH), U.S. Department of Health and

Human Services, or designee.

Employee exposure means the exposure

to airborne respirable crystalline silica that

would occur if the employee were not using a

respirator.

High-efﬁciency particulate air [HEPA] ﬁlter

means a ﬁlter that is at least 99.97 percent

efﬁcient in removing mono-dispersed

particles of 0.3 micrometers in diameter.

Objective data means information, such

as air monitoring data from industry-

wide surveys or calculations based on the

composition of a substance, demonstrating

employee exposure to respirable crystalline

silica associated with a particular product

or material or a speciﬁc process, task, or

activity. The data must reﬂect workplace

conditions closely resembling or with a

higher exposure potential than the processes,

types of material, control methods, work

practices, and environmental conditions in

the employer’s current operations.

Physician or other licensed health care

professional [PLHCP] means an individual

whose legally permitted scope of practice (i.e.,

license, registration, or certiﬁcation) allows

him or her to independently provide or be

delegated the responsibility to provide some

or all of the particular health care services

required by paragraph (i) of this section.

Regulated area means an area, demarcated

by the employer, where an employee’s

exposure to airborne concentrations of

respirable crystalline silica exceeds, or can

reasonably be expected to exceed, the PEL.

Respirable crystalline silica means quartz,

cristobalite, and/or tridymite contained in

Occupational Safety and Health Administration

airborne particles that are determined to be

respirable by a sampling device designed

to meet the characteristics for respirable-

particle-size-selective samplers speciﬁed

in the International Organization for

Standardization (ISO) 7708:1995: Air Quality –

Particle Size Fraction Deﬁnitions for Health-

Related Sampling.

Specialist means an American Board

Certiﬁed Specialist in Pulmonary Disease

or an American Board Certiﬁed Specialist in

Occupational Medicine.

This section means this respirable crystalline

silica standard, 29 CFR 1910.1053.

employer shall ensure that no employee

is exposed to an airborne concentration

of respirable crystalline silica in excess of

50 μg/ m

, calculated as an 8-hour TWA.

(d) Exposure assessment—(1) General.

The employer shall assess the exposure of

each employee who is or may reasonably

be expected to be exposed to respirable

crystalline silica at or above the action level in

accordance with either the performance option

in paragraph (d)(2) or the scheduled monitoring

option in paragraph (d)(3) of this section.

(2) Performance option. The employer shall

assess the 8-hour TWA exposure for each

employee on the basis of any combination

of air monitoring data or objective data

sufﬁcient to accurately characterize employee

exposures to respirable crystalline silica.

(3) Scheduled monitoring option. (i) The

employer shall perform initial monitoring

to assess the 8-hour TWA exposure for

each employee on the basis of one or more

personal breathing zone air samples that

reﬂect the exposures of employees on each

shift, for each job classiﬁcation, in each work

area. Where several employees perform

the same tasks on the same shift and in the

same work area, the employer may sample

a representative fraction of these employees

in order to meet this requirement. In

representative sampling, the employer shall

sample the employee(s) who are expected

to have the highest exposure to respirable

crystalline silica.

(ii) If initial monitoring indicates that employee

exposures are below the action level, the

employer may discontinue monitoring for

those employees whose exposures are

represented by such monitoring.

(iii) Where the most recent exposure

monitoring indicates that employee

exposures are at or above the action level

but at or below the PEL, the employer shall

repeat such monitoring within six months of

the most recent monitoring.

(iv) Where the most recent exposure

monitoring indicates that employee

exposures are above the PEL, the employer

shall repeat such monitoring within three

months of the most recent monitoring.

(v) Where the most recent (non-initial)

exposure monitoring indicates that employee

exposures are below the action level, the

employer shall repeat such monitoring within

six months of the most recent monitoring

until two consecutive measurements, taken

7 or more days apart, are below the action

level, at which time the employer may

discontinue monitoring for those employees

whose exposures are represented by such

monitoring, except as otherwise provided in

paragraph (d)(4) of this section.

(4) Reassessment of exposures. The

employer shall reassess exposures whenever

a change in the production, process, control

equipment, personnel, or work practices may

reasonably be expected to result in new or

additional exposures at or above the action

level, or when the employer has any reason

to believe that new or additional exposures at

or above the action level have occurred.

(5) Methods of sample analysis. The employer

shall ensure that all samples taken to satisfy

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

the monitoring requirements of paragraph (d)

of this section are evaluated by a laboratory

that analyzes air samples for respirable

crystalline silica in accordance with the

procedures in Appendix A to this section.

(6) Employee notiﬁcation of assessment

results. (i) Within 15 working days after

completing an exposure assessment in

accordance with paragraph (d) of this section,

the employer shall individually notify each

affected employee in writing of the results

of that assessment or post the results in an

appropriate location accessible to all affected

employees.

(ii) Whenever an exposure assessment

indicates that employee exposure is above

the PEL, the employer shall describe in the

written notiﬁcation the corrective action

being taken to reduce employee exposure to

or below the PEL.

(7) Observation of monitoring. (i) Where air

monitoring is performed to comply with the

requirements of this section, the employer

shall provide affected employees or their

designated representatives an opportunity

to observe any monitoring of employee

exposure to respirable crystalline silica.

(ii) When observation of monitoring requires

entry into an area where the use of protective

clothing or equipment is required for any

workplace hazard, the employer shall provide

the observer with protective clothing and

equipment at no cost and shall ensure

that the observer uses such clothing and

equipment.

(e) Regulated areas—(1) Establishment. The

employer shall establish a regulated area

wherever an employee’s exposure to airborne

concentrations of respirable crystalline silica

is, or can reasonably be expected to be, in

excess of the PEL.

(2) Demarcation. (i) The employer shall

demarcate regulated areas from the rest of

the workplace in a manner that minimizes the

number of employees exposed to respirable

crystalline silica within the regulated area.

(ii) The employer shall post signs at all entrances

to regulated areas that bear the legend speciﬁed

in paragraph (j)(2) of this section.

(3) Access. The employer shall limit access to

regulated areas to:

(A) Persons authorized by the employer and

required by work duties to be present in the

regulated area;

(B) Any person entering such an area as a

designated representative of employees for

the purpose of exercising the right to observe

monitoring procedures under paragraph (d)

of this section; and

Safety and Health Act or regulations issued

under it to be in a regulated area.

(4) Provision of respirators. The employer shall

provide each employee and the employee’s

designated representative entering a

regulated area with an appropriate respirator

in accordance with paragraph (g) of this

section and shall require each employee and

the employee’s designated representative to

use the respirator while in a regulated area.

(f) Methods of compliance—(1) Engineering

and work practice controls. The employer

shall use engineering and work practice

controls to reduce and maintain employee

exposure to respirable crystalline silica to

or below the PEL, unless the employer can

demonstrate that such controls are not

feasible. Wherever such feasible engineering

and work practice controls are not sufﬁcient

to reduce employee exposure to or below

the PEL, the employer shall nonetheless use

them to reduce employee exposure to the

lowest feasible level and shall supplement

them with the use of respiratory protection

that complies with the requirements of

paragraph (g) of this section.

Occupational Safety and Health Administration

(2) Written exposure control plan. (i) The

employer shall establish and implement a

written exposure control plan that contains at

least the following elements:

(A) A description of the tasks in the

workplace that involve exposure to

respirable crystalline silica;

(B) A description of the engineering controls,

work practices, and respiratory protection

used to limit employee exposure to respirable

crystalline silica for each task; and

measures used to limit employee exposure to

respirable crystalline silica.

(ii) The employer shall review and evaluate

the effectiveness of the written exposure

control plan at least annually and update it

as necessary.

(iii) The employer shall make the written

exposure control plan readily available for

examination and copying, upon request, to

each employee covered by this section, their

designated representatives, the Assistant

Secretary and the Director.

(3) Abrasive blasting. In addition to the

requirements of paragraph (f)(1) of this

section, the employer shall comply with other

OSHA standards, when applicable, such as

29 CFR 1910.94 (Ventilation), 29 CFR 1915.34

(Mechanical paint removers), and 29 CFR 1915

Subpart I (Personal Protective Equipment),

where abrasive blasting is conducted using

crystalline silica-containing blasting agents,

or where abrasive blasting is conducted on

substrates that contain crystalline silica.

(g) Respiratory protection—(1) General.

Where respiratory protection is required

by this section, the employer must provide

each employee an appropriate respirator

that complies with the requirements of this

paragraph and 29 CFR 1910.134. Respiratory

protection is required:

(i) Where exposures exceed the PEL during

periods necessary to install or implement

feasible engineering and work practice controls;

(ii) Where exposures exceed the PEL during

tasks, such as certain maintenance and

repair tasks, for which engineering and work

practice controls are not feasible;

(iii) During tasks for which an employer has

implemented all feasible engineering and

work practice controls and such controls

are not sufﬁcient to reduce exposures to or

below the PEL; and

(iv) During periods when the employee is in a

regulated area.

(2) Respiratory protection program. Where

respirator use is required by this section, the

employer shall institute a respiratory protection

program in accordance with 29 CFR 1910.134.

(h) Housekeeping. (1) The employer shall

not allow dry sweeping or dry brushing

where such activity could contribute to

employee exposure to respirable crystalline

silica unless wet sweeping, HEPA-ﬁltered

vacuuming or other methods that minimize

the likelihood of exposure are not feasible.

(2) The employer shall not allow compressed

air to be used to clean clothing or surfaces

where such activity could contribute to

employee exposure to respirable crystalline

silica unless:

(i) The compressed air is used in conjunction

with a ventilation system that effectively

captures the dust cloud created by the

compressed air; or

(ii) No alternative method is feasible.

(i) Medical surveillance—(1) General. (i) The

employer shall make medical surveillance

available at no cost to the employee, and

at a reasonable time and place, for each

employee who will be occupationally exposed

to respirable crystalline silica at or above the

action level for 30 or more days per year.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

(ii) The employer shall ensure that all medical

examinations and procedures required by

this section are performed by a PLHCP as

deﬁned in paragraph (b) of this section.

(2) Initial examination. The employer shall

make available an initial (baseline) medical

examination within 30 days after initial

assignment, unless the employee has

received a medical examination that meets

the requirements of this section within the last

three years. The examination shall consist of:

(i) A medical and work history, with emphasis

on: past, present, and anticipated exposure

to respirable crystalline silica, dust, and other

agents affecting the respiratory system; any

history of respiratory system dysfunction,

including signs and symptoms of respiratory

disease (e.g., shortness of breath, cough,

wheezing); history of tuberculosis; and

smoking status and history;

(ii) A physical examination with special

emphasis on the respiratory system;

(iii) A chest X-ray (a single posteroanterior

radiographic projection or radiograph of the

chest at full inspiration recorded on either

ﬁlm (no less than 14 x 17 inches and no more

than 16 x 17 inches) or digital radiography

systems), interpreted and classiﬁed

according to the International Labour

Ofﬁce (ILO) International Classiﬁcation

of Radiographs of Pneumoconioses by a

NIOSH-certiﬁed B Reader;

(iv) A pulmonary function test to include

forced vital capacity (FVC) and forced

expiratory volume in one second (FEV1) and

FEV1/FVC ratio, administered by a spirometry

technician with a current certiﬁcate from a

NIOSH-approved spirometry course;

(v) Testing for latent tuberculosis infection; and

(vi) Any other tests deemed appropriate by

the PLHCP.

(3) Periodic examinations. The employer shall

make available medical examinations that

include the procedures described in paragraph

(i)(2) of this section (except paragraph (i)(2)(v))

at least every three years, or more frequently

if recommended by the PLHCP.

(4) Information provided to the PLHCP. The

employer shall ensure that the examining

PLHCP has a copy of this standard, and

shall provide the PLHCP with the following

information:

(i) A description of the employee’s former,

current, and anticipated duties as they relate

to the employee’s occupational exposure to

respirable crystalline silica;

(ii) The employee’s former, current, and

anticipated levels of occupational exposure to

respirable crystalline silica;

(iii) A description of any personal protective

equipment used or to be used by the

employee, including when and for how

long the employee has used or will use that

equipment; and

(iv) Information from records of employment-

related medical examinations previously

provided to the employee and currently

within the control of the employer.

(5) PLHCP’s written medical report for the

employee. The employer shall ensure that the

PLHCP explains to the employee the results

of the medical examination and provides

each employee with a written medical report

within 30 days of each medical examination

performed. The written report shall contain:

(i) A statement indicating the results of the

medical examination, including any medical

condition(s) that would place the employee

at increased risk of material impairment to

health from exposure to respirable crystalline

silica and any medical conditions that require

further evaluation or treatment;

(ii) Any recommended limitations on the

employee’s use of respirators;

Occupational Safety and Health Administration

(iii) Any recommended limitations on the

employee’s exposure to respirable crystalline

silica; and

(iv) A statement that the employee should

be examined by a specialist (pursuant to

paragraph (i)(7) of this section) if the chest

X-ray provided in accordance with this

section is classiﬁed as 1/0 or higher by

the B Reader, or if referral to a specialist is

otherwise deemed appropriate by the PLHCP.

(6) PLHCP’s written medical opinion for the

employer. (i) The employer shall obtain a

written medical opinion from the PLHCP within

30 days of the medical examination. The

written opinion shall contain only the following:

(A) The date of the examination;

(B) A statement that the examination has met

the requirements of this section; and

employee’s use of respirators.

(ii) If the employee provides written

authorization, the written opinion shall also

contain either or both of the following:

(A) Any recommended limitations on

the employee’s exposure to respirable

crystalline silica;

(B) A statement that the employee should

be examined by a specialist (pursuant to

paragraph (i)(7) of this section) if the chest

X-ray provided in accordance with this

section is classiﬁed as 1/0 or higher by

the B Reader, or if referral to a specialist is

otherwise deemed appropriate by the PLHCP.

(iii) The employer shall ensure that each

employee receives a copy of the written

medical opinion described in paragraph (i)

(6)(i) and (ii) of this section within 30 days of

each medical examination performed.

(7) Additional examinations. (i) If the PLHCP’s

written medical opinion indicates that an

employee should be examined by a specialist,

the employer shall make available a medical

examination by a specialist within 30 days

after receiving the PLHCP’s written opinion.

(ii) The employer shall ensure that the

examining specialist is provided with all of

the information that the employer is obligated

to provide to the PLHCP in accordance with

paragraph (i)(4) of this section.

(iii) The employer shall ensure that the

specialist explains to the employee the

results of the medical examination and

provides each employee with a written

medical report within 30 days of the

examination. The written report shall meet

the requirements of paragraph (i)(5) (except

paragraph (i)(5)(iv)) of this section.

(iv) The employer shall obtain a written

opinion from the specialist within 30 days of

the medical examination. The written opinion

shall meet the requirements of paragraph (i)

(6) (except paragraph (i)(6)(i)(B) and (i)(6)(ii)(B))

of this section.

(j) Communication of respirable crystalline

silica hazards to employees—(1) Hazard

communication. The employer shall include

respirable crystalline silica in the program

established to comply with the hazard

communication standard (HCS) (29 CFR

1910.1200). The employer shall ensure that

each employee has access to labels on

containers of crystalline silica and safety data

sheets, and is trained in accordance with the

provisions of HCS and paragraph (j)(3) of this

section. The employer shall ensure that at

least the following hazards are addressed:

Cancer, lung effects, immune system effects,

and kidney effects.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

(2) Signs. The employer shall post signs at

all entrances to regulated areas that bear the

following legend:

DANGER

RESPIRABLE CRYSTALLINE SILICA

MAY CAUSE CANCER

CAUSES DAMAGE TO LUNGS

WEAR RESPIRATORY PROTECTION IN THIS AREA

AUTHORIZED PERSONNEL ONLY

(3) Employee information and training. (i) The

employer shall ensure that each employee

covered by this section can demonstrate

knowledge and understanding of at least the

following:

(A) The health hazards associated with

exposure to respirable crystalline silica;

(B) Speciﬁc tasks in the workplace that could

result in exposure to respirable crystalline

silica;

implemented to protect employees from

exposure to respirable crystalline silica,

including engineering controls, work

practices, and respirators to be used;

(D) The contents of this section; and

(E) The purpose and a description of the

medical surveillance program required by

paragraph (i) of this section.

(ii) The employer shall make a copy of this

section readily available without cost to each

employee covered by this section.

(k) Recordkeeping—(1) Air monitoring

data. (i) The employer shall make and

maintain an accurate record of all exposure

measurements taken to assess employee

exposure to respirable crystalline silica, as

prescribed in paragraph (d) of this section.

(ii) This record shall include at least the

following information:

(A) The date of measurement for each sample

taken;

(B) The task monitored;

(D) Number, duration, and results of samples

taken;

(E) Identity of the laboratory that performed

the analysis;

(F) Type of personal protective equipment,

such as respirators, worn by the employees

monitored; and

(G) Name, social security number, and job

classiﬁcation of all employees represented by

the monitoring, indicating which employees

were actually monitored.

(iii) The employer shall ensure that exposure

records are maintained and made available in

accordance with 29 CFR 1910.1020.

(2) Objective data. (i) The employer shall

make and maintain an accurate record of all

objective data relied upon to comply with the

requirements of this section.

(ii) This record shall include at least the

following information:

(A) The crystalline silica-containing material

in question;

(B) The source of the objective data;

(D) A description of the process, task, or

activity on which the objective data were

based; and

(E) Other data relevant to the process, task,

activity, material, or exposures on which the

objective data were based.

(iii) The employer shall ensure that objective

data are maintained and made available in

accordance with 29 CFR 1910.1020.

Occupational Safety and Health Administration

(3) Medical surveillance. (i) The employer shall

make and maintain an accurate record for each

employee covered by medical surveillance

under paragraph (i) of this section.

(ii) The record shall include the following

information about the employee:

(A) Name and social security number;

(B) A copy of the PLHCPs’ and specialists’

written medical opinions; and

PLHCPs and specialists.

(iii) The employer shall ensure that medical

records are maintained and made available in

accordance with 29 CFR 1910.1020.

(l) Dates. (1) This section is effective June 23,

2016.

(2) Except as provided for in paragraphs (l)(3)

and (4) of this section, all obligations of this

section commence June 23, 2018.

(3) For hydraulic fracturing operations in the

oil and gas industry:

(i) All obligations of this section, except

obligations for medical surveillance in

paragraph (i)(1)(i) and engineering controls

in paragraph (f)(1) of this section, commence

June 23, 2018;

(ii) Obligations for engineering controls in

paragraph (f)(1) of this section commence

June 23, 2021; and

(iii) Obligations for medical surveillance in

paragraph (i)(1)(i) commence in accordance

with paragraph (l)(4) of this section.

(4) The medical surveillance obligations

in paragraph (i)(1)(i) commence on June

23, 2018, for employees who will be

occupationally exposed to respirable

crystalline silica above the PEL for 30 or more

days per year. Those obligations commence

June 23, 2020, for employees who will

be occupationally exposed to respirable

crystalline silica at or above the action level

for 30 or more days per year.

Appendix A to § 1910.1053 –

Methods of Sample Analysis.

This appendix speciﬁes the procedures for

analyzing air samples for respirable crystalline

silica, as well as the quality control procedures

that employers must ensure that laboratories

use when performing an analysis required

under 29 CFR 1926.1153 (d)(2)(v). Employers

must ensure that such a laboratory:

1. Evaluates all samples using the procedures

speciﬁed in one of the following analytical

methods: OSHA ID-142; NMAM 7500; NMAM

7602; NMAM 7603; MSHA P-2; or MSHA P-7;

2. Is accredited to ANS/ISO/IEC Standard

17025:2005 with respect to crystalline silica

analyses by a body that is compliant with ISO/

IEC Standard 17011:2004 for implementation

of quality assessment programs;

3. Uses the most current National Institute

of Standards and Technology (NIST) or NIST

traceable standards for instrument calibration

or instrument calibration veriﬁcation;

4. Implements an internal quality control (QC)

program that evaluates analytical uncertainty

and provides employers with estimates of

sampling and analytical error;

5. Characterizes the sample material by

identifying polymorphs of respirable

crystalline silica present, identiﬁes the

presence of any interfering compounds that

might affect the analysis, and makes any

corrections necessary in order to obtain

accurate sample analysis; and

6. Analyzes quantitatively for crystalline

silica only after conﬁrming that the sample

matrix is free of uncorrectable analytical

interferences, corrects for analytical

interferences, and uses a method that meets

the following performance speciﬁcations:

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

6.1 Each day that samples are analyzed,

performs instrument calibration checks

with standards that bracket the sample

concentrations;

6.2 Uses ﬁve or more calibration standard

levels to prepare calibration curves and

ensures that standards are distributed

through the calibration range in a manner

that accurately reﬂects the underlying

calibration curve; and

6.3 Optimizes methods and instruments to

obtain a quantitative limit of detection that

represents a value no higher than 25 percent

of the PEL based on sample air volume.

Appendix B to § 1910.1053 –

Medical Surveillance Guidelines.

Introduction

The purpose of this Appendix is to provide

medical information and recommendations

to aid physicians and other licensed health

care professionals (PLHCPs) regarding

compliance with the medical surveillance

provisions of the respirable crystalline silica

standard (29 CFR 1926.1153). Appendix B is

for informational and guidance purposes

only and none of the statements in Appendix

B should be construed as imposing a

mandatory requirement on employers that is

not otherwise imposed by the standard.

Medical screening and surveillance allow for

early identiﬁcation of exposure-related health

effects in individual employee and groups

of employees, so that actions can be taken

to both avoid further exposure and prevent

or address adverse health outcomes. Silica-

related diseases can be fatal, encompass a

variety of target organs, and may have public

health consequences when considering the

increased risk of a latent tuberculosis (TB)

infection becoming active. Thus, medical

surveillance of silica-exposed employees

requires that PLHCPs have a thorough

knowledge of silica-related health effects.

This Appendix is divided into seven

sections. Section 1 reviews silica-related

diseases, medical responses, and public

health responses. Section 2 outlines the

components of the medical surveillance

program for employees exposed to

silica. Section 3 describes the roles and

responsibilities of the PLHCP implementing

the program and of other medical specialists

and public health professionals. Section 4

provides a discussion of considerations,

including conﬁdentiality. Section 5 provides

a list of additional resources and Section 6

lists references. Section 7 provides sample

forms for the written medical report for the

employee, the written medical opinion for the

employer and the written authorization.

1. Recognition of Silica-related Diseases.

1.1. Overview. The term “silica” refers

speciﬁcally to the compound silicon dioxide

(SiO2). Silica is a major component of

sand, rock, and mineral ores. Exposure to

ﬁne (respirable size) particles of crystalline

forms of silica is associated with adverse

health effects, such as silicosis, lung

cancer, chronic obstructive pulmonary

disease (COPD), and activation of latent TB

infections. Exposure to respirable crystalline

silica can occur in industry settings such

as foundries, abrasive blasting operations,

paint manufacturing, glass and concrete

product manufacturing, brick making, china

and pottery manufacturing, manufacturing

of plumbing ﬁxtures, and many construction

activities including highway repair, masonry,

concrete work, rock drilling, and tuck-pointing.

New uses of silica continue to emerge. These

include countertop manufacturing, ﬁnishing,

and installation (Kramer et al. 2012; OSHA

2015) and hydraulic fracturing in the oil and

gas industry (OSHA 2012).

Silicosis is an irreversible, often disabling,

and sometimes fatal ﬁbrotic lung disease.

Progression of silicosis can occur despite

removal from further exposure. Diagnosis of

silicosis requires a history of exposure to silica

Occupational Safety and Health Administration

and radiologic ﬁndings characteristic of silica

exposure. Three different presentations of

silicosis (chronic, accelerated, and acute) have

been deﬁned. Accelerated and acute silicosis

are much less common than chronic silicosis.

However, it is critical to recognize all cases of

accelerated and acute silicosis because these

are life-threatening illnesses and because

they are caused by substantial overexposures

to respirable crystalline silica. Although any

case of silicosis indicates a breakdown in

prevention, a case of acute or accelerated

silicosis implies current high exposure and a

very marked breakdown in prevention.

In addition to silicosis, employees exposed to

respirable crystalline silica, especially those

with accelerated or acute silicosis, are at

increased risks of contracting active TB and

other infections (ATS 1997; Rees and Murray

2007). Exposure to respirable crystalline

silica also increases an employee’s risk of

developing lung cancer, and the higher the

cumulative exposure, the higher the risk

(Steenland et al. 2001; Steenland and Ward

2014). Symptoms for these diseases and

other respirable crystalline silica-related

diseases are discussed below.

1.2. Chronic Silicosis. Chronic silicosis is

the most common presentation of silicosis

and usually occurs after at least 10 years of

exposure to respirable crystalline silica. The

clinical presentation of chronic silicosis is:

1.2.1. Symptoms - shortness of breath

and cough, although employees may not

notice any symptoms early in the disease.

Constitutional symptoms, such as fever, loss

of appetite and fatigue, may indicate other

diseases associated with silica exposure,

such as TB infection or lung cancer.

Employees with these symptoms should

immediately receive further evaluation and

treatment.

1.2.2. Physical Examination - may be normal

or disclose dry rales or rhonchi on lung

auscultation.

1.2.3. Spirometry - may be normal or may

show only a mild restrictive or obstructive

pattern.

1.2.4. Chest X-ray - classic ﬁndings are small,

rounded opacities in the upper lung ﬁelds

bilaterally. However, small irregular opacities

and opacities in other lung areas can also

occur. Rarely, “eggshell calciﬁcations” in the

hilar and mediastinal lymph nodes are seen.

1.2.5. Clinical Course - chronic silicosis in most

cases is a slowly progressive disease. Under

the respirable crystalline silica standard, the

PLHCP is to recommend that employees

with a 1/0 category X-ray be referred to

an American Board Certiﬁed Specialist in

Pulmonary Disease or Occupational Medicine.

The PLHCP and/or Specialist should counsel

employees regarding work practices and

personal habits that could affect employees’

respiratory health.

1.3. Accelerated Silicosis. Accelerated silicosis

generally occurs within 5-10 years of exposure

and results from high levels of exposure

to respirable crystalline silica. The clinical

presentation of accelerated silicosis is:

1.3.1. Symptoms - shortness of breath, cough,

and sometimes sputum production. Employees

with exposure to respirable crystalline silica,

and especially those with accelerated silicosis,

are at high risk for activation of TB infections,

atypical mycobacterial infections, and fungal

superinfections. Constitutional symptoms, such

as fever, weight loss, hemoptysis (coughing

up blood), and fatigue may herald one of these

infections or the onset of lung cancer.

1.3.2. Physical Examination - rales, rhonchi,

or other abnormal lung ﬁndings in relation to

illnesses present. Clubbing of the digits, signs

of heart failure, and cor pulmonale may be

present in severe lung disease.

1.3.3. Spirometry - restrictive or mixed

restrictive/obstructive pattern.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

1.3.4. Chest X-ray - small rounded and/

or irregular opacities bilaterally. Large

opacities and lung abscesses may indicate

infections, lung cancer, or progression

to complicated silicosis, also termed

progressive massive ﬁbrosis.

1.3.5. Clinical Course - accelerated silicosis

has a rapid, severe course. Under the

respirable crystalline silica standard, the

PLHCP can recommend referral to a Board

Certiﬁed Specialist in either Pulmonary

Disease or Occupational Medicine, as

deemed appropriate, and referral to a

Specialist is recommended whenever the

diagnosis of accelerated silicosis is being

considered.

1.4. Acute Silicosis. Acute silicosis is a rare

disease caused by inhalation of extremely

high levels of respirable crystalline silica

particles. The pathology is similar to alveolar

proteinosis with lipoproteinaceous material

accumulating in the alveoli. Acute silicosis

develops rapidly, often, within a few months

to less than 2 years of exposure, and is

almost always fatal. The clinical presentation

of acute silicosis is as follows:

1.4.1. Symptoms - sudden, progressive, and

severe shortness of breath. Constitutional

symptoms are frequently present and

include fever, weight loss, fatigue, productive

cough, hemoptysis (coughing up blood), and

pleuritic chest pain.

1.4.2. Physical Examination - dyspnea at rest,

cyanosis, decreased breath sounds, inspiratory

rales, clubbing of the digits, and fever.

1.4.3. Spirometry - restrictive or mixed

restrictive/obstructive pattern.

1.4.4. Chest X-ray - diffuse haziness of the

lungs bilaterally early in the disease. As

the disease progresses, the “ground glass”

appearance of interstitial ﬁbrosis will appear.

1.4.5. Clinical Course - employees with acute

silicosis are at especially high risk of TB

activation, nontuberculous mycobacterial

infections, and fungal superinfections. Acute

silicosis is immediately life-threatening. The

employee should be urgently referred to

a Board Certiﬁed Specialist in Pulmonary

Disease or Occupational Medicine for

evaluation and treatment. Although any

case of silicosis indicates a breakdown in

prevention, a case of acute or accelerated

silicosis implies a profoundly high level

of silica exposure and may mean that

other employees are currently exposed to

dangerous levels of silica.

1.5. COPD. COPD, including chronic bronchitis

and emphysema, has been documented in

silica-exposed employees, including those who

do not develop silicosis. Periodic spirometry

tests are performed to evaluate each employee

for progressive changes consistent with

the development of COPD. In addition to

evaluating spirometry results of individual

employees over time, PLHCPs may want to

be aware of general trends in spirometry

results for groups of employees from the same

workplace to identify possible problems that

might exist at that workplace. (See Section

2 of this Appendix on Medical Surveillance

for further discussion.) Heart disease may

develop secondary to lung diseases such as

COPD. A recent study by Liu et al. 2014 noted a

signiﬁcant exposure-response trend between

cumulative silica exposure and heart disease

deaths, primarily due to pulmonary heart

disease, such as cor pulmonale.

1.6. Renal and Immune System. Silica

exposure has been associated with

several types of kidney disease, including

glomerulonephritis, nephrotic syndrome, and

end stage renal disease requiring dialysis.

Silica exposure has also been associated

with other autoimmune conditions, including

progressive systemic sclerosis, systemic

Occupational Safety and Health Administration

lupus erythematosus, and rheumatoid

arthritis. Studies note an association between

employees with silicosis and serologic

markers for autoimmune diseases, including

antinuclear antibodies, rheumatoid factor,

and immune complexes (Jalloul and Banks

2007; Shtraichman et al. 2015).

1.7. TB and Other Infections. Silica-exposed

employees with latent TB are 3 to 30 times

more likely to develop active pulmonary

TB infection (ATS 1997; Rees and Murray

2007). Although respirable crystalline silica

exposure does not cause TB infection,

individuals with latent TB infection are

at increased risk for activation of disease

if they have higher levels of respirable

crystalline silica exposure, greater profusion

of radiographic abnormalities, or a diagnosis

of silicosis. Demographic characteristics,

such as immigration from some countries,

are associated with increased rates of latent

TB infection. PLHCPs can review the latest

Centers for Disease Control and Prevention

(CDC) information on TB incidence rates and

high risk populations online (See Section

5 of this Appendix). Additionally, silica-

exposed employees are at increased risk for

contracting nontuberculous mycobacterial

infections, including Mycobacterium avium-

intracellulare and Mycobacterium kansaii.

1.8. Lung Cancer. The National Toxicology

Program has listed respirable crystalline

silica as a known human carcinogen since

2000 (NTP 2014). The International Agency

for Research on Cancer (2012) has also

classiﬁed silica as Group 1 (carcinogenic

to humans). Several studies have indicated

that the risk of lung cancer from exposure to

respirable crystalline silica and smoking is

greater than additive (Brown 2009; Liu et al.

2013). Employees should be counseled on

smoking cessation.

2. Medical Surveillance.

PLHCPs who manage silica medical

surveillance programs should have a thorough

understanding of the many silica-related

diseases and health effects outlined in Section

1 of this Appendix. At each clinical encounter,

the PLHCP should consider silica-related

health outcomes, with particular vigilance

for acute and accelerated silicosis. In this

Section, the required components of medical

surveillance under the respirable crystalline

silica standard are reviewed, along with

additional guidance and recommendations

for PLHCPs performing medical surveillance

examinations for silica-exposed employees.

2.1. History.

2.1.1. The respirable crystalline silica standard

requires the following: A medical and work

history, with emphasis on: past, present, and

anticipated exposure to respirable crystalline

silica, dust, and other agents affecting the

respiratory system; any history of respiratory

system dysfunction, including signs and

symptoms of respiratory disease (e.g.,

shortness of breath, cough, wheezing); history

of TB; and smoking status and history.

2.1.2. Further, the employer must provide the

PLHCP with the following information:

2.1.2.1. A description of the employee’s

former, current, and anticipated duties as

they relate to the employee’s occupational

exposure to respirable crystalline silica;

2.1.2.2. The employee’s former, current, and

anticipated levels of occupational exposure to

respirable crystalline silica;

2.1.2.3. A description of any personal protective

equipment used or to be used by the employee,

including when and for how long the employee

has used or will use that equipment; and

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

2.1.2.4. Information from records of

employment-related medical examinations

previously provided to the employee and

currently within the control of the employer.

2.1.3. Additional guidance and

recommendations: A history is particularly

important both in the initial evaluation and in

periodic examinations. Information on past

and current medical conditions (particularly

a history of kidney disease, cardiac disease,

connective tissue disease, and other immune

diseases), medications, hospitalizations and

surgeries may uncover health risks, such

as immune suppression, that could put

an employee at increased health risk from

exposure to silica. This information is important

when counseling the employee on risks and

safe work practices related to silica exposure.

2.2. Physical Examination.

2.2.1. The respirable crystalline silica

standard requires the following: A physical

examination, with special emphasis on the

respiratory system. The physical examination

must be performed at the initial examination

and every three years thereafter.

2.2.2. Additional guidance and

recommendations: Elements of the physical

examination that can assist the PHLCP include:

an examination of the cardiac system, an

extremity examination (for clubbing, cyanosis,

edema, or joint abnormalities), and an

examination of other pertinent organ systems

identiﬁed during the history.

2.3. TB Testing.

2.3.1. The respirable crystalline silica standard

requires the following: Baseline testing for TB

on initial examination.

2.3.2. Additional guidance and

recommendations:

2.3.2.1. Current CDC guidelines (See Section

5 of this Appendix) should be followed for the

application and interpretation of Tuberculin

skin tests (TST). The interpretation and

documentation of TST reactions should

be performed within 48 to 72 hours of

administration by trained PLHCPs.

2.3.2.2. PLHCPs may use alternative TB tests,

such as interferon-release assays (IGRAs), if

sensitivity and speciﬁcity are comparable to

TST (Mazurek et al. 2010; Slater et al. 2013).

PLHCPs can consult the current CDC guidelines

for acceptable tests for latent TB infection.

2.3.2.3. The silica standard allows the PLHCP

to order additional tests or test at a greater

frequency than required by the standard,

if deemed appropriate. Therefore, PLHCPs

might perform periodic (e.g., annual) TB

testing as appropriate, based on employees’

risk factors. For example, according to

the American Thoracic Society (ATS), the

diagnosis of silicosis or exposure to silica for

25 years or more are indications for annual

TB testing (ATS 1997). PLHCPs should consult

the current CDC guidance on risk factors for

TB (See Section 5 of this Appendix).

2.3.2.4. Employees with positive TB tests

and those with indeterminate test results

should be referred to the appropriate agency

or specialist, depending on the test results

and clinical picture. Agencies, such as local

public health departments, or specialists,

such as a pulmonary or infectious disease

specialist, may be the appropriate referral.

Active TB is a nationally notiﬁable disease.

PLHCPs should be aware of the reporting

requirements for their region. All States have

TB Control Ofﬁces that can be contacted for

further information. (See Section 5 of this

Appendix for links to CDC’s TB resources and

State TB Control Ofﬁces.)

2.3.2.5. The following public health principles

are key to TB control in the U.S. (ATS-CDC-

IDSA 2005):

(1) Prompt detection and reporting of persons

who have contracted active TB;

Occupational Safety and Health Administration

(2) Prevention of TB spread to close contacts

of active TB cases;

(3) Prevention of active TB in people with

latent TB through targeted testing and

treatment; and

(4) Identiﬁcation of settings at high risk for TB

transmission so that appropriate infection-

control measures can be implemented.

2.4. Pulmonary Function Testing.

2.4.1. The respirable crystalline silica

standard requires the following: Pulmonary

function testing must be performed on the

initial examination and every three years

thereafter. The required pulmonary function

test is spirometry and must include forced

vital capacity (FVC), forced expiratory

volume in one second (FEV1), and FEV1/

FVC ratio. Testing must be administered

by a spirometry technician with a current

certiﬁcate from a National Institute for

Occupational Health and Safety (NIOSH)-

approved spirometry course.

2.4.2. Additional guidance and

recommendations: Spirometry provides

information about individual respiratory

status and can be used to track an

employee’s respiratory status over time or

as a surveillance tool to follow individual

and group respiratory function. For quality

results, the ATS and the American College of

Occupational and Environmental Medicine

(ACOEM) recommend use of the third National

Health and Nutrition Examination Survey

(NHANES III) values, and ATS publishes

recommendations for spirometry equipment

(Miller et al. 2005; Townsend 2011; Redlich

et al. 2014). OSHA’s publication, Spirometry

Testing in Occupational Health Programs:

Best Practices for Healthcare Professionals,

provides helpful guidance (See Section 5 of

this Appendix). Abnormal spirometry results

may warrant further clinical evaluation and

possible recommendations for limitations

on the employee’s exposure to respirable

crystalline silica.

2.5. Chest X-ray.

2.5.1. The respirable crystalline silica

standard requires the following: A single

posteroanterior (PA) radiographic projection

or radiograph of the chest at full inspiration

recorded on either ﬁlm (no less than 14 x 17

inches and no more than 16 x 17 inches) or

digital radiography systems. A chest X-ray

must be performed on the initial examination

and every three years thereafter. The chest

X-ray must be interpreted and classiﬁed

according to the International Labour

Ofﬁce (ILO) International Classiﬁcation

of Radiographs of Pneumoconioses by a

NIOSH-certiﬁed B Reader.

Chest radiography is necessary to diagnose

silicosis, monitor the progression of silicosis,

and identify associated conditions such as

TB. If the B reading indicates small opacities

in a profusion of 1/0 or higher, the employee

is to receive a recommendation for referral

to a Board Certiﬁed Specialist in Pulmonary

Disease or Occupational Medicine.

2.5.2. Additional guidance and

recommendations: Medical imaging has

largely transitioned from conventional ﬁlm-

based radiography to digital radiography

systems. The ILO Guidelines for the

Classiﬁcation of Pneumoconioses has

historically provided ﬁlm-based chest

radiography as a referent standard for

comparison to individual exams. However,

in 2011, the ILO revised the guidelines to

include a digital set of referent standards

that were derived from the prior ﬁlm-

based standards. To assist in assuring that

digitally-acquired radiographs are at least

as safe and effective as ﬁlm radiographs,

NIOSH has prepared guidelines, based

upon accepted contemporary professional

recommendations (See Section 5 of this

Appendix). Current research from Laney et al.

2011 and Halldin et al. 2014 validate the use of

the ILO digital referent images. Both studies

conclude that the results of pneumoconiosis

classiﬁcation using digital references are

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

comparable to ﬁlm-based ILO classiﬁcations.

Current ILO guidance on radiography for

pneumoconioses and B-reading should

be reviewed by the PLHCP periodically, as

needed, on the ILO or NIOSH websites (See

Section 5 of this Appendix).

2.6. Other Testing. Under the respirable

crystalline silica standards, the PLHCP has

the option of ordering additional testing he

or she deems appropriate. Additional tests

can be ordered on a case-by-case basis

depending on individual signs or symptoms

and clinical judgment. For example, if an

employee reports a history of abnormal

kidney function tests, the PLHCP may want

to order a baseline renal function tests (e.g.,

serum creatinine and urinalysis). As indicated

above, the PLHCP may order annual TB

testing for silica-exposed employees who are

at high risk of developing active TB infections.

Additional tests that PLHCPs may order based

on ﬁndings of medical examinations include,

but is not limited to, chest computerized

tomography (CT) scan for lung cancer or

COPD, testing for immunologic diseases, and

cardiac testing for pulmonary-related heart

disease, such as cor pulmonale.

3. Roles and Responsibilities.

3.1. PLHCP. The PLHCP designation refers

to “an individual whose legally permitted

scope of practice (i.e., license, registration,

or certiﬁcation) allows him or her to

independently provide or be delegated the

responsibility to provide some or all of the

particular health care services required” by

the respirable crystalline silica standard. The

legally permitted scope of practice for the

PLHCP is determined by each State. PLHCPs

who perform clinical services for a silica

medical surveillance program should have a

thorough knowledge of respirable crystalline

silica-related diseases and symptoms.

Suspected cases of silicosis, advanced COPD,

or other respiratory conditions causing

impairment should be promptly referred to

a Board Certiﬁed Specialist in Pulmonary

Disease or Occupational Medicine.

Once the medical surveillance examination

is completed, the employer must ensure

that the PLHCP explains to the employee

the results of the medical examination and

provides the employee with a written medical

report within 30 days of the examination.

The written medical report must contain

a statement indicating the results of the

medical examination, including any medical

condition(s) that would place the employee

at increased risk of material impairment to

health from exposure to respirable crystalline

silica and any medical conditions that

require further evaluation or treatment. In

addition, the PLHCP’s written medical report

must include any recommended limitations

on the employee’s use of respirators, any

recommended limitations on the employee’s

exposure to respirable crystalline silica, and

a statement that the employee should be

examined by a Board Certiﬁed Specialist in

Pulmonary Disease or Occupational medicine

if the chest X-ray is classiﬁed as 1/0 or higher

by the B Reader, or if referral to a Specialist is

otherwise deemed appropriate by the PLHCP.

The PLHCP should discuss all ﬁndings and test

results and any recommendations regarding

the employee’s health, worksite safety and

health practices, and medical referrals for

further evaluation, if indicated. In addition, it

is suggested that the PLHCP offer to provide

the employee with a complete copy of

their examination and test results, as some

employees may want this information for their

own records or to provide to their personal

physician or a future PLHCP. Employees are

entitled to access their medical records.

Under the respirable crystalline silica

standard, the employer must ensure that

the PLHCP provides the employer with a

written medical opinion within 30 days of

the employee examination, and that the

employee also gets a copy of the written

medical opinion for the employer within

30 days. The PLHCP may choose to directly

provide the employee a copy of the written

medical opinion. This can be particularly

Occupational Safety and Health Administration

helpful to employees, such as construction

employees, who may change employers

frequently. The written medical opinion can

be used by the employee as proof of up-

to-date medical surveillance. The following

lists the elements of the written medical

report for the employee and written medical

opinion for the employer. (Sample forms for

the written medical report for the employee,

the written medical opinion for the employer,

and the written authorization are provided in

Section 7 of this Appendix.)

3.1.1. The written medical report for the

employee must include the following

information:

3.1.1.1. A statement indicating the results of the

medical examination, including any medical

condition(s) that would place the employee

at increased risk of material impairment to

health from exposure to respirable crystalline

silica and any medical conditions that require

further evaluation or treatment;

3.1.1.2. Any recommended limitations upon

the employee’s use of a respirator;

3.1.1.3. Any recommended limitations on the

employee’s exposure to respirable crystalline

silica; and

3.1.1.4. A statement that the employee should

be examined by a Board Certiﬁed Specialist

in Pulmonary Disease or Occupational

Medicine, where the standard requires or

where the PLHCP has determined such a

referral is necessary. The standard requires

referral to a Board Certiﬁed Specialist in

Pulmonary Disease or Occupational Medicine

for a chest X-ray B reading indicating small

opacities in a profusion of 1/0 or higher, or

if the PHLCP determines that referral to a

Specialist is necessary for other silica-related

ﬁndings.

3.1.2. The PLHCP’s written medical opinion

for the employer must include only the

following information:

3.1.2.1. The date of the examination;

3.1.2.2. A statement that the examination has

met the requirements of this section; and

3.1.2.3. Any recommended limitations on the

employee’s use of respirators.

3.1.2.4. If the employee provides the PLHCP

with written authorization, the written

opinion for the employer shall also contain

either or both of the following:

(1) Any recommended limitations on the

employee’s exposure to respirable crystalline

silica; and

(2) A statement that the employee should be

examined by a Board Certiﬁed Specialist in

Pulmonary Disease or Occupational Medicine

if the chest X-ray provided in accordance

with this section is classiﬁed as 1/0 or higher

by the B Reader, or if referral to a Specialist is

otherwise deemed appropriate.

3.1.2.5. In addition to the above referral for

abnormal chest X-ray, the PLHCP may refer

an employee to a Board Certiﬁed Specialist in

Pulmonary Disease or Occupational Medicine

for other ﬁndings of concern during the medical

surveillance examination if these ﬁndings are

potentially related to silica exposure.

3.1.2.6. Although the respirable crystalline

silica standard requires the employer to

ensure that the PLHCP explains the results of

the medical examination to the employee, the

standard does not mandate how this should

be done. The written medical opinion for

the employer could contain a statement that

the PLHCP has explained the results of the

medical examination to the employee.

3.2. Medical Specialists. The silica standard

requires that all employees with chest X-ray B

readings of 1/0 or higher be referred to a Board

Certiﬁed Specialist in Pulmonary Disease or

Occupational Medicine. If the employee has

given written authorization for the employer

to be informed, then the employer shall

make available a medical examination by a

Specialist within 30 days after receiving the

PLHCP’s written medical opinion.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

3.2.1. The employer must provide the

following information to the Board Certiﬁed

Specialist in Pulmonary Disease or

Occupational Medicine:

3.2.1.1. A description of the employee’s

former, current, and anticipated duties as

they relate to the employee’s occupational

exposure to respirable crystalline silica;

3.2.1.2. The employee’s former, current, and

anticipated levels of occupational exposure to

respirable crystalline silica;

3.2.1.3. A description of any personal

protective equipment used or to be used by

the employee, including when and for how

long the employee has used or will use that

equipment; and

3.2.1.4. Information from records of

employment-related medical examinations

previously provided to the employee and

currently within the control of the employer.

3.2.2. The PLHCP should make certain that,

with written authorization from the employee,

the Board Certiﬁed Specialist in Pulmonary

Disease or Occupational Medicine has any

other pertinent medical and occupational

information necessary for the specialist’s

evaluation of the employee’s condition.

3.2.3. Once the Board Certiﬁed Specialist in

Pulmonary Disease or Occupational Medicine

has evaluated the employee, the employer

must ensure that the Specialist explains

to the employee the results of the medical

examination and provides the employee with

a written medical report within 30 days of the

examination. The employer must also ensure

that the Specialist provides the employer with

a written medical opinion within 30 days of

the employee examination. (Sample forms for

the written medical report for the employee,

the written medical opinion for the employer

and the written authorization are provided in

Section 7 of this Appendix.)

3.2.4. The Specialist’s written medical report

for the employee must include the following

information:

3.2.4.1. A statement indicating the results

of the medical examination, including any

medical condition(s) that would place the

employee at increased risk of material

impairment to health from exposure to

respirable crystalline silica and any medical

conditions that require further evaluation or

treatment;

3.2.4.2. Any recommended limitations upon

the employee’s use of a respirator; and

3.2.4.3. Any recommended limitations on the

employee’s exposure to respirable crystalline

silica.

3.2.5. The Specialist’s written medical

opinion for the employer must include the

following information:

3.2.5.1. The date of the examination; and

3.2.5.2. Any recommended limitations on the

employee’s use of respirators.

3.2.5.3. If the employee provides the Board

Certiﬁed Specialist in Pulmonary Disease

or Occupational Medicine with written

authorization, the written medical opinion

for the employer shall also contain any

recommended limitations on the employee’s

exposure to respirable crystalline silica.

3.2.5.4. Although the respirable crystalline

silica standard requires the employer to

ensure that the Board Certiﬁed Specialist

in Pulmonary Disease or Occupational

Medicine explains the results of the medical

examination to the employee, the standard

does not mandate how this should be done.

The written medical opinion for the employer

could contain a statement that the Specialist

has explained the results of the medical

examination to the employee.

Occupational Safety and Health Administration

3.2.6. After evaluating the employee, the

Board Certiﬁed Specialist in Pulmonary

Disease or Occupational Medicine

should provide feedback to the PLHCP as

appropriate, depending on the reason for

the referral. OSHA believes that because the

PLHCP has the primary relationship with the

employer and employee, the Specialist may

want to communicate his or her ﬁndings to

the PLHCP and have the PLHCP simply update

the original medical report for the employee

and medical opinion for the employer. This is

permitted under the standard, so long as all

requirements and time deadlines are met.

3.3. Public Health Professionals. PLHCPs

might refer employees or consult with

public health professionals as a result of

silica medical surveillance. For instance, if

individual cases of active TB are identiﬁed,

public health professionals from state

or local health departments may assist

in diagnosis and treatment of individual

cases and may evaluate other potentially

affected persons, including coworkers.

Because silica-exposed employees are at

increased risk of progression from latent

to active TB, treatment of latent infection

is recommended. The diagnosis of active

TB, acute or accelerated silicosis, or other

silica-related diseases and infections should

serve as sentinel events suggesting high

levels of exposure to silica and may require

consultation with the appropriate public

health agencies to investigate potentially

similarly exposed coworkers to assess for

disease clusters. These agencies include

local or state health departments or OSHA.

In addition, NIOSH can provide assistance

upon request through their Health Hazard

Evaluation program. (See Section 5 of this

Appendix)

4. Conﬁdentiality and Other Considerations.

The information that is provided from the

PLHCP to the employee and employer

under the medical surveillance section of

OSHA’s respirable crystalline silica standard

differs from that of medical surveillance

requirements in previous OSHA standards.

The standard requires two separate written

communications, a written medical report

for the employee and a written medical

opinion for the employer. The conﬁdentiality

requirements for the written medical opinion

are more stringent than in past standards. For

example, the information the PLHCP can (and

must) include in his or her written medical

opinion for the employer is limited to: the

date of the examination, a statement that the

examination has met the requirements of this

section, and any recommended limitations

on the employee’s use of respirators. If the

employee provides written authorization

for the disclosure of any limitations on the

employee’s exposure to respirable crystalline

silica, then the PLHCP can (and must) include

that information in the written medical

opinion for the employer as well. Likewise,

with the employee’s written authorization, the

PLHCP can (and must) disclose the PLHCP’s

referral recommendation (if any) as part of

the written medical opinion for the employer.

However, the opinion to the employer

must not include information regarding

recommended limitations on the employee’s

exposure to respirable crystalline silica or

any referral recommendations without the

employee’s written authorization.

The standard also places limitations on the

information that the Board Certiﬁed Specialist

in Pulmonary Disease or Occupational

Medicine can provide to the employer

without the employee’s written authorization.

The Specialist’s written medical opinion

for the employer, like the PLHCP’s opinion,

is limited to (and must contain): the date

of the examination and any recommended

limitations on the employee’s use of

respirators. If the employee provides written

authorization, the written medical opinion

can (and must) also contain any limitations

on the employee’s exposure to respirable

crystalline silica.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

The PLHCP should discuss the implication of

signing or not signing the authorization with

the employee (in a manner and language that

he or she understands) so that the employee

can make an informed decision regarding the

written authorization and its consequences.

The discussion should include the risk of

ongoing silica exposure, personal risk factors,

risk of disease progression, and possible

health and economic consequences. For

instance, written authorization is required

for a PLHCP to advise an employer that an

employee should be referred to a Board

Certiﬁed Specialist in Pulmonary Disease

or Occupational Medicine for evaluation of

an abnormal chest X-ray (B-reading 1/0 or

greater). If an employee does not sign an

authorization, then the employer will not

know and cannot facilitate the referral to a

Specialist and is not required to pay for the

Specialist’s examination. In the rare case

where an employee is diagnosed with acute

or accelerated silicosis, co-workers are likely

to be at signiﬁcant risk of developing those

diseases as a result of inadequate controls in

the workplace. In this case, the PLHCP and/or

Specialist should explain this concern to the

affected employee and make a determined

effort to obtain written authorization from the

employee so that the PLHCP and/or Specialist

can contact the employer.

Finally, without written authorization from

the employee, the PLHCP and/or Board

Certiﬁed Specialist in Pulmonary Disease

or Occupational Medicine cannot provide

feedback to an employer regarding control of

workplace silica exposure, at least in relation

to an individual employee. However, the

regulation does not prohibit a PLHCP and/

or Specialist from providing an employer

with general recommendations regarding

exposure controls and prevention programs

in relation to silica exposure and silica-

related illnesses, based on the information

that the PLHCP receives from the employer

such as employees’ duties and exposure

levels. Recommendations may include

increased frequency of medical surveillance

examinations, additional medical surveillance

components, engineering and work practice

controls, exposure monitoring and personal

protective equipment. For instance, more

frequent medical surveillance examinations

may be a recommendation to employers

for employees who do abrasive blasting

with silica because of the high exposures

associated with that operation.

ACOEM’s Code of Ethics and discussion is a

good resource to guide PLHCPs regarding the

issues discussed in this section (See Section

5 of this Appendix).

5. Resources.

5.1. American College of Occupational and

Environmental Medicine (ACOEM):

ACOEM Code of Ethics. Accessed at: http://

www.acoem.org/codeofconduct.aspx

Raymond, L.W. and Wintermeyer, S. (2006)

ACOEM evidenced-based statement on

medical surveillance of silica-exposed

workers: medical surveillance of workers

exposed to crystalline silica. J Occup Environ

Med, 48, 95-101.

5.2. Center for Disease Control and

Prevention (CDC)

Tuberculosis webpage: http://www.cdc.gov/

tb/default.htm

State TB Control Ofﬁces web page: http://

www.cdc.gov/tb/links/tbofﬁces.htm

Tuberculosis Laws and Policies webpage:

http://www.cdc.gov/tb/programs/laws/

default.htm

CDC. (2013). Latent Tuberculosis Infection:

A Guide for Primary Health Care Providers.

Accessed at: http://www.cdc.gov/tb/

publications/ltbi/pdf/targetedltbi.pdf

Occupational Safety and Health Administration

5.3. International Labour Organization

International Labour Ofﬁce (ILO).

(2011) Guidelines for the use of the ILO

International Classiﬁcation of Radiographs

of Pneumoconioses, Revised edition 2011.

Occupational Safety and Health Series No. 22:

http://www.ilo.org/safework/info/publications/

WCMS_168260/lang--en/index.htm

5.4. National Institute of Occupational Safety

and Health (NIOSH)

NIOSH B Reader Program webpage.

(Information on interpretation of X-rays for

silicosis and a list of certiﬁed B-readers).

Accessed at: http://www.cdc.gov/niosh/

topics/chestradiography/breader-info.html

NIOSH Guideline (2011). Application of

Digital Radiography for the Detection and

Classiﬁcation of Pneumoconiosis. NIOSH

publication number 2011-198. Accessed at:

http://www.cdc.gov/niosh/docs/2011-198/

NIOSH Hazard Review (2002), Health Effects

of Occupational Exposure to Respirable

Crystalline Silica. NIOSH publication number

2002-129: Accessed at http://www.cdc.gov/

niosh/docs/2002-129/

NIOSH Health Hazard Evaluations Programs.

(Information on the NIOSH Health Hazard

Evaluation (HHE) program, how to request

an HHE and how to look up an HHE report).

Accessed at: http://www.cdc.gov/niosh/hhe/

5.5. National Industrial Sand Association:

Occupational Health Program for Exposure

to Crystalline Silica in the Industrial

Sand Industry. National Industrial Sand

Association, 2nd ed. 2010. Can be ordered

at: http://www.sand.org/silica-occupational-

health-program

5.6. Occupational Safety and Health

Administration (OSHA)

Contacting OSHA: http://www.osha.gov/

html/Feed_Back.html

OSHA’s Clinicians webpage. (OSHA

resources, regulations and links to help

clinicians navigate OSHA’s web site and aid

clinicians in caring for workers.) Accessed

at: http://www.osha.gov/dts/oom/clinicians/

index.html

OSHA’s Safety and Health Topics webpage

on Silica. Accessed at: http://www.osha.gov/

dsg/topics/silicacrystalline/index.html

OSHA (2013). Spirometry Testing in

Occupational Health Programs: Best Practices

for Healthcare Professionals. (OSHA 3637-03

2013). Accessed at: http://www.osha.gov/

Publications/OSHA3637.pdf

OSHA/NIOSH (2011). Spirometry: OSHA/

NIOSH Spirometry InfoSheet (OSHA 3415-

1-11). (Provides guidance to employers).

Accessed at http://www.osha.gov/

Publications/osha3415.pdf

OSHA/NIOSH (2011) Spirometry: OSHA/

NIOSH Spirometry Worker Info. (OSHA 3418-

3-11). Accessed at http://www.osha.gov/

Publications/osha3418.pdf

5.7. Other

Steenland, K. and Ward E. (2014). Silica: A

lung carcinogen. CA Cancer J Clin, 64, 63-69.

(This article reviews not only silica and lung

cancer but also all the known silica-related

health effects. Further, the authors provide

guidance to clinicians on medical surveillance

of silica-exposed workers and worker

counselling on safety practices to minimize

silica exposure.)

6. References.

American Thoracic Society (ATS). Medical

Section of the American Lung Association

(1997). Adverse effects of crystalline silica

exposure. Am J Respir Crit Care Med, 155,

761-765.

American Thoracic Society (ATS), Centers for

Disease Control (CDC), Infectious Diseases

Society of America (IDSA) (2005). Controlling

Tuberculosis in the United States. Morbidity

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

and Mortality Weekly Report (MMWR),

54(RR12), 1-81. Accessed at: http://www.cdc.

gov/mmwr/preview/mmwrhtml/rr5412a1.htm

Brown, T. (2009). Silica exposure, smoking,

silicosis and lung cancer – complex

interactions. Occupational Medicine, 59, 89-95.

Halldin, C. N., Petsonk, E. L., and Laney,

A. S. (2014). Validation of the International

Labour Ofﬁce digitized standard images for

recognition and classiﬁcation of radiographs

of pneumoconiosis. Acad Radiol, 21,305-311.

International Agency for Research on

Cancer. (2012). Monographs on the

evaluation of carcinogenic risks to humans:

Arsenic, Metals, Fibers, and Dusts Silica

Dust, Crystalline, in the Form of Quartz

or Cristobalite. A Review of Human

Carcinogens. Volume 100 C. Geneva,

Switzerland: World Health Organization.

Jalloul, A. S. and Banks D. E. (2007). Chapter

23. The health effects of silica exposure.

In: Rom, W. N. and Markowitz, S. B. (Eds).

Environmental and Occupational Medicine,

edition. Lippincott, Williams and Wilkins,

Philadelphia, 365-387.

Kramer, M. R., Blanc, P. D., Fireman, E.,

Amital, A., Guber, A., Rahman, N. A., and

Shitrit, D. (2012). Artiﬁcal stone silicosis:

disease resurgence among artiﬁcial stone

workers. Chest, 142, 419-424.

Laney, A. S., Petsonk, E. L., and Attﬁeld, M.

D. (2011). Intramodality and intermodality

comparisons of storage phosphor computed

radiography and conventional ﬁlm-

screen radiography in the recognition of

small pneumonconiotic opacities. Chest,

140,1574-1580.

Liu, Y., Steenland, K., Rong, Y., Hnizdo, E.,

Huang, X., Zhang, H., Shi, T., Sun, Y., Wu,

T., and Chen, W. (2013). Exposure-response

analysis and risk assessment for lung cancer

in relationship to silica exposure: a 44-year

cohort study of 34,018 workers. Am J Epi,

178,1424-1433.

Liu, Y., Rong, Y., Steenland, K., Christiani, D.

C., Huang, X., Wu, T., and Chen, W. (2014).

Long-term exposure to crystalline silica and

risk of heart disease mortality. Epidemiology,

25, 689-696.

Mazurek, G. H., Jereb, J., Vernon, A., LoBue,

P., Goldberg, S., Castro, K. (2010). Updated

guidelines for using interferon gamma

release assays to detect Mycobacterium

tuberculosis infection – United States.

Morbidity and Mortality Weekly Report

(MMWR), 59(RR05), 1-25.

Miller, M. R., Hankinson, J., Brusasco, V.,

Burgos, F., Casaburi, R., Coates, A., Crapo, R.,

Enright, P., van der Grinten, C. P., Gustafsson,

P., Jensen, R., Johnson, D. C., MacIntyre,

N., McKay, R., Navajas, D., Pedersen, O. F.,

Pellegrino, R., Viegi, G., and Wanger, J. (2005).

American Thoracic Society/European

Respiratory Society (ATS/ERS) Task Force:

Standardisation of Spirometry. Eur Respir J,

26, 319-338.

National Toxicology Program (NTP) (2014).

Report on Carcinogens, Thirteenth Edition.

Silica, Crystalline (respirable Size). Research

Triangle Park, NC: U.S. Department of Health

and Human Services, Public Health Service.

http://ntp.niehs.nih.gov/ntp/roc/content/

proﬁles/silica.pdf

Occupational Safety and Health

Administration/National Institute for

Occupational Safety and Health (OSHA/

NIOSH) (2012). Hazard Alert. Worker

exposure to silica during hydraulic fracturing.

Occupational Safety and Health Administration/

National Institute for Occupational Safety and

Health (OSHA/NIOSH) (2015). Hazard alert.

Worker exposure to silica during countertop

manufacturing, ﬁnishing, and installation.

(OSHA- HA-3768-2015).

Redlich, C. A., Tarlo, S. M., Hankinson, J. L.,

Townsend, M. C, Eschenbacher, W. L., Von

Essen, S. G., Sigsgaard, T., Weissman, D. N.

(2014). Ofﬁcial American Thoracic Society

Occupational Safety and Health Administration

technical standards: spirometry in the

occupational setting. Am J Respir Crit Care

Med; 189, 984-994.

Rees, D. and Murray, J. (2007). Silica, silicosis

and tuberculosis. Int J Tuberc Lung Dis, 11(5),

474-484.

Shtraichman, O., Blanc, P. D., Ollech, J. E.,

Fridel, L., Fuks, L., Fireman, E., and Kramer,

M. R. (2015). Outbreak of autoimmune

disease in silicosis linked to artiﬁcial stone.

Occup Med, 65, 444-450.

Slater, M. L., Welland, G., Pai, M., Parsonnet,

J., and Banaei, N. (2013). Challenges with

QuantiFERON-TB gold assay for large-scale,

routine screening of U.S. healthcare workers.

Am J Respir Crit Care Med, 188,1005-1010.

Steenland, K., Mannetje, A., Boffetta, P.,

Stayner, L., Attﬁeld, M., Chen, J., Dosemeci,

M., DeKlerk, N., Hnizdo, E., Koskela, R., and

Checkoway, H. (2001). International Agency

for Research on Cancer. Pooled exposure-

response analyses and risk assessment for

lung cancer in 10 cohorts of silica-exposed

workers: an IARC multicentre study. Cancer

Causes Control,12(9):773-84.

Steenland, K. and Ward E. (2014). Silica: A

lung carcinogen. CA Cancer J Clin, 64, 63-69.

Townsend, M. C. ACOEM Guidance

Statement. (2011). Spirometry in the

occupational health setting – 2011 Update. J

Occup Environ Med, 53, 569-584.

7. Sample Forms.

Three sample forms are provided. The ﬁrst

is a sample written medical report for the

employee. The second is a sample written

medical opinion for the employer. And

the third is a sample written authorization

form that employees sign to clarify what

information the employee is authorizing to be

released to the employer.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

WRITTEN MEDICAL REPORT FOR EMPLOYEE

EMPLOYEE NAME: ____________________________________ DATE OF EXAMINATION: _______________

TYPE OF EXAMINATION:

[ ] Initial examination [ ] Periodic examination [ ] Specialist examination

[ ] Other: _______________________________________________________________________________________

RESULTS OF MEDICAL EXAMINATION:

Physical Examination – [ ] Normal [ ] Abnormal (see below) [ ] Not performed

Chest X-Ray – [ ] Normal [ ] Abnormal (see below) [ ] Not performed

Breathing Test (Spirometry) – [ ] Normal [ ] Abnormal (see below) [ ] Not performed

Test for Tuberculosis – [ ] Normal [ ] Abnormal (see below) [ ] Not performed

Other:___________________ [ ] Normal [ ] Abnormal (see below) [ ] Not performed

Results reported as abnormal: ____________________________________________________________________

__________________________________________________________________________________________________

[ ] Your health may be at increased risk from exposure to respirable crystalline silica due to the following:

_________________________________________________________________________________________________

RECOMMENDATIONS:

[ ] No limitations on respirator use

[ ] Recommended limitations on use of respirator: ________________________________________________________

[ ] Recommended limitations on exposure to respirable crystalline silica: ______________________________________

_________________________________________________________________________________________________

Dates for recommended limitations, if applicable: _______________ to _____________

MM/DD/YYYY MM/DD/YYYY

[ ] I recommend that you be examined by a Board Certified Specialist in Pulmonary Disease or Occupational Medicine

[ ] Other recommendations*:

__________________________________________________________________________

__________________________________________________________________________________________________

Your next periodic examination for silica exposure should be in: [ ] 3 years [ ] Other: ___________________

MM/DD/YYYY

Examining Provider: ________________________________________ Date: _____________________

(signature)

Provider Name: ___________________________________________

Office Address: ____________________________________________ Office Phone: ___________________

*These findings may not be related to respirable crystalline silica exposure or may not be work-related, and therefore

may not be covered by the employer. These findings may necessitate follow-up and treatment by your personal

physician.

Respirable Crystalline Silica standard (§ 1910.1053 or 1926.1153)

Occupational Safety and Health Administration

Small Entity Compliance Guide for Construction

Draft – Do not Quote or Cite 2/22/2017

WRITTEN MEDICAL OPINION FOR EMPLOYER

EMPLOYER: ____________________________________________

EMPLOYEE NAME: _______________________________________ DATE OF EXAMINATION: _______________

TYPE OF EXAMINATION:

[ ] Initial examination [ ] Periodic examination [ ] Specialist examination

[ ] Other: _______________________________________________________________________________________

USE OF RESPIRATOR:

[ ] No limitations on respirator use

[ ] Recommended limitations on use of respirator:_________________________________________________________

Dates for recommended limitations, if applicable: _______________ to _______________

MM/DD/YYYY MM/DD/YYYY

The employee has provided written authorization for disclosure of the following to the employer (if applicable):

[ ] This employee should be examined by an American Board Certified Specialist in Pulmonary Disease or Occupational

Medicine

[ ] Recommended limitations on exposure to respirable crystalline silica:_______________________________________

__________________________________________________________________________________________________

Dates for exposure limitations noted above: _______________ to _______________

MM/DD/YYYY MM/DD/YYYY

NEXT PERIODIC EVALUATION: [ ] 3 years [ ] Other: ______________

MM/DD/YYYY

Examining Provider: ______________________________________ Date: ___________

(signature)

Provider Name: _________________________________________ Provider’s specialty:_______________________

Office Address: _________________________________________ Office Phone: ______________

[ ] I attest that the results have been explained to the employee.

The following is required to be checked by the Physician or other Licensed Health Care Professional (PLHCP):

[ ] I attest that this medical examination has met the requirements of the medical surveillance section of the OSHA

Respirable Crystalline Silica standard (§ 1910.1053(h) or 1926.1153(h)).

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Small Entity Compliance Guide for Construction

Draft – Do not Quote or Cite 2/22/2017

AUTHORIZATION FOR CRYSTALLINE SILICA OPINION TO EMPLOYER

This medical examination for exposure to crystalline silica could reveal a medical condition that

results in recommendations for (1) limitations on respirator use, (2) limitations on exposure to

crystalline silica, or (3) examination by a specialist in pulmonary disease or occupational

medicine. Recommended limitations on respirator use will be included in the written opinion to

the employer. If you want your employer to know about limitations on crystalline silica exposure

or recommendations for a specialist examination, you will need to give authorization for the

written opinion to the employer to include one or both of those recommendations.

I hereby authorize the opinion to the employer to contain the following information, if relevant

(please check all that apply):

Recommendations for limitations on crystalline silica exposure

Recommendation for a specialist examination

I do not authorize the opinion to the employer to contain anything other than recommended

limitations on respirator use.

Please read and initial:

___ I understand that if I do not authorize my employer to receive the recommendation for

specialist examination, the employer will not be responsible for arranging and covering

costs of a specialist examination.

________________________________

Name (printed)

________________________________ ______________________

Signature Date

Occupational Safety and Health Administration

WORKERS’ RIGHTS

Under federal law, workers are entitled to

working conditions that do not pose a risk of

serious harm.

For more information on how to assure a

safe and healthful workplace, see OSHA’s

Workers page.

OSHA ASSISTANCE, SERVICES AND PROGRAMS

OSHA has a great deal of information to

assist employers in complying with their

responsibilities under OSHA law. Several

OSHA programs and services can help

employers identify and correct job hazards,

as well as improve their safety and health

program.

Establishing a Safety and

Health Program

Safety and health programs are systems that

can substantially reduce the number and

severity of workplace injuries and illnesses,

while reducing costs to employers.

Visit

www. osha.gov/shpguidelines for more

information.

Compliance Assistance Specialists

OSHA Compliance assistance specialists can

provide information to employers and workers

about OSHA standards, short educational

programs on speciﬁc hazards or OSHA rights

and responsibilities, and information on

additional compliance assistance resources.

Visit www.osha.gov/dcsp/compliance_

assistance/cas.html or call 1-800-321-OSHA

(6742) to contact your local OSHA ofﬁce.

Free On-site Safety and Health

Consultation Services for Small

Business

OSHA’s On-site Consultation Program offers

free and conﬁdential advice to small and

medium-sized businesses in all states, with

priority given to high-hazard worksites.

On-site consultation services are separate

from enforcement and do not result in

penalties or citations.

For more information or to ﬁnd the local

On-site Consultation ofﬁce in your state, visit

www.osha.gov/consultation, or call 1-800-321-

OSHA (6742).

Under the consultation program, certain

exemplary employers may request

participation in OSHA’s Safety and Health

Achievement Recognition Program (SHARP).

Worksites that receive SHARP recognition are

exempt from programmed inspections during

the period that the SHARP certiﬁcation is valid.

Cooperative Programs

OSHA offers cooperative programs under

which businesses, labor groups and other

organizations can work cooperatively with

OSHA. To ﬁnd out more about any of the

following programs, visit www.osha.gov/

cooperativeprograms.

Strategic Partnerships and Alliances

The OSHA Strategic Partnerships (OSP)

provide the opportunity for OSHA to partner

with employers, workers, professional or trade

associations, labor organizations, and/or other

interested stakeholders. Through the Alliance

Program, OSHA works with groups to develop

compliance assistance tools and resources

to share with workers and employers, and

educate workers and employers about their

rights and responsibilities.

Small Entity Compliance Guide for the Respirable Crystalline Silica Standard for General Industry and Maritime

Voluntary Protection Programs (VPP)

The VPP recognize employers and workers

in private industry and federal agencies who

have implemented effective safety and health

management programs and maintain injury and

illness rates below the national average for their

respective industries.

Occupational Safety and Health

Training Courses

The OSHA Training Institute partners with

27 OSHA Training Institute Education

Centers at 42 locations throughout the

United States to deliver courses on OSHA

standards and occupational safety and health

topics to thousands of students a year. For

more information on training courses, visit

www. osha.gov/otiec.

OSHA Educational Materials

OSHA has many types of educational materials

to assist employers and workers in ﬁnding and

preventing workplace hazards.

All OSHA publications are free at

www. osha. gov/

publications and www.osha.gov/ebooks.

You can also call 1-800-321-OSHA (6742) to

order publications.

Employers and safety and health professionals

can sign-up for Quic kTakes , OSHA’s free, twice-

monthly online newsletter with the latest news

about OSHA initiatives and products to assist in

ﬁnding and preventing workplace hazards. To

www. osha.gov/quicktakes.

Occupational Safety and Health Administration

OSHA REGIONAL OFFICES

Region I

Boston Regional Office

(CT*, ME*, MA, NH, RI, VT*)

JFK Federal Building, Room E340

Boston, MA 02203

(617) 565-9860 (617) 565-9827 Fax

Region II

New York Regional Office

(NJ*, NY*, PR*, VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378 (212) 337-2371 Fax

Region III

Philadelphia Regional Office

(DE, DC, MD*, PA, VA*, WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-3309

(215) 861-4900 (215) 861-4904 Fax

Region IV

Atlanta Regional Office

(AL, FL, GA, KY*, MS, NC*, SC*, TN*)

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(678) 237-0400 (678) 237-0447 Fax

Region V

Chicago Regional Office

(IL*, IN*, MI*, MN*, OH, WI)

230 South Dearborn Street

Room 3244

Chicago, IL 60604

(312) 353-2220 (312) 353-7774 Fax

Region VI

Dallas Regional Office

(AR, LA, NM*, OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(972) 850-4145 (972) 850-4149 Fax

(972) 850-4150 FSO Fax

Region VII

Kansas City Regional Office

(IA*, KS, MO, NE)

Two Pershing Square Building

2300 Main Street, Suite 1010

Kansas City, MO 64108-2416

(816) 283-8745 (816) 283-0547 Fax

Region VIII

Denver Regional Office

(CO, MT, ND, SD, UT*, WY*)

Cesar Chavez Memorial Building

1244 Speer Boulevard, Suite 551

Denver, CO 80204

(720) 264-6550 (720) 264-6585 Fax

Region IX

San Francisco Regional Office

(AZ*, CA*, HI*, NV*, and American Samoa,

Guam and the Northern Mariana Islands)

90 7th Street, Suite 18100

San Francisco, CA 94103

(415) 625-2547 (415) 625-2534 Fax

Region X

Seattle Regional Office

(AK*, ID, OR*, WA*)

300 Fifth Avenue, Suite 1280

Seattle, WA 98104

(206) 757-6700 (206) 757-6705 Fax

*These states and territories operate their own OSHA-

approved job safety and health plans and cover state

and local government employees as well as private

sector employees. The Connecticut, Illinois, Maine,

New Jersey, New York and Virgin Islands programs

cover public employees only. (Private sector workers

in these states are covered by Federal OSHA). States

with approved programs must have standards that

are identical to, or at least as effective as, the Federal

OSHA standards.

Note: To get contact information for OSHA area

offices, OSHA-approved state plans and OSHA

consultation projects, please visit us online at

www. osha.gov or call us at 1-800-321-OSHA (6742).

HOW TO CONTACT OSHA

For questions or to get information or advice, to report an

emergency, fatality, inpatient hospitalization, amputation,

or loss of an eye, or to ﬁle a conﬁdential complaint,

contact your nearest OSHA ofﬁce, visit www.osha.gov or

call OSHA at 1-800-321-OSHA (6742), TTY 1-877-889-5627.

For assistance, contact us.

We are OSHA. We can help.

For more information:

Occupational

Safety and Health

Administration

www.osha.gov (800) 321-OSHA (6742)

U.S. Department of Labor

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