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Small Entity

Compliance Guide

for the Respirable Crystalline

Silica Standard for Construction

OSHA 3902-07R 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.”

Material contained in this publication is in the public domain and may

be reproduced, fully or partially, without permission. Source credit is

requested but not required.

This information will be made available to sensory-impaired individuals

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 OSHA, International Masonry Institute.

Small Entity

Compliance Guide

for the Respirable Crystalline

Silica Standard for Construction

Occupational Safety and Health Administration

U.S. Department of Labor

OSHA 3902-07R 2017

This guidance document provides an

overview of OSHA’s Respirable Crystalline

Silica Standard for Construction. 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...................................................................................3

DEFINITIONS – PARAGRAPH (B) OF THE STANDARD ........................................................................5

SPECIFIED EXPOSURE CONTROL METHODS – PARAGRAPH (C) OF THE STANDARD .................5

ALTERNATIVE EXPOSURE CONTROL METHODS – PARAGRAPH (D) OF THE STANDARD ........34

Permissible Exposure Limit (PEL) ..................................................................................................34

Exposure Assessment ....................................................................................................................34

Methods of Compliance .................................................................................................................38

RESPIRATORY PROTECTION – PARAGRAPH (E) OF THE STANDARD ...........................................40

HOUSEKEEPING – PARAGRAPH (F) OF THE STANDARD ................................................................ 41

WRITTEN EXPOSURE CONTROL PLAN – PARAGRAPH (G) OF THE STANDARD ........................42

MEDICAL SURVEILLANCE – PARAGRAPH (H) OF THE STANDARD ...............................................48

COMMUNICATION OF HAZARDS – PARAGRAPH (I) OF THE STANDARD ....................................56

RECORDKEEPING – PARAGRAPH (J) OF THE STANDARD ..............................................................59

DATES – PARAGRAPH (K) OF THE STANDARD .................................................................................60

APPENDIX I: OSHA RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION .....61

WORKERS’ RIGHTS ...............................................................................................................................93

OSHA ASSISTANCE, SERVICES AND PROGRAMS .......................................................................... 93

OSHA REGIONAL OFFICES ................................................................................................................... 94

HOW TO CONTACT OSHA ....................................................................................................................95

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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 Construction. Workers

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 construction

from the hazards associated with exposure

to respirable crystalline silica. Employers in

industries other than construction should

refer to the small entity compliance guide for

occupational exposure to respirable crystalline

silica in general industry and maritime.

What is Respirable Crystalline Silica?

Crystalline silica is a common mineral found

in many naturally occurring and man-made

materials used at construction sites. Materials

like sand, concrete, brick, block, stone and

mortar contain crystalline silica. Amorphous

silica, such as silica gel, is not crystalline silica.

Respirable crystalline silica – very small

particles typically at least 100 times smaller

than ordinary sand found on beaches or

playgrounds – is generated by high-energy

operations like cutting, sawing, grinding, drilling

and crushing stone, rock, concrete, brick, block

and mortar, or when abrasive blasting with sand.

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 construction. 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.

Overview of the Standard

and Guide

This guide is divided into sections that

correspond to the major provisions

(paragraphs) of the silica standard for

construction. Each section describes the

provision and gives additional details to

help employers better understand the

requirements of the standard.

The ﬁrst step for an employer is to determine

if the standard applies to its work. If its work

is covered by the standard, an employer has

two options for limiting employee exposure

to respirable crystalline silica:

■ Speciﬁed exposure control methods; or

■ Alternative exposure control methods.

Employers who choose the speciﬁed

exposure controls option must fully and

properly implement protections for the

tasks or equipment listed in Table 1 of the

standard. Employers who fully and properly

implement the controls in Table 1 do not have

to assess employees’ silica exposure levels

or keep employee exposures at or below the

permissible exposure limit (PEL).

Employers who follow alternative exposure

control methods must:

■ Determine the levels of respirable crystalline

silica that employees are exposed to;

■ Limit employee exposures to a PEL of

50 micrograms per cubic meter of air

(50 μg/m

) as an 8-hour time-weighted

average (TWA);

■ Use engineering and work practice

controls, to the extent feasible, to limit

employee exposures to the PEL, and

supplement the controls with respiratory

protection when necessary.

■ Keep records of employee exposure to

respirable crystalline silica.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Roadmap for Meeting the Requirements of the Respirable Crystalline Silica Standard

1. Determine if the silica standard applies to your employees.

Could employees be exposed to respirable crystalline silica at or above 25 µg/m

as an 8-hour TWA under any

foreseeable conditions, including the failure of engineering controls, while performing construction activities?

No: No further action is required under the silica standard.

Yes: Choose to comply with the standard using either the:

• Speciﬁed exposure control methods in Table 1, or

• The alternative methods of compliance

2. Determine what additional requirements you must meet under the standard, based on the compliance

method you are following.

Requirement

Must the Employer Follow this Requirement?

If Fully and Properly

Implementing Table 1

If Following Alternative

Exposure Controls

PEL

No Yes

Exposure Assessment

Yes, when exposures are

reasonably expected to be

above the action level.

Methods of Compliance

No Yes

Respiratory Protection

Yes, if respirator use is

required by Table 1

Yes, if respirator use is

required to reduce exposures

to the PEL

Housekeeping

Yes Yes

Written Exposure Control Plan

Yes Yes

Medical surveillance

Yes, for employees who must wear a respirator under the silica

standard for 30 or more days a year.

Communication of Hazards

Yes Yes

Recordkeeping Yes, for any employees who are

getting medical examinations

Yes, for exposure assessments

and for any employees who are

getting medical examinations

All employers covered by the standard must:

■ Provide respiratory protection when required;

■ Restrict housekeeping practices that expose

employees to respirable crystalline silica

where feasible alternatives are available;

■ Establish and implement a written

exposure control plan, including

designating a competent person;

■ Offer medical exams to employees who

will be required to wear a respirator under

the standard for 30 or more days a year;

■ Communicate hazards and train

employees; and

■ Keep records of medical examinations.

See the roadmap listed below for more

information.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

SCOPE – PARAGRAPH (A) OF THE STANDARD

The standard applies to all occupational

exposures to respirable crystalline silica in

construction work, except where employee

exposure will remain below 25 μg/m

an 8-hour TWA under any foreseeable

conditions. Exposures to respirable

crystalline silica occur when the following

tools are used on concrete, brick, block,

stone, mortar, and other materials that

contain crystalline silica:

■ Stationary masonry saws;

■ Handheld power saws;

■ Walk-behind saws;

■ Drivable saws;

■ Rig-mounted core saws or drills;

■ Handheld and stand-mounted drills

(including impact and rotary hammer drills);

■ Dowel drilling rigs;

■ Vehicle-mounted drilling rigs;

■ Jackhammers and handheld powered

chipping tools;

■ Handheld grinders;

■ Walk-behind milling machines and

ﬂoor grinders;

■ Drivable milling machines;

■ Crushing machines; and

■ Heavy equipment and utility vehicles

when used to abrade or fracture silica-

containing materials (such as hoe-

ramming or rock ripping) or during

demolition activities, and for tasks such as

grading and excavating.

Exposures to respirable crystalline silica also

occur during tunneling operations and during

abrasive blasting when sand or other blasting

agents containing crystalline silica are used,

or when abrasive blasting is performed on

substrates that contain crystalline silica, such

as concrete.

Where Employee Exposure Will Remain

Below 25 μg/m

as an 8-Hour TWA

The standard does not apply where employee

exposure will remain below 25 μg/m

as an

8-hour TWA under any foreseeable conditions.

The phrase “any foreseeable conditions”

refers to situations that can reasonably

be anticipated. OSHA considers failure of

engineering controls to be a situation that is

reasonably foreseeable. 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

an 8-hour TWA are expected or achieved, but

only because engineering controls are being

used to limit exposures.

Employee exposure can reasonably be

anticipated to remain below 25 μg/m

an 8-hour TWA when performing certain

tasks that involve only minimal exposure to

respirable crystalline silica. Such tasks include:

■ Mixing concrete for post holes;

■ Pouring concrete footers, slab foundation,

and foundation walls; and

■ Removing concrete formwork.

When these tasks are performed in isolation

from tasks that generate signiﬁcant exposures

to respirable crystalline silica, the standard

does not apply. These examples are not

exclusive, and there may be other tasks that

involve exposure under 25 μg/m

as an 8-hour

TWA under any foreseeable conditions.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Some employees in the construction sector

perform tasks involving occasional, brief

exposures to respirable crystalline silica that

are incidental to their primary work. These

workers include carpenters, plumbers, and

electricians who occasionally drill holes

in concrete or masonry or perform other

tasks that involve exposure to respirable

crystalline silica. Where employees perform

tasks that involve exposure to respirable

crystalline silica for a very short period

of time, exposures for many tasks will be

below 25 μg/m

as an 8-hour TWA. For

example, for hole drillers using hand-held

drills, if the duration of exposure is 15

minutes or less, the 8-hour TWA exposure

can reasonably be anticipated to remain

under the 25 μg/m

threshold (assuming no

exposure for the remainder of the shift), and

the standard would not apply.

This exception for situations where

exposures are not likely to present signiﬁcant

risk to workers allows employers to focus

their resources on exposures of greater

occupational health concern.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

Competent person means an individual

who is capable of identifying existing and

foreseeable respirable crystalline silica

hazards in the workplace and who has

authorization to take prompt corrective

measures to eliminate or minimize them.

The competent person must have the

knowledge and ability necessary to

implement the written exposure control

plan required under the standard.

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, and some Table 1 tasks require HEPA-

ﬁltered vacuuming.

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.

SPECIFIED EXPOSURE CONTROL METHODS – PARAGRAPH (C)

OF THE STANDARD

The silica standard for construction provides

a ﬂexible approach for construction

employers to achieve compliance. The

standard includes Table 1, which lists 18

common tasks using various types of tools

or equipment found at construction sites.

For each employee engaged in a task in

Table 1, employers who choose to follow the

Table for that task are required to fully and

properly implement the engineering controls,

work practices, and respiratory protection

speciﬁed in Table 1. Employers who comply

with Table 1 are not required to conduct

exposure assessments or comply with a PEL

for those employees.

Employees engaged in the Table 1 task

means the equipment operator; helpers,

laborers and other employees who are

assisting with the task; or any other

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

employee responsible for completing the

task. For example, an employee operating

a walk-behind saw and another employee

helping the operator guide the saw are both

engaged in the task. An employee operating

a jackhammer would be engaged in the

task, but another employee directing trafﬁc

near the employee jackhammering would

not be engaged in the task. When Table 1

requires respiratory protection, employers

must provide respirators to all employees

engaged in the task. Employers must

describe procedures for restricting access of

employees not engaged in the task as part of

its Written Exposure Control Plan.

Fully and properly implemented means that

controls are in place, are properly operated

and maintained, and employees understand

how to use them. Several factors required

for full and proper implementation of

controls are listed in the discussion for each

Table 1 entry below. The presence of large

amounts of visible dust generally indicates

that controls are not fully and properly

implemented. A small amount of dust can be

expected from equipment that is operating

as intended by the manufacturer; however, a

noticeable increase in dust generation during

the task is a sign that the dust controls are not

operating correctly. The difference between

the small amounts of dust generated when

control measures are working properly and

the large amount of dust generated during

tasks when control measures are not used or

not operated effectively is easily observed.

When this happens, prompt corrective

actions are required.

As part of full and proper implementation,

many Table 1 tasks require the employer

to operate and maintain tools according to

manufacturers’ instructions for minimizing

dust emissions. Manufacturer’s instructions

for minimizing dust can include:

■ Water ﬂow rates,

■ Vacuum equipment air ﬂow rate and

capacity,

■ Rotation of the blade (speed, direction),

■ Maintaining and changing blades, and

■ Frequency for changing water.

See sections on Water Delivery Systems and

Dust Collection Systems for more information

about the use of controls for respirable

crystalline silica.

Several entries in Table 1 have requirements

for the use of respiratory protection with

a minimum “assigned protection factor”

(APF). Paragraph (d)(3)(i)(A) of the Respiratory

Protection standard (29 CFR 1910.134) includes

a table that can be used to determine the

type or class of respirator that will provide

employees with a particular APF, and it

can help employers determine the type of

respirator that would meet the required

minimum APF speciﬁed by Table 1. Employers

have the ﬂexibility to provide a more

protective respirator to those employees who

request one or require the employees to use

a more protective respirator. See section on

Determining Task Duration and Requirements

for Respirator Use for information on how

to measure task duration to determine

respiratory protection requirements for

employees doing one or more Table 1 task.

Description of Table 1 Entries

This section lists each Table 1 entry and

explains the requirement for that entry.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(i) Stationary masonry saws Use saw equipped with integrated water

delivery system that continuously feeds

water to the blade.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

None None

Stationary masonry saws must be equipped

with an integrated water delivery system

(commercially developed speciﬁcally for the

type of tool in use) that continuously feeds

water to the blade. The water delivery system

usually includes a nozzle for spraying water

attached near the blade that is connected

to a water basin by a hose and pump. The

tool must be operated and maintained in

accordance with manufacturer’s instructions

to minimize dust emissions. Stationary

masonry saws equipped with an integrated

system for blade cooling also suppress dust

and meet the requirements of Table 1.

Full and proper implementation of water

controls on stationary masonry saws

requires the employer to ensure that:

■ An adequate supply of water for dust

suppression is used;

■ The spray nozzle is working properly

to apply water at the point of dust

generation;

■ The spray nozzle is not clogged or

damaged; and

■ All hoses and connections are intact.

Table 1 does not specify a minimum ﬂow

rate; however, water must be applied at the

ﬂow rates speciﬁed by the manufacturer.

When using a stationary masonry saw

indoors or in an enclosed space (areas

where airborne dust can buildup, such as

a structure with a roof and three walls),

employers must provide additional exhaust

as needed to minimize the accumulation of

visible airborne dust.

See the section on Indoors or Enclosed Areas

for more information.

Respiratory protection is not required

for work with stationary masonry saws

regardless of task duration.

Worker cutting masonry block on a stationary masonry saw equipped with

integrated water delivery system that continuously feeds water to the blade.

Note water supply hose attached to top of shroud around blade.

Photo courtesy of OSHA, International Masonry Institute. The equipment

shown in this picture is for illustrative purposes only and is not intended as

an endorsement by OSHA of this company, its products or services.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(ii) Handheld power saws

(any blade diameter)

Use saw equipped with integrated water

delivery system that continuously feeds

water to the blade.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

Handheld power saws with any blade

diameter must be equipped with an

integrated water delivery system

(commercially developed speciﬁcally for

the type of tool in use) that continuously

feeds water to the blade. The water

delivery system usually includes a nozzle

for spraying water attached near the

blade that is connected to a water basin

via a hose and pump. The tool must be

operated and maintained in accordance with

manufacturer’s instructions to minimize dust

emissions. Handheld power saws equipped

with an integrated water delivery system for

blade cooling also suppress dusts and meet

the requirements of Table 1.

Full and proper implementation of water

controls on handheld power saws requires

the employer to ensure that:

■ An adequate supply of water for dust

suppression is used;

■ The spray nozzle is working properly to

apply water at the point of dust generation;

■ The spray nozzle is not clogged or damaged;

■ All hoses and connections are intact.

Table 1 does not specify a minimum ﬂow

rate; however, water must be applied at the

ﬂow rate speciﬁed by the manufacturer.

When working with handheld power saws

of any blade diameter, respiratory protection

with a minimum APF of 10 is required for

work done outdoors for

more than four hours per

shift and for work done

indoors, or in an enclosed

location, regardless of

task duration.

When using a handheld

saw indoors or in

enclosed spaces (areas

where airborne dust

can buildup, such

as a structure with a

roof and three walls),

employers must provide

additional exhaust, as

needed to minimize the

accumulation of visible

airborne dust. See the

section on Indoors or

Enclosed Areas for more

information.

A worker cutting a concrete

block using a handheld masonry

saw with an integrated water

delivery system.

Photo courtesy Husqvarna.

The equipment shown in

this picture is for illustrative

purposes only and is not

intended as an endorsement

by OSHA of this company, its

products or services.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(iii) Handheld power saws

for cutting ﬁber-cement

board (with blade diameter

of 8 inches or less)

For tasks performed outdoors only:

• Use saw equipped with commercially

available dust collection system.

• Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

• Dust collector must provide the air ﬂow

recommended by the tool manufacturer,

or greater, and have a ﬁlter with 99% or

greater efﬁciency.

None None

Specialty handheld power saws for cutting

ﬁber-cement board (with a blade diameter

of 8 inches or less) must be equipped with

commercially available dust collection

systems and a ﬁlter with a 99 percent or

greater efﬁciency. The saws must be operated

and maintained in accordance with the

manufacturer’s instructions to minimize

dust emissions, and provide the air ﬂow rate

recommended by the manufacturer or greater.

When employers are complying with Table 1,

the saws must only be used outdoors.

Full and proper implementation of dust

collection systems on handheld power saws

for cutting ﬁber-cement board requires the

employer to ensure that:

■ The shroud or cowling is intact and

installed in accordance with the

manufacturer’s instructions;

■ The hose connecting the tool to the vacuum

is intact and without kinks or tight bends;

■ The ﬁlter(s) on the vacuum are cleaned

or changed in accordance with the

manufacturer’s instructions to prevent

clogging; and

■ The dust collection bags are emptied to

avoid overﬁlling.

Respiratory protection is not required for

work outdoors with specialty handheld

power saws while cutting ﬁber-cement board

regardless of task duration.

Worker cutting ﬁber-cement board outdoors using a handheld power saw and

dust collection system. The dust collection system consists of the shroud on

the saw, hose, and dust collector positioned between the saw horses.

Photo courtesy of NIOSH.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(iv) Walk-behind saws

Use saw equipped with integrated water

delivery system that continuously feeds

water to the blade.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

None

APF 10

Walk-behind saws must be equipped

with an integrated water delivery system

(commercially developed speciﬁcally for

the type of tool in use) that continuously

feeds water to the blade. The tool must be

operated and maintained in accordance with

manufacturer’s instructions to minimize dust

emissions. Full and proper implementation of

water controls on walk-behind saws requires

the employer to ensure that:

■ An adequate supply of water for dust

suppression is used;

■ The spray nozzles are working properly

to apply water at the point of dust

generation;

■ The spray nozzles are not clogged or

damaged; and

■ All hoses and connections are intact.

Table 1 does not specify a minimum ﬂow

rate; however, water must be applied at the

ﬂow rate speciﬁed by the manufacturer.

Walk-behind saws used to cut roads and

cut pavement are most commonly used

outdoors, though they can also be used

indoors to cut concrete ﬂoors. When using

walk-behind saws indoors or in enclosed

areas (areas where airborne dust can

buildup, such as a structure with a roof

and three walls), employers must provide

additional exhaust, as needed to minimize the

accumulation of visible airborne dust. See

the section on Indoors or Enclosed Areas for

more information.

When working outdoors, respiratory protection

is not required for work with walk-behind saws

regardless of task duration. When working

indoors, or in an enclosed location, respiratory

protection with a minimum APF of 10 is

required regardless of task duration.

Worker using a walk-behind saw with an integrated water delivery system

to cut asphalt roadway.

Photo courtesy of OSHA.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(v) Drivable saws For tasks performed outdoors only:

• Use saw equipped with integrated water

delivery system that continuously feeds

water to the blade.

• Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

None None

Drivable saws used to cut silica-containing

materials (such as concrete, asphalt,

granite and terrazzo) must be equipped

with an integrated water delivery system

(commercially developed speciﬁcally for

the type of tool in use) that continuously

feeds water to the blade and must be

operated and maintained in accordance with

manufacturer’s instructions to minimize dust

emissions. Employers following Table 1 must

only allow the saws to be used outdoors.

Full and proper implementation of water

controls on drivable saws requires the

employer to ensure that:

■ An adequate supply of water for dust

suppression is used;

■ The spray nozzles produce a pattern

that applies water at the point of dust

generation;

■ The spray nozzles are not clogged or

damaged; and

■ All hoses and connections are intact.

Respiratory protection is not required

for work with drivable saws regardless of

task duration.

Worker cutting a groove in concrete roadway with drivable saw using

integrated water delivery system.

Photo courtesy of Husquvarna. The equipment shown in this picture is for

illustrative purposes only and is not intended as an endorsement by OSHA of

this company, its products or services.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(vi) Rig-mounted core

saws or drills

• Use tool equipped with integrated water

delivery system that supplies water to

cutting surface.

• Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

None None

Rig-mounted core saws or drills must be

equipped with an integrated water delivery

system (commercially developed speciﬁcally

for the type of tool in use) that supplies

water to the cutting surface, and must be

operated and maintained in accordance

with manufacturer’s instructions to minimize

dust emissions.

Full and proper implementation of water

controls on rig-mounted core saws or drills

requires the employer to ensure that:

■ An adequate supply of water for dust

suppression is used;

■ The spray nozzles produce a pattern

that applies water at the point of dust

generation;

■ The spray nozzles are not clogged or

damaged; and

■ All hoses and connections are intact.

When using rig-mounted core saws or drills

indoors or in enclosed areas (areas where

airborne dust can buildup, such as a structure

with a roof and three walls), employers must

provide additional exhaust, as needed to

minimize the accumulation of visible airborne

dust. See the section on Indoors or Enclosed

Areas for more information.

Respiratory protection is not required for

work with rig-mounted core saws or drills

regardless of task duration.

A rig-mounted core drill with an integrated water delivery system.

Photo courtesy of Hilti. The equipment shown in this picture is for illustrative

purposes only and is not intended as an endorsement by OSHA of this

company, its products or services.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(vii) Handheld and stand-

mounted drills (including

impact and rotary hammer

drills)

• Use drill equipped with commercially

available shroud or cowling with dust

collection system.

• Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

• Dust collector must provide the air ﬂow

recommended by the tool manufacturer,

or greater, and have a ﬁlter with 99% or

greater efﬁciency and a ﬁlter-cleaning

mechanism.

• Use a HEPA-ﬁltered vacuum when

cleaning holes.

None None

Handheld and stand-mounted drills (including

impact and rotary hammer drills). Handheld

and stand-mounted drills must be equipped

with a commercially available shroud or

cowling with a dust collection system that

provides at least the minimum air ﬂow

recommended by the manufacturer. The dust

collection system must include a ﬁlter

cleaning mechanism and be equipped with a

ﬁlter with 99 percent or greater efﬁciency. In

addition, the tool must be operated and

maintained in accordance with manufacturer’s

instructions to minimize dust emissions.

Full and proper implementation of dust

collection systems on handheld drills

requires the employer to ensure that:

■ The shroud or cowling is intact and

installed in accordance with the

manufacturer’s instructions;

Worker drilling into concrete with a rotary hammer equipped with shroud and

dust collection system. Note the shroud around drill bit, silver and black hose, and

dust collector are attached conveniently to the drill.

Photo courtesy of DeWalt. The equipment shown in this picture is for

illustrative purposes only and is not intended as an endorsement by OSHA of

this company, its products or services.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

■ The hose connecting the tool to the

vacuum is intact and without kinks or

tight bends;

■ The ﬁlter(s) on the vacuum are cleaned

or changed in accordance with the

manufacturer’s instructions; and

■ The dust collection bags are emptied to

avoid overﬁlling.

A HEPA-ﬁltered vacuum must be used when

cleaning holes. Compressed air can be used

to clean holes when used in conjunction with

a HEPA-ﬁltered vacuum to capture the dust

or a hole cleaning kit designed for use with

compressed air.

When using handheld and stand-mounted

drills indoors or in enclosed areas (areas

where airborne dust can buildup, such as

a structure with a roof and three walls),

employers must provide additional exhaust,

as needed to minimize the accumulation

of visible airborne dust. See the section

on Indoors or Enclosed Areas for more

information.

Respiratory protection is not required when

using handheld or stand-mounted drills

equipped with a dust collection system,

including for overhead drilling, regardless of

task duration.

Worker is drilling horizontal holes in a concrete wall using two stand-

mounted drills, each equipped with a dust collector. Note the shrouds around

drill bits, black hose, and dust collector are attached to the stand.

Photo courtesy of David Rempel, University of California, San Francisco.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(viii) Dowel drilling rigs for

concrete

For tasks performed outdoors only:

• Use shroud around drill bit with a

dust collection system. Dust collector

must have a ﬁlter with 99% or greater

efﬁciency and a ﬁlter-cleaning

mechanism.

• Use a HEPA-ﬁltered vacuum when

cleaning holes.

APF 10 APF 10

Dowel drills for concrete (i.e., gang drills) are

drills equipped with multiple drill bits that are

used to drill several holes at the same time.

Dowel drills must be equipped with a shroud

around the drill bit and a dust collection

system that has a ﬁlter with 99 percent

or greater efﬁciency. The dust collection

equipment must be equipped with a ﬁlter

cleaning mechanism. Employers following

Table 1 must allow dowel drilling rigs to only

be used outdoors.

Full and proper implementation of dust

collection systems on dowel drilling rigs

requires the employer to ensure that:

■ The shroud is intact and installed in

accordance with the manufacturer’s

instructions;

■ The hose connecting the tool to the

vacuum is intact and without kinks or

tight bends;

■ The ﬁlter(s) on the vacuum are cleaned

or changed in accordance with the

manufacturer’s instructions; and

■ The dust collection bags are emptied to

avoid overﬁlling.

A HEPA-ﬁltered vacuum must be used when

cleaning holes. Compressed air can be used

to clean holes when used in conjunction with

a HEPA-ﬁltered vacuum to capture the dust

or a hole cleaning kit designed for use with

compressed air.

Respiratory protection with a minimum APF of

10 is required for all work with dowel drilling

rigs for concrete regardless of task duration.

Worker drilling horizontal holes in concrete slab with a dowel drilling rig. The

shroud surrounds the drill steel where it enters the concrete and the dust

collector is the canister on the right. Worker is wearing respiratory protection.

Photo courtesy of NIOSH.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(ix) Vehicle-mounted

drilling rigs for rock and

concrete

Use dust collection system with close

capture hood or shroud around drill bit with

a low-ﬂow water spray to wet the dust at the

discharge point from the dust collector.

Operate from within an enclosed cab and

use water for dust suppression on drill bit.

None

Vehicle-mounted rock and concrete drilling

rigs must be equipped with a dust collection

system with a close capture hood or shroud

around the drill bit, and a low-ﬂow water

spray to wet the dust discharged from

the dust collector. This combination of

local exhaust ventilation (LEV) and water

application controls dust at all emission

points that can contribute to the operator’s

and other employees’ exposures.

Employers also have the option to have

the drill operator work within an enclosed

cab and, when necessary, apply water at

the drill bit, as described above, to reduce

exposures to other employees in the area.

See the section on Enclosed Cabs for more

information on how to make sure cabs meet

the requirements of Table 1.

Full and proper implementation of dust

collection systems on vehicle-mounted drilling

rigs requires the employer to ensure that:

■ The shroud or hood is intact and installed

in accordance with the manufacturer’s

instructions;

■ The hose connecting the tool to the vacuum

is intact and without kinks or tight bends;

■ The ﬁlter(s) on the vacuum are cleaned

or changed in accordance with the

manufacturer’s instructions; and

■ The dust collection bags are emptied to

avoid overﬁlling.

Full and proper

implementation of

water controls on

vehicle-mounted

drilling rigs requires

the employer to

ensure that:

■ An adequate

supply of

water for dust

suppression

is used;

■ The spray nozzles are working properly and

produce a pattern that applies water on the

discharge point from the dust collector;

■ The spray nozzles are not clogged or

damaged; and

■ All hoses and connections are intact.

Respiratory protection is not required for

work with vehicle-mounted drilling rigs

regardless of task duration.

Vehicle-mounted drilling rig using water on the

drill bit. The enclosed operator’s cab is on the right.

Photo courtesy of NIOSH.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(x) Jackhammers and

handheld powered

chipping tools

Use tool with water delivery system that

supplies a continuous stream or spray of

water at the point of impact.

• When used outdoors.

• When used indoors or in an

enclosed area.

Use tool equipped with commercially

available shroud and dust collection system.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

Dust collector must provide the air ﬂow

recommended by the tool manufacturer,

or greater, and have a ﬁlter with 99% or

greater efﬁciency and a ﬁlter-cleaning

mechanism.

• When used outdoors.

• When used indoors or in an

enclosed area.

None

APF 10

None

APF 10

Jackhammers and handheld powered

chipping tools must be operated using

either a water delivery system that supplies

a continuous stream or spray of water at the

point of impact, or a tool equipped with a

commercially available shroud and vacuum

dust collection system. Jackhammers and

other handheld powered chipping tools must

be operated and maintained in accordance

with manufacturer’s instructions to minimize

dust emissions.

If using the shroud and dust collection

system, the vacuum dust collection

system must provide at least the air ﬂow

recommended by the tool manufacturer,

and have a ﬁlter with 99 percent or greater

efﬁciency and a ﬁlter cleaning mechanism.

The water delivery system is not required to

be integrated or mounted on the tool; it can

be assembled and installed by the employer.

However, it must deliver a continuous stream

or spray of water at the point of impact.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Full and proper implementation of water

controls on jackhammers and other handheld

powered chipping tools requires the

employer to ensure that:

■ An adequate supply of water for dust

suppression is used;

■ The water sprays are working properly

and produce a pattern that applies water

at the point of dust generation;

■ The spray nozzles are not clogged or

damaged; and

■ All hoses and connections are intact.

Acceptable water delivery systems include

direct connections to ﬁxed water lines or

portable water tank systems. These water

delivery systems can be operated by one

worker or could require a second worker to

supply the water at the point of impact.

Full and proper implementation of dust

collection systems requires the employer

to ensure that:

■ The shroud is intact and installed in

accordance with the manufacturer’s

instructions;

■ The hose connecting the tool to the

vacuum is intact and without kinks or

tight bends;

■ The ﬁlter(s) on the vacuum are cleaned

or changed in accordance with the

manufacturer’s instructions; and

■ The dust collection bags are emptied to

avoid overﬁlling.

Respiratory protection with an APF of 10

is required when the task is done outdoors

for more than four hours per shift, or when

the task is done indoors or in an enclosed

location regardless of task duration.

When working indoors or in an enclosed

space (areas where airborne dust can

buildup, such as a structure with a roof

and three walls), employers must provide

additional exhaust, as needed to minimize the

accumulation of visible airborne dust. See

the section on Indoors or Enclosed Areas for

more information.

Jackhammer equipped with water spray delivery system to control dust. The

water nozzle is mounted on the jackhammer frame just to the right of the

chisel. Note the wet concrete on left from the water spray.

Photo courtesy of CPWR, Norman Zuckerman.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xi) Handheld grinders

for mortar removal (i.e.,

tuckpointing)

Use grinder equipped with commercially

available shroud and dust collection

system.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

Dust collector must provide 25 cubic feet

per minute (cfm) or greater of airﬂow per

inch of wheel diameter and have a ﬁlter

with 99% or greater efﬁciency and a

cyclonic pre-separator or ﬁlter-cleaning

mechanism.

APF 10 APF 25

Handheld grinders for mortar removal

(i.e., tuckpointing). Tuckpointing involves

removing deteriorating mortar from between

bricks using a handheld grinder and replacing

it with fresh mortar.

The handheld grinders must be equipped

with a commercially available shroud and

dust collection system and operated and

maintained in accordance with manufacturer’s

instructions to minimize dust emissions. The

dust collection system must provide at least

25 cfm of air ﬂow per inch of wheel diameter

and have a ﬁlter that has a 99 percent or

greater efﬁciency and either a cyclonic pre-

separator or a ﬁlter-cleaning mechanism.

Cyclonic pre-separators and ﬁlter-cleaning

mechanisms improve the suction of dust

collection systems by preventing debris from

building up on the ﬁlter.

Full and proper implementation of dust

collection systems on handheld grinders

requires the employer to ensure that:

■ The shroud is intact, encloses most of

the grinding blade, and is installed in

accordance with the manufacturer’s

instructions;

■ The hose connecting the tool to the

vacuum is intact and without kinks or tight

bends;

■ The ﬁlter(s) on the vacuum are cleaned

or changed in accordance with the

manufacturer’s instructions;

■ The dust collection bags are emptied to

avoid overﬁlling;

■ The blade is kept ﬂush against the surface

whenever possible; and

■ The tool is operated against the direction

of blade rotation, whenever practical.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

When using handheld grinders for mortar

removal indoors or in enclosed areas (areas

where airborne dust can buildup, such as

a structure with a roof and three walls),

employers must provide additional exhaust

if needed to minimize the accumulation

of visible airborne dust. See the section

on Indoors or Enclosed Areas for more

information on how to determine when those

work situations apply.

Respiratory protection with a minimum APF

of 10 is required for work with handheld

grinders for mortar removal lasting four

hours or less in a shift. Respiratory protection

with a minimum APF of 25 is required for

work lasting more than four hours per shift.

Worker grinding mortar from between bricks with a handheld grinder

equipped with a shroud and dust collection system. In addition, worker is

using respiratory protection.

Photo courtesy of OSHA, International Masonry Institute.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xii) Handheld grinders for

uses other than mortar

removal

For tasks performed outdoors only:

Use grinder equipped with integrated

water delivery system that continuously

feeds water to the grinding surface.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

Use grinder equipped with commercially

available shroud and dust collection system.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

Dust collector must provide 25 cubic feet

per minute (cfm) or greater of airﬂow per

inch of wheel diameter and have a ﬁlter

with 99% or greater efﬁciency and a

cyclonic pre-separator or ﬁlter-cleaning

mechanism.

• When used outdoors.

• When used indoors or in an

enclosed area.

None

APF 10

Handheld grinders may also be used for

tasks other than mortar removal, such as to

remove thin layers of concrete and surface

coatings. Two control options may be used:

(1) A grinder equipped with an integrated

water delivery system (commercially

developed speciﬁcally for the type of tool

in use) that continuously feeds water to the

grinding surface operated for outdoor work

only; and (2) a dust collector equipped with

a commercially available shroud and dust

collection system with the same features as

the dust collection system used for mortar

removal for outdoor and indoor work. The

dust collector must be rated to provide 25

cfm or greater air ﬂow per inch of wheel

diameter, have a ﬁlter with a 99 percent

or greater efﬁciency, and a cyclonic pre-

separator or ﬁlter-cleaning mechanism.

Cyclonic pre-separators and ﬁlter-cleaning

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

mechanisms improve the suction of dust

collection systems by preventing debris from

building up on the ﬁlter. The grinder and both

controls must be operated and maintained in

accordance with manufacturer’s instructions

to minimize dust emissions.

The integrated water delivery system can

be a free-ﬂowing water system designed

for blade cooling as well as manufacturers’

systems designed for dust suppression

alone. This option applies only when grinders

are used outdoors.

Full and proper implementation of water

controls on grinders requires the employer

to ensure that:

■ An adequate supply of water for dust

suppression is used;

■ The spray nozzles are working properly

and produce a pattern that applies water

at the point of dust generation;

■ The spray nozzles are not clogged or

damaged; and

■ All hoses and connections are intact.

Handheld grinders equipped with dust

collection systems may be used outdoors or

indoors. Full and proper implementation of

dust collection systems on handheld grinders

requires the employer to ensure that:

■ The shroud is intact and installed in

accordance with the manufacturer’s

instructions;

■ The hose connecting the tool to the

vacuum is intact and without kinks or

tight bends;

■ The ﬁlter(s) on the vacuum are cleaned

or changed in accordance with the

manufacturer’s instructions; and

■ The dust collection bags are emptied to

avoid overﬁlling.

Respiratory protection is not required when

water-based dust suppression systems are

used regardless of task duration. When dust

collection systems are used, respiratory

protection with a minimum APF of 10 is

required only when engaged in a task indoors

or in an enclosed location for more than four

hours per shift.

When using handheld grinders indoors or in

enclosed areas (areas where airborne dust

can buildup, such as a structure with a roof

and three walls), employers must provide

additional exhaust as needed to minimize the

accumulation of visible airborne dust. See

the section on Indoors or Enclosed Areas for

more information.

Worker grinding concrete ﬂoor with grinder attached to dust

collector (background).

Photo courtesy of the University of Washington.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xiii) Walk-behind milling

machines and ﬂoor

grinders

Use machine equipped with integrated

water delivery system that continuously

feeds water to the cutting surface.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

Use machine equipped with dust collection

system recommended by the manufacturer.

Operate and maintain tool in accordance

with manufacturer’s instructions to

minimize dust emissions.

Dust collector must provide the air ﬂow

recommended by the manufacturer, or

greater, and have a ﬁlter with 99% or

greater efﬁciency and a ﬁlter-cleaning

mechanism.

When used indoors or in an enclosed area,

use a HEPA-ﬁltered vacuum to remove

loose dust in between passes.

None

Two control options may be used when

using walk-behind milling machines and

ﬂoor grinders. Regardless of control option

used, the tool must also be operated

and maintained in accordance with

manufacturer’s instructions for minimizing

dust emissions.

Option one is to use an integrated water

delivery system (commercially developed

speciﬁcally for the type of tool in use) that

continuously feeds water to the cutting

surface. Table 1 does not specify a minimum

ﬂow rate; however, water must be applied at

ﬂow rates speciﬁed by the manufacturer.

Full and proper implementation of water

controls on walk-behind milling machines

and ﬂoor grinders requires the employer to

ensure that:

■ An adequate supply of water for dust

suppression is used;

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

■ The spray nozzles are working properly

and produce a pattern that applies water

at the point of dust generation;

■ The spray nozzles are not clogged or

damaged; and

■ All hoses and connections are intact.

Option two is to use a dust collection system

recommended by the manufacturer of

the milling machine or ﬂoor grinder and a

ﬁlter with 99 percent or greater efﬁciency

and a ﬁlter-cleaning mechanism. The dust

collection system used must be capable of

maintaining the air ﬂow recommended by the

manufacturer.

Full and proper implementation of dust

collection systems on walk-behind milling

machines and ﬂoor grinders requires the

employer to ensure that:

■ The hose connecting the tool to the

vacuum is intact and without kinks or

tight bends;

■ The ﬁlter(s) on the vacuum are cleaned

or changed in accordance with the

manufacturer’s instructions to prevent

clogging; and

■ The dust collection bags are emptied to

avoid overﬁlling.

When using a dust collector system indoors

or in enclosed areas (areas where airborne

dust can buildup, such as a structure with

a roof and three walls), loose dust must

be cleaned with a HEPA-ﬁltered vacuum in

between passes of the milling machine or

ﬂoor grinder to prevent the loose dust from

being re-suspended. Removing loose dust

with a HEPA vacuum also maximizes vacuum

suction by improving the seal between the

machine and ﬂoor. For indoor and enclosed

spaces, employers must provide additional

ventilation as needed to minimize the

accumulation of visible airborne dust. See

the section on Indoors or Enclosed Areas for

more information.

Respiratory protection is not required for

work with walk-behind milling machines and

ﬂoor grinders regardless of task duration.

Worker milling granite ﬂoor indoors with milling machine and dust collection

system (background).

Photo courtesy of OSHA.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xiv) Small drivable

milling machines (less

than half-lane)

Use a machine equipped with supplemental

water sprays designed to suppress dust.

Water must be combined with a surfactant.

Operate and maintain machine to minimize

dust emissions.

None None

Small drivable milling machines must

be used with supplemental water sprays

designed to suppress dust and must be

operated and maintained to minimize

dust emissions. The water used must be

combined with a surfactant.

Full and proper implementation of water

controls on small drivable milling machines

requires the employer to ensure that:

■ An adequate supply of water for dust

suppression is used;

■ The spray nozzles are working properly

and produce a pattern that applies water

at the point of dust generation;

■ The spray nozzles are not clogged or

damaged; and

■ All hoses and connections are intact.

When using small drivable milling machines

indoors or in enclosed areas (areas where

airborne dust can buildup, such as a

structure with a roof and three walls), the

employer must provide additional exhaust

as needed to prevent the accumulation

of visible airborne dust. See the section

on Indoors or Enclosed Areas for more

information on how to determine when

those work situations apply.

Respiratory protection is not required for work

with small drivable milling machines (less than

half-lane) regardless of task duration.

Milling machine milling asphalt road and loading debris into haul truck.

U.S. Air Force photo, Beth Holliker. The equipment shown in this picture is for

illustrative purposes only and is not intended as an endorsement by OSHA of

this company, its products or services.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xv) Large drivable

milling machines (half-

lane and larger)

For cuts of any depth on asphalt only:

Use machine equipped with exhaust ventilation

on drum enclosure and supplemental water

sprays designed to suppress dust.

Operate and maintain machine to minimize

dust emissions.

For cuts of four inches in depth or less on

any substrate:

Use machine equipped with exhaust ventilation

on drum enclosure and supplemental water

sprays designed to suppress dust.

Operate and maintain machine to minimize

dust emissions.

Use a machine equipped with supplemental

water spray designed to suppress dust.

Water must be combined with a surfactant.

Operate and maintain machine to minimize

dust emissions.

None

Employers whose employees operate large

(one-half lane or wider) milling machines

have two control options for cuts of four

inches in depth or less on any substrate

and one control option for cuts of any depth

on asphalt. When using any of the control

options, the machine must be operated and

maintained to minimize dust emissions.

The two control options for making cuts of

four inches or less on any combination of

roadway material (asphalt and concrete),

are to: (1) use a machine equipped with

exhaust ventilation on the drum enclosure

and supplemental water sprays designed to

suppress dust; or (2) use a machine equipped

with a supplemental water spray, combined

with a surfactant, designed to suppress dust.

When making cuts of any depth on roadway

material containing asphalt only, the only

control option is to use a machine equipped

with exhaust ventilation on the drum

enclosure and supplemental water sprays

designed to suppress dust.

Respiratory protection is not required for work

with large drivable milling machines (half-lane

or larger) regardless of task duration.

Milling machine milling asphalt road and loading debris into a haul truck.

Photo courtesy of NIOSH. The equipment shown in this picture is for

illustrative purposes only and is not intended as an endorsement by OSHA of

this company, its products or services.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xvi) Crushing machines Use equipment designed to deliver water

spray or mist for dust suppression at crusher

and other points where dust is generated

(e.g., hoppers, conveyers, sieves/sizing or

vibrating components, and discharge points).

Operate and maintain machine in

accordance with manufacturer’s

instructions to minimize dust emissions.

Use a ventilated booth that provides fresh,

climate-controlled air to the operator, or a

remote control station.

None None

When using crushing machines, employers

must provide workers with a remote control

station or ventilated booth that provides

fresh, climate-controlled air to the operator.

Water sprays or mists must be used for

dust suppression at the crusher and other

points where dust is generated (e.g., at

hoppers, conveyors, sieves/sizing or vibrating

components, and discharge points). See

the section on Enclosed Cabs for more

information on how to make sure enclosures

meet the requirements of the rule. Table 1 also

requires that the machine be operated and

maintained according to the manufactures

instructions to minimize dust emissions.

The water spray systems can be installed

so that they can be activated by remote

control. To prevent airborne dust from being

generated, full and proper implementation of

controls requires that:

■ Nozzles are located upstream of dust

generation points and positioned to

thoroughly wet the material;

■ The volume and size of droplets is adequate

to sufﬁciently wet the material (optimal

droplet size is between 10 and 150 μm); and

■ Spray nozzles are located far enough from

the target area to provide complete water

coverage but not so far that the water is

carried away by wind.

Respiratory protection is not required for

crusher operators regardless of task duration.

Crushing machine being loaded with construction debris by an excavator

Photo courtesy of Screen Machine Industries. The equipment shown in this

picture is for illustrative purposes only and is not intended as an endorsement

by OSHA of this company, its products or services.

Heavy equipment and utility vehicles include

a variety of wheeled or tracked vehicles,

ranging in size from large heavy construction

equipment, such as bulldozers, scrapers,

loaders, cranes and road graders, to smaller

and medium-sized utility vehicles, such as

tractors, bobcats and backhoes with attached

tools. Table 1 has two entries for heavy

equipment and utility vehicles based on the

types of tasks performed with that equipment.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xvii) Heavy equipment

and utility vehicles used to

abrade or fracture silica-

containing materials

(e.g., hoe-ramming, rock

ripping) or used during

demolition activities

involving silica-containing

materials

Operate equipment from within an

enclosed cab.

When employees outside of the cab are

engaged in the task, apply water and/

or dust suppressants as necessary to

minimize dust emissions.

None

The next Table 1 entry is heavy equipment

and utility vehicles used to abrade or fracture

silica-containing materials (e.g., hoe-ramming,

rock ripping) or used during demolition

activities involving silica-containing materials.

These include activities such as fracturing or

abrading rock and soil; demolishing concrete or

masonry structures; and loading, dumping, and

removing demolition debris.

The operator must be in an enclosed cab.

Modern heavy equipment already comes

equipped with enclosed, ﬁltered cabs that meet

the requirements of Table 1. See the section on

Enclosed Cabs for more information on how to

make sure that the cab meets the requirements

of the rule. When other employees are engaged

in the task, water, dust suppressants, or both

must also be applied as necessary to minimize

dust emissions.

Respiratory protection is not required for

heavy equipment operators and laborers

who assist heavy equipment operators

during demolition activities involving silica-

containing materials or activities where silica-

containing materials are abraded or fractured,

regardless of the duration of the task.

NOTE: When the operator exits the enclosed

cab and is no longer actively preforming

the task, the operator is considered to have

stopped the task. However, if other abrading,

fracturing, or demolition work is performed

by other heavy equipment and utility vehicles

in the area while an operator is outside the

cab, that operator is considered to be an

employee “engaged in the task” and must be

protected by the application of water and/or

dust suppressants.

Excavator equipped with an enclosed cab and hoe-ram demolishing a

concrete wall.

Photo courtesy of CPWR.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xviii) Heavy equipment

and utility vehicles for

tasks such as grading

and excavating but not

including demolishing,

abrading, or fracturing

silica-containing materials

Apply water and/or dust suppressants as

necessary to minimize dust emissions.

When the equipment operator is the only

employee engaged in the task, operate

equipment from within an enclosed cab.

None

Heavy equipment and utility vehicles used

for tasks such as grading and excavating do

not involve demolition or the fracturing or

abrading of silica. Tasks include earthmoving,

grading, and excavating; other activities such

as moving, loading, and dumping soil and

rock; and dumping and grading of ballast

in the railroad industry, which is generally

subject to OSHA’s Construction standards.

Employers have two control options when the

operator is the only employee engaged in the

task and one option when employees other

than the operator are engaged in the task. The

ﬁrst option requires the equipment operator

to operate the equipment within an enclosed

cab when the operator is the only employee

in the area. Most heavy equipment already

comes equipped with enclosed, ﬁltered

cabs that meet the requirements of Table 1.

See the section on Enclosed Cabs for more

information on how to make sure that the cab

meets the requirements of the rule.

The second option requires the application of

water and/or dust suppressants as necessary

to minimize dust emissions. Water must be

applied at rates sufﬁcient to minimize release

of visible dust. The following scenarios are

examples of when the employer must use

water and/or dust suppressants as necessary

to minimize dust emissions: (1) equipment for

grading and excavating is not equipped with

enclosed, pressurized cabs or (2) employees

other than the operator are engaged in

the task. If water or dust suppressants are

applied as necessary to minimize visible dust,

the employer need not provide an enclosed,

ﬁltered cab for the operator.

Respiratory protection is not required for

work with heavy equipment when it is

operated from within an enclosed cab, or

when water or other dust suppressants are

used, regardless of task duration.

Earthmoving using a dozer equipped with enclosed operator cab.

Photo courtesy of NIOSH.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Water Delivery Systems

Integrated water delivery systems are

required for several types of equipment

in Table 1. Integrated water systems must

be developed speciﬁcally for the type of

tool in use so they will apply water at the

appropriate dust emission points based

on tool conﬁguration and do not interfere

with other tool components or safety

devices. Water systems designed for blade

cooling also suppress dust and meet the

requirements for Table 1.

The water must be applied at ﬂow rates

sufﬁcient to minimize release of visible

dust. Effective control of the dust depends

on factors such as dust particle size, dust

particle velocity, spray nozzle size and

location, use of surfactants or other binders,

and environmental factors (water hardness,

humidity, weather, etc.), all of which must be

considered when using wet methods. The

appropriate water ﬂow rates for controlling

silica dust emissions can vary; therefore,

it is necessary to follow manufacturers’

instructions when determining the required

ﬂow rate for dust suppression systems on a

given worksite.

Any slurry generated when using water to

suppress dust should be cleaned up to limit

secondary exposure to silica dust when the

slurry dries following procedures described in

the employer’s Written Exposure Control Plan.

When working in cold temperatures, where

there is a risk of water freezing, additional

work practices such as insulating drums,

wrapping drums with gutter heat tape or

adding environmentally-friendly antifreeze

additives to water may be needed.

Dust Collection Systems

Commercially available dust collection

systems (i.e., LEV) are required for several

types of equipment in Table 1. This

requirement ensures that employers use

equipment that is designed to effectively

capture dust generated by the tool being

used and does not introduce new hazards

such as obstructing or interfering with safety

mechanisms.

The “commercially available” limitation

is meant only to eliminate on-site

improvisations of equipment by the

employer. Employers can use products that

are made by aftermarket manufacturers

(someone other than the original tool

manufacturer) that are intended to ﬁt the

make and model of the tool. This includes

custom-designed products made to meet

the particular needs and speciﬁcations of

the employer purchasing the product. These

systems are designed to work effectively

with the equipment and not introduce new

hazards such as obstructing or interfering

with safety mechanisms. When employers

use methods other than commercially

available systems for dust suppression, they

must conduct exposure assessments and

comply with the PEL.

Some Table 1 entries for dust collection

systems specify use of cyclonic pre-

separators and ﬁlter cleaning mechanisms to

prevent buildup of debris on ﬁlters that result

in less dust capture. A cyclonic pre-separator

collects large debris before the air reaches

the ﬁlters. A ﬁlter cleaning mechanism

prevents the need for manually cleaning

ﬁlters to prevent buildup of debris (caking).

Some vacuums are equipped with a gauge

indicating ﬁlter pressure or an equivalent

device (e.g., timer to periodically pulse the

ﬁlter) to help employees in determining when

it is time to run a ﬁlter cleaning cycle.

Indoors or Enclosed Areas

Several Table 1 entries refer to tasks

performed “outdoors” or “indoors or in an

enclosed area.” Indoors or in an enclosed

areas mean areas where airborne dust can

build up unless additional exhaust is used.

For example, a work area with only a roof

that does not affect the dispersal of dust

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

would not be considered enclosed; however,

an open-top structure with three walls and

limited air movement or a roof that does limit

dispersal would be considered enclosed.

Sufﬁcient air circulation in enclosed or indoor

environments is important to ensure the

effectiveness of the control strategies and to

prevent the accumulation of airborne dust.

Employers following Table 1 are required

to provide a means of exhaust as needed

to minimize the accumulation of visible

airborne dust for tasks performed indoors

or in enclosed areas. The means of exhaust

necessary could include: the use of portable

fans (box fans, ﬂoor fans, axial fans), portable

ventilation systems, or other systems that

increase air movement and assist in the

removal and dispersion of airborne dust. To

be effective, the ventilation must be set up so

that movements of employees during work,

or the opening of doors and windows, will

not negatively affect the airﬂow.

Enclosed Cabs

Enclosed cabs or booths are speciﬁed for

rock drilling, crushers, and heavy equipment.

Employers must ensure that the enclosed cab

or booth is:

■ Maintained as free as practicable from

settled dust;

■ Has door seals and closing mechanisms

that work properly;

■ Has gaskets and seals that are in good

condition and work properly;

■ Is under positive pressure maintained

through continuous delivery of ﬁltered air;

■ Has intake air that is ﬁltered through a pre-

ﬁlter that is 95% efﬁcient in the 0.3-10.0

μm range (e.g., MERV-16 or better); and

■ Has heating and cooling capabilities.

The controls for enclosed cabs lower the

potential for dust to be re-suspended inside

the cab or enter the enclosed cab or booth.

They also ensure that the ﬁltered air provided

to the employee does not contain silica

particles and that the working conditions in

the cab are comfortable so that employees are

less likely to open windows and be exposed.

The procedures for maintaining and cleaning

the cab or booth, and for frequent and regular

inspections of the cabs and booths, must be

addressed through the employer’s Written

Exposure Control Plan and Competent Person

requirements described below.

Determining Task Duration and

Requirements for Respirator Use

Respirator requirements in Table 1 are

divided by task duration:

■ “Less than or equal to four hours/shift” and,

■ “Greater than four hours/shift”.

Each of the following scenarios is considered

a “shift” for purposes of determining the

maximum amount of time that an employee

may spend on Table 1 tasks without

respiratory protection:

■ A standard 8-hour work period;

■ A day with a break between work periods

(e.g., four hours on, two hours off, four

hours on);

■ Work periods longer than eight hours;

■ Double shifts within a single day;

■ A work period spanning two calendar days

(e.g., 8 p.m. until 4 a.m.).

Task duration time starts when the

operator begins using the tool, and

continues to be counted until he or she

completes the task. This time includes

intermittent breaks in tool usage and clean-

up. However, tasks that are performed

multiple times per day, during distinct time

periods, should be counted as separate

tasks, and times should be combined.

The requirement to provide respirators is

based on the anticipated duration of the task.

Employers must make a good-faith judgment

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

of the task’s anticipated duration over the work

shift, whether performed continuously or

intermittently, based on previous experience

and all other available information.

If an employer estimates that an employee

will perform a single task for four hours or

less during a single shift, then the employer

must ensure that the employee uses

whichever respirator, if any, is speciﬁed in

the “≤ 4 hr/shift” column in Table 1. If an

employer estimates that the task will take

more than four hours, then the employer

must ensure that the employee uses any

respiratory protection speciﬁed in the “> 4 hr/

shift” column in Table 1, during the entire

task, not just during the time beyond the ﬁrst

four hours that the task is performed.

If an employer anticipates that a task will take

four hours or less, but unforeseen difﬁculties

will extend the task duration beyond four

hours, the employer is required to provide

the listed respiratory protection as soon as it

becomes evident that the duration of the task

may exceed the 4-hour limit, measured from

the beginning of the task.

Where an employee performs more than

one task in Table 1 during the course of

a shift, and the total duration of all tasks

combined is less than four hours, the

required respiratory protection for each

task is the respiratory protection speciﬁed

in the less than four hours per shift column.

If the total duration of all Table 1 tasks

combined is more than four hours per shift,

the required respiratory protection for each

task is the respiratory protection speciﬁed

in the more than four hours per shift

column. As was discussed for single tasks,

if multiple tasks are estimated to last less

than 4 hours, but it becomes evident that the

tasks will take more than four hours total,

the employer must reexamine respiratory

protection requirements and immediately

provide a respirator, when required.

Examples of Determining Task Durations

1. Tasks with intermittent breaks. An

employee cuts and places bricks, one at a

time, for four hours consecutively and then

spends 30 minutes cleaning up the saw and

emptying slurry or dust collectors. All four

hours spent cutting and laying bricks along

with the 30 minutes for clean-up count for a

total task duration of four and a half hours.

2. Tasks with distinct time periods. An

employee cuts multiple bricks for 15 minutes,

lays bricks for two hours before returning to

cut more bricks for another 30 minutes. The

total task duration is 45 minutes

Examples of Respiratory Protection

Requirements for Single Tasks in Table 1

1. An employer anticipates that it will take

an employee 3 hours to cut concrete walls

using a handheld power saw (outdoors). No

respiratory protection is required.

2. An employer anticipates that it will take an

employee 5 hours to demolish an asphalt

road using a jackhammer (outdoors). The

employer must provide a respirator with

an APF of 10 and ensure that the employee

wears it for the entire duration of the task.

3. An employer anticipates that it will take an

employee 3 hours to grind a concrete ﬂoor

(indoors) and, therefore, determines that

respiratory protection is not required under

Table 1. However, at two hours, the employer

determines that it will take more than 4 hours

to complete the task. The employer must

provide a respirator with an APF of 10 at that

time and ensure that the employee wears it

for the remaining duration of the task.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

Examples of Respiratory Protection Requirements for Employees who do more than

one Table 1 Task

1. An employer anticipates that an employee will use a handheld grinder on a concrete wall outdoors for

3 hours and then use a chipping hammer outdoors for 2 hours (total Table 1 task duration of 5 hours per

shift). The employer looks in the “> 4 hour/shift” column for each task to determine that no respiratory

protection is required during use of the handheld grinder outdoors, but a respirator with an APF of 10 is

required during use of the chipping hammer outdoors.

2. An employer anticipates that an employee will use a stationary masonry saw to cut bricks for 1 hour

and use a handheld power saw to cut concrete indoors for 1 hour over the course of a shift (total Table

1 task duration of two hours per shift). The employer looks in the “≤ 4 hour/shift” column for each task

to determine that no respiratory protection is required during use of the stationary masonry saw, but a

respirator with an APF of 10 is required during use of the handheld power saw indoors.

3. An employer anticipates that an employee will drive a half-lane milling machine for 4 hours and then

operate a walk-behind milling machine equipped with an integrated water delivery system for 4 hours

(total Table 1 task duration of 8 hours). The employer looks in the “> 4 hour/shift” column for each task

to determine that no respiratory protection is required for either task.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

ALTERNATIVE EXPOSURE CONTROL METHODS –

PARAGRAPH (D) OF THE STANDARD

Employers that conduct tasks not listed in

Table 1 or do not fully and properly implement

the engineering controls, work practices, and

respiratory protection described in Table 1

of the speciﬁed exposure control methods

approach must follow the alternative exposure

control methods approach. The alternative

exposure control methods approach involves

assessing employee exposure to respirable

crystalline silica, and limiting exposure to

the PEL using feasible engineering and work

practice control methods, and respiratory

protection when necessary. Each of the three

components of alternative exposure control

methods – the PEL, exposure assessment, and

methods of compliance – is explained below.

Permissible Exposure Limit (PEL)

Employers complying with the alternative

exposure control methods 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 at

construction workplaces, and in most cases,

quartz will be the only form of respirable

crystalline silica analyzed in air samples used

to measure employee exposures.

Exposure Assessment

Construction employers following alternative

exposure control methods 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.

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

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

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.

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

The performance option may be especially

useful when measuring employee exposures

is challenging, such as when tasks are

conducted for short durations of time or

performed under different weather conditions.

The performance option gives employers

ﬂexibility for characterizing the exposures

of all employees. For example, instead

of 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 APF of at least 10, as well as medical

surveillance for employees required to wear

a respirator under the silica standard for

30 or more days per year.

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.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

■ 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

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

task performed in an open, outdoor location

is moved to an enclosed or conﬁned space,

because the change in conditions 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 indoor to an outdoor

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 5 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 5-day period for notiﬁcation starts when:

■ An employer following the performance

option ﬁnishes the exposure assessment; or

■ 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 5 days to identify the right engineering

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

controls, respiratory protection is the

corrective action that would be described in

the written notiﬁcation.

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.

Methods of Compliance

Employers following alternative exposure

control methods must comply with the

methods of compliance requirements 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 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.

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 an integrated water delivery

system on a stationary masonry saw.

Local exhaust ventilation removes dust by

capturing it at or near the point where it is

created. An example is a dust collector for a

handheld grinder.

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 cab on heavy equipment.

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;

■ Making sure that nozzles spray water

at the point of dust generation for wet

method controls;

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

■ Making sure that hoses are not kinked on

a tool used with a dust collector;

■ 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 less prone to human error than 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.

Abrasive Blasting. In addition to complying

with requirements to use engineering controls

and work practices according to the hierarchy

of controls, construction employers that

conduct abrasive blasting operations using

crystalline silica-containing blasting agents or

conduct abrasive blasting on structures that

contain crystalline silica must also comply

with other relevant standards, such as the

ventilation standard for construction (29 CFR

1926.57), which contains requirements for

ventilation and personal protective equipment,

including respirators. This is simply a cross-

reference to other standards that construction

employers must comply with when

conducting abrasive blasting.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

RESPIRATORY PROTECTION – PARAGRAPH (E)

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 who follow the speciﬁed

exposure control methods listed in Table 1

must provide respiratory protection where

required by Table 1. Employers who follow

alternative exposure control methods 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.

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.

If an employer following the speciﬁed

exposure control methods fully and properly

implements the engineering controls, work

practices, and respiratory protection required

in Table 1, the employer will be considered to

be in compliance with the requirements of the

silica standard and the respiratory protection

standard for identifying and evaluating

respiratory hazards and providing each

employee with an appropriate respirator.

Employers following Table 1 must comply

with all other requirements of the Respiratory

Protection 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.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

HOUSEKEEPING – PARAGRAPH (F) OF THE STANDARD

The respirable crystalline silica standard

requires all construction employers covered

by the standard, including those who

fully and properly implement the control

methods speciﬁed in Table 1, 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

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 a wood ﬂoor because water would

damage the wood or cause mold growth,

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 created by high-

energy tasks such as drilling, cutting,

grinding, or crushing crystalline-silica-

containing materials. Employers are not

required to follow these housekeeping

requirements when cleaning ordinary soil,

large debris, and non-silica-containing

materials, such as sawdust.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

WRITTEN EXPOSURE CONTROL PLAN – PARAGRAPH (G)

OF THE STANDARD

All employers covered by the standard,

including employers who fully and properly

implement the speciﬁed exposure controls

in Table 1, 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, housekeeping methods,

and restricting access to areas where

high exposures occur. 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 the use of a

stationary masonry saws for cutting bricks.

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. This section could also describe

the equipment used and factors that affect

exposures, such as types of silica-containing

materials handled in those tasks (concrete or

tile), weather conditions (wind or humidity),

soil types (clay versus rock), and if tasks

are done outdoors versus indoors or in

enclosed locations.

Example: Cutting bricks using a stationary

masonry saw outdoors.

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 a dust collector with

manufacturer’s recommended air ﬂow and

a ﬁlter with 99 percent efﬁciency, effective

work practices, as in checking that water

nozzles are not plugged, 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

saw blade.

This section of the written exposure control

plan is especially important for construction

employers who use controls in Table 1,

because they are not required to measure

exposures to make sure that controls are

working. Therefore, including information

such as manufacturer’s instructions for

operating and maintaining tools to decrease

dust, when possible, demonstrates that the

employer has a complete understanding

of those instructions and is using them to

control dust. Describing those instructions in

the written exposure control plans also lets

employees know what the employer needs to

do to protect them.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

Example: When cutting bricks using a

stationary masonry saw, Table 1 will be fully

and properly implemented, including using a

saw with an integrated water delivery system

that delivers a steady stream of water to the

cutting blade. The saw operator will make

sure that enough water for the saw is available

before starting to cut, and that a steady

stream of water can be seen while cutting. The

operator will change water, when needed, to

maintain ﬂow of water to the blade.

Use the stationary masonry saw in accordance

with manufacturer’s instructions to minimize

the release of visible dust. Inspect dust

controls daily to make sure they are functioning

properly. Stop work and adjust controls if you

see an increase in visible dust.

Respiratory protection is not required.

The plan must include a description of

the housekeeping methods used to limit

employee exposure to respirable crystalline

silica. While employees are cleaning, dust

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: Slurry generated by the saw will be

cleaned up before it dries using a wet vacuum.

When emptying the vacuum, the slurry will be

transferred into a plastic bag and placed inside

a container for disposal. The container will be

sealed to prevent the release of dust back into

the work space.

Never sweep or use compressed air on dried

slurry. If slurry dries, immediately wet it down

and clean it up with the wet vacuum.

The plan must include a description of the

procedures used to restrict access to work

areas, when necessary, to limit the number of

employees exposed to respirable crystalline

silica and the levels to which they are

exposed, including exposures generated by

other employers or self-employed workers.

This section of the plan must describe how

the employer restricts access to prevent

exposures, such as:

■ Scheduling certain tasks when others are

not around,

■ Telling employees to stay out of areas

where dust is generated,

■ Moving employees to an area where they

are not exposed to dust, or

■ Posting warning signs.

Employers following the alternative exposure

control methods approach must restrict

access where an exposure assessment shows

that exposures are above the PEL. When

following Table 1, employers must restrict

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

access when employees are engaged in tasks

that require respirator use under Table 1. For

example, if an employer following Table 1

has an employee who is jackhammering for

more than four hours and is therefore wearing

a respirator, the employer or the competent

person must make sure that an employee

directing trafﬁc (not engaged in the task),

is positioned away and upwind from the

employee who is jackhammering.

The employer or competent person must also

restrict access, when needed, for exposures

generated by another employer or self-

employed person. Such a situation might

occur if the other employer of self-employed

person is conducting a task that generates

clearly visible dust.

Example: When the controls on a stationary

masonry saw are fully and properly

implemented, access does not need to be

restricted to decrease other employees’

exposure to respirable crystalline silica.

The competent person can use trafﬁc cones

or barrier tape to restrict access if needed for

other reasons such as safety concerns.

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 CONSTRUCTION

The Center for Construction Research and

Training (CPWR) has a tool to help employers

develop written exposure control plans that

is available at www.silica-safe.org. 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 construction 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.

Employers can also develop a comprehensive

plan that includes all equipment, materials,

tasks, and conditions for the jobs they

perform. Doing so will greatly reduce the

need to update the written plan for each

new job or jobsite for the many construction

employers who use the same equipment to

perform the same tasks at many locations.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Sample Written Exposure Control Plan

Company: Person Completing the Plan, Title:

John Doe Renovators John Doe, Owner

Description of Task:

Demolishing concrete and tile ﬂoors inside homes or public buildings using a jackhammer.

Control Description

Controls:

• Use jackhammer equipped with the appropriate, commercially available shroud and a vacuum

dust collection system with the ﬂow rate recommended by the jackhammer manufacturer, a ﬁlter

that is at least 99 percent efﬁcient, and a ﬁlter cleaning mechanism.

• Use a portable fan to exhaust air and prevent the buildup of dust.

Work practices:

• Check shrouds and hoses to make sure they are not damaged before starting work.

• Make sure the hoses do not become kinked or bent while working.

• Use switch on vacuum to activate ﬁlter cleaning at the frequency recommended by the manufacturer.

• Replace vacuum bags as needed to prevent overﬁlling.

• Use the jackhammer and vacuum controls according to manufacturer’s instructions for reducing

the release of visible dust.

• If visible dust increases, check controls and adjust as needed.

Respiratory protection:

• Use respirator with APF of 10 the entire time the task is being performed.

• See the written respiratory protection program for information on selection, training and ﬁt

testing requirements, in addition to proper use instructions for respirators (for example, being

clean shaven when using a respirator that seals against the face).

Housekeeping:

• Dust containing silica on work surfaces and equipment must be cleaned up using wet methods or

a HEPA-ﬁltered vacuum.

• Do not use compressed air or dry sweeping for removing dust and debris containing silica from

work surfaces.

• Dispose of used vacuum bags in a container and keep the container sealed.

Procedures Used to Restrict Access to Work Areas:

Schedule the work so that only employees who are engaged in the task (the jackhammer operator

and employees helping the operator) are in the area.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

Competent Person Requirements

The employer must designate a competent

person to frequently and regularly inspect

job sites, materials, and equipment to

implement the written exposure control plan.

A competent person is someone who:

■ Can identify existing and foreseeable

respirable crystalline silica hazards;

■ Is authorized to promptly eliminate or

minimize silica hazards; and

■ Has the knowledge and ability to implement

the written exposure control plan.

The employer can designate any of his or her

employees to be a competent person if the

employee is qualiﬁed, including the employee

who does the work on a jobsite. For example,

employees who go to jobsites alone can be

designated a competent person if they know

how to properly implement controls on the

tools they use, can recognize if the controls

are not working, and can correct the non-

working control.

The standard does not require speciﬁc training

for a competent person. The employer is

responsible for determining what training

is necessary to provide the knowledge and

ability for his or her competent person to

implement the written exposure control plan.

The training will depend on the types of

work done, and in some cases, successfully

completing training required under the silica

standard and OSHA’s Hazard Communication

standard will be enough. In other cases,

additional training may be needed. For

example, a competent person at a small

residential construction company might only

need training on controls for power tools that

they do not typically use to do their own tasks,

so that they could help other employees with

questions about or problems with dust controls

on those tools. In contrast, a competent

person for heavy equipment tasks may require

more specialized training in heavy equipment

inspection or in recognizing different soil types

to determine if exposures might be a concern.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

MEDICAL SURVEILLANCE – PARAGRAPH (H)

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.

Which Employees Must be Offered

Medical Surveillance

Employers must make an initial or periodic

medical examination available to employees

who will be required by the silica standard

to wear a respirator for 30 or more days

per year in the upcoming year (the next 365

days). If the employee is required to wear

a respirator at any time during a day, that

counts as one day of respirator use.

An employer will be able to estimate how often

respirator use will be required by the standard

in the upcoming year based on the types of

tasks that the employee will perform, as well

as how long and how often those tasks are

performed. Respirator use with past employers

does not count toward the 30-day threshold.

When unexpected circumstances result in

employees being required to wear respirators

more frequently than ﬁrst expected,

employers must make medical surveillance

available as soon as it becomes apparent that

the employee will be required by the silica

standard to wear a respirator for 30 or more

days in the upcoming year.

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 required

by the silica standard to wear a respirator

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 require respirator use under the silica

standard 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

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

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).

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 FEV

/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.

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

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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 (if the employer does not have

information on the employee’s past or

current exposure level because they are

following Table 1 and are not required to

measure exposures, the employer can

indicate if the employee is likely exposed

at or above the PEL, based on required

respirator use under Table 1);

■ 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 (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.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Sample Form 1: Written Medical Report for Employee

Small Entity Compliance Guide– Construction

Draft – Do not Quote or Cite 9/7/2016

SAMPLE FORM 1: WRITTEN MEDICAL REPORT FOR EMPLOYEE

EMPLOYEE NAME: Joe Smith DATE OF EXAMINATION: June 1, 2017

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, June 1, 2018

Examining Provider: Dr. Jones Date: June 1, 2017

(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)

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

Sample Form 2: Written Medical Opinion for Employer

Small Entity Compliance Guide– Construction

Draft – Do not Quote or Cite 9/7/2016

SAMPLE FORM 2: WRITTEN MEDICAL OPINION FOR EMPLOYER

EMPLOYER: _John Doe Renovations___________________________________________

EMPLOYEE NAME: __Joe Smith_________________ DATE OF EXAMINATION: June 1, 2017________

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, June 1, 2018

Examining Provider: __Dr. Jones____________________________ Date: June 1, 2017

(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)).

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Sample Form 3: Authorization for Crystalline Silica Opinion to Employer

Small Entity Compliance Guide– Construction

Draft – Do not Quote or Cite 9/7/2016

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______________________________ June 1, 2017______________________

Signature Date

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

COMMUNICATION OF HAZARDS – PARAGRAPH (I)

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. If employers are using Table 1, they

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.

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. Examples include

those listed in Table 1, such as using a

stationary masonry saw to cut crystalline

silica-containing materials.

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.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

This training must be speciﬁc for the

task that each employee performs. For

example, employees who operate tools

with built-in controls, such as saws with

integrated water delivery systems, would

need to demonstrate knowledge and

understanding of:

■ The full and proper use of the controls

on those tools; and

■ Signs that controls may not be

functioning properly.

Laborers who do not operate equipment

but are engaged in a task by helping

the tool operator would only need

to demonstrate knowledge and

understanding of:

■ The general types of controls used

in the workplace, such as water or

vacuum controls and how to recognize

if those controls are not working

properly; and

■ Work practices they perform as part

of helping the tool operator, such as

appropriate clean-up of respirable

crystalline silica dust accumulations.

4. The contents of the respirable

crystalline silica standard. This would

involve a description of the standard’s

requirements.

5. The identity of the competent person

designated by the employer. This could

be as simple as announcing who the

competent person is at the beginning of

a work shift.

6. 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 are

required to wear a respirator under

the silica standard 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 physician or

other licensed health care professional;

■ 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 to 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, speciﬁc controls or work practices

that the employer is using, and the identity of

the competent person.

When Employees Must be Trained

Employees must be trained at the time they

are assigned to a position involving exposure

to respirable crystalline silica.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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 (for example, an employer

who was having employees use a

handheld grinder with wet method

controls decides to have employees use

a handheld grinder with a dust collection

system); or

■ When an employee is working in a manner

that suggests he or she has forgotten

what was learned in training.

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.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

RECORDKEEPING – PARAGRAPH (J) 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.

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.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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 (K) OF THE STANDARD

Construction employers must comply

with all requirements of the standard

by September 23, 2017 (delayed from

June 23, 2017), except the requirement to

use laboratories that analyze respirable

crystalline silica samples according to

the procedures in Appendix A, which will

be enforced beginning on June 23, 2018.

That means that as of September 23,

2017, employers must either fully and

properly implement Table 1 requirements

or implement alternative exposure control

measures, and comply with requirements

for respiratory protection, housekeeping,

medical surveillance, hazard communication

and training, and recordkeeping. Prior to

September 23, 2017, the previous PEL (a

formula that is approximately equivalent to

250 μg/m

of respirable crystalline silica as

an 8-hour TWA) remains in effect.

Take steps now to ensure the requirements

can be met by the compliance dates.

1. Implement speciﬁed exposure control

methods in Table 1.

2. Complete exposure assessments needed to

select appropriate engineering controls and

respiratory protection for tasks not in Table 1.

3. Set up respiratory protection programs

where required.

4. Get appropriate equipment, controls,

and respirators.

5. Arrange for medical surveillance.

6. Take actions such as the following to meet

all other requirements:

a. Determine appropriate housekeeping

methods.

b. Prepare a written exposure control plan.

c. Set up a training program.

d. Set up a recordkeeping system.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

APPENDIX I: OSHA RESPIRABLE CRYSTALLINE SILICA

STANDARD FOR CONSTRUCTION

§1926.1153 Respirable crystalline silica.

(a) Scope and application. This section applies

to all occupational exposures to respirable

crystalline silica in construction work, except

where employee exposure will remain below

25 micrograms per cubic meter of air (25 μg/

) as an 8-hour time-weighted average

(TWA) under any foreseeable 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.

Competent person means an individual

who is capable of identifying existing and

foreseeable respirable crystalline silica

hazards in the workplace and who has

authorization to take prompt corrective

measures to eliminate or minimize them.

The competent person must have the

knowledge and ability necessary to fulﬁll the

responsibilities set forth in paragraph (g) of

this section.

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 (h) of this section.

Respirable crystalline silica means quartz,

cristobalite, and/or tridymite contained

in 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 1926.1153.

(1) For each employee engaged in a task

identiﬁed on Table 1, the employer shall fully

and properly implement the engineering

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

controls, work practices, and respiratory

protection speciﬁed for the task in Table 1,

unless the employer assesses and limits

the exposure of the employee to respirable

crystalline silica in accordance with

paragraph (d) of this section.

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(i) Stationary

masonry saws

Use saw equipped with integrated water delivery

system that continuously feeds water to the blade.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize

dust emissions.

None

(ii) Handheld power

saws (any blade

diameter)

Use saw equipped with integrated water delivery

system that continuously feeds water to the blade.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

(iii) Handheld power

saws for cutting

ﬁber-cement board

(with blade diameter

of 8 inches or less)

For tasks performed outdoors only:

Use saw equipped with commercially available

dust collection system.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

Dust collector must provide the air ﬂow

recommended by the tool manufacturer,

or greater, and have a ﬁlter with 99% or

greater efﬁciency.

None None

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(iv) Walk-behind saws Use saw equipped with integrated water delivery

system that continuously feeds water to the blade.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

None

APF 10

(v) Drivable saws For tasks performed outdoors only:

Use saw equipped with integrated water delivery

system that continuously feeds water to the blade.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize

dust emissions.

None None

(vi) Rig-mounted

core saws or drills

Use tool equipped with integrated water delivery

system that supplies water to cutting surface.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

None

(vii) Handheld and

stand-mounted

drills (including

impact and rotary

hammer drills)

Use drill equipped with commercially available

shroud or cowling with dust collection system.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize

dust emissions.

Dust collector must provide the air ﬂow

recommended by the tool manufacturer, or

greater, and have a ﬁlter with 99% or greater

efﬁciency and a ﬁlter-cleaning mechanism.

Use a HEPA-ﬁltered vacuum when cleaning holes.

None None

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(viii) Dowel drilling

rigs for concrete

For tasks performed outdoors only:

Use shroud around drill bit with a dust

collection system. Dust collector must have a

ﬁlter with 99% or greater efﬁciency and a ﬁlter-

cleaning mechanism.

Use a HEPA-ﬁltered vacuum when cleaning holes.

APF 10 APF 10

(ix) Vehicle-mounted

drilling rigs for rock

and concrete

Use dust collection system with close capture

hood or shroud around drill bit with a low-ﬂow

water spray to wet the dust at the discharge point

from the dust collector.

Operate from within an enclosed cab and use

water for dust suppression on drill bit.

None

(x) Jackhammers and

handheld powered

chipping tools

Use tool with water delivery system that supplies

a continuous stream or spray of water at the point

of impact.

• When used outdoors.

• When used indoors or in an enclosed area.

Use tool equipped with commercially available

shroud and dust collection system.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

Dust collector must provide the air ﬂow

recommended by the tool manufacturer, or

greater, and have a ﬁlter with 99% or greater

efﬁciency and a ﬁlter-cleaning mechanism.

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

None

APF 10

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xi) Handheld

grinders for mortar

removal (i.e.,

tuckpointing)

Use grinder equipped with commercially available

shroud and dust collection system.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

Dust collector must provide 25 cubic feet per

minute (cfm) or greater of airﬂow per inch of

wheel diameter and have a ﬁlter with 99% or

greater efﬁciency and a cyclonic pre-separator

or ﬁlter-cleaning mechanism.

APF 10 APF 25

(xii) Handheld

grinders for uses

other than mortar

removal

For tasks performed outdoors only:

Use grinder equipped with integrated water

delivery system that continuously feeds water

to the grinding surface.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

Use grinder equipped with commercially available

shroud and dust collection system.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

Dust collector must provide 25 cubic feet per

minute (cfm) or greater of airﬂow per inch of

wheel diameter and have a ﬁlter with 99% or

greater efﬁciency and a cyclonic pre-separator or

ﬁlter-cleaning mechanism.

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xiii) Walk-behind

milling machines and

ﬂoor grinders

Use machine equipped with integrated water

delivery system that continuously feeds water to

the cutting surface.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize

dust emissions.

Use machine equipped with dust collection

system recommended by the manufacturer.

Operate and maintain tool in accordance

with manufacturer’s instructions to minimize dust

emissions.

Dust collector must provide the air ﬂow

recommended by the manufacturer, or greater,

and have a ﬁlter with 99% or greater efﬁciency

and a ﬁlter-cleaning mechanism.

When used indoors or in an enclosed area, use

a HEPA-ﬁltered vacuum to remove loose dust in

between passes.

None

(xiv) Small drivable

milling machines

(less than half-lane)

Use a machine equipped with supplemental water

sprays designed to suppress dust. Water must be

combined with a surfactant.

Operate and maintain machine to minimize

dust emissions.

None None

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xv) Large drivable

milling machines

(half-lane and larger)

For cuts of any depth on asphalt only:

Use machine equipped with exhaust ventilation

on drum enclosure and supplemental water

sprays designed to suppress dust.

Operate and maintain machine to minimize

dust emissions.

For cuts of four inches in depth or less on

any substrate:

Use machine equipped with exhaust ventilation

on drum enclosure and supplemental water

sprays designed to suppress dust.

Operate and maintain machine to minimize

dust emissions.

Use a machine equipped with supplemental water

spray designed to suppress dust. Water must be

combined with a surfactant.

Operate and maintain machine to minimize dust

emissions.

None

(xvi) Crushing

machines

Use equipment designed to deliver water spray

or mist for dust suppression at crusher and other

points where dust is generated (e.g., hoppers,

conveyers, sieves/sizing or vibrating components,

and discharge points).

Operate and maintain machine in accordance

with manufacturer’s instructions to minimize dust

emissions.

Use a ventilated booth that provides fresh,

climate-controlled air to the operator, or a remote

control station.

None None

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Speciﬁed Exposure Control Methods When

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice

Control Methods

Required Respiratory Protection

and Minimum Assigned

Protection Factor (APF)

≤ 4 hours/shift > 4 hours/shift

(xvii) Heavy

equipment and

utility vehicles

used to abrade

or fracture silica-

containing materials

(e.g., hoe-ramming,

rock ripping) or used

during demolition

activities involving

silica-containing

materials

Operate equipment from within an enclosed cab.

When employees outside of the cab are engaged

in the task, apply water and/or dust suppressants

as necessary to minimize dust emissions.

None

(xviii) Heavy

equipment and utility

vehicles for tasks

such as grading

and excavating

but not including:

demolishing,

abrading, or

fracturing silica-

containing materials

Apply water and/or dust suppressants as

necessary to minimize dust emissions.

When the equipment operator is the only

employee engaged in the task, operate equipment

from within an enclosed cab.

None

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

(2) When implementing the control measures

speciﬁed in Table 1, each employer shall:

(i) For tasks performed indoors or in enclosed

areas, provide a means of exhaust as needed

to minimize the accumulation of visible

airborne dust;

(ii) For tasks performed using wet methods,

apply water at ﬂow rates sufﬁcient to

minimize release of visible dust;

(iii) For measures implemented that include

an enclosed cab or booth, ensure that the

enclosed cab or booth:

(A) Is maintained as free as practicable from

settled dust;

(B) Has door seals and closing mechanisms

that work properly;

condition and working properly;

(D) Is under positive pressure maintained

through continuous delivery of fresh air;

(E) Has intake air that is ﬁltered through a

ﬁlter that is 95% efﬁcient in the 0.3-10.0 μm

range (e.g., MERV-16 or better); and

(F) Has heating and cooling capabilities.

(3) Where an employee performs more

than one task on Table 1 during the course

of a shift, and the total duration of all tasks

combined is more than four hours, the

required respiratory protection for each task

is the respiratory protection speciﬁed for

more than four hours per shift. If the total

duration of all tasks on Table 1 combined is

less than four hours, the required respiratory

protection for each task is the respiratory

protection speciﬁed for less than four hours

per shift.

(d) Alternative exposure control methods.

For tasks not listed in Table 1, or where

the employer does not fully and properly

implement the engineering controls, work

practices, and respiratory protection

described in Table 1:

(1) Permissible exposure limit (PEL). The

employer shall ensure that no employee

is exposed to an airborne concentration of

respirable crystalline silica in excess of 50 μg/

, calculated as an 8-hour TWA.

(2) Exposure assessment—(i) 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)(ii) or the scheduled

monitoring option in paragraph (d)(2)(iii) of

this section.

(ii) 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.

(iii) Scheduled monitoring option. (A) 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.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(B) 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.

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.

(D) 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.

(E) 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

seven 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)(2)(iv) of this section.

(iv) 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.

(v) Methods of sample analysis. The employer

shall ensure that all samples taken to satisfy

the monitoring requirements of paragraph (d)

(2) 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.

(vi) Employee notiﬁcation of assessment

results. (A) Within ﬁve working days after

completing an exposure assessment in

accordance with paragraph (d)(2) 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.

(B) 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.

(vii) Observation of monitoring. (A) 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.

(B) 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.

(3) Methods of compliance—(i) 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 (e) of this section.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

(ii) Abrasive blasting. In addition to the

requirements of paragraph (d)(3)(i) of this

section, the employer shall comply with other

OSHA standards, when applicable, such as

29 CFR 1926.57 (Ventilation), where abrasive

blasting is conducted using crystalline silica-

containing blasting agents, or where abrasive

blasting is conducted on substrates that

contain crystalline silica.

(e) 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 speciﬁed by Table 1 of paragraph (c)

of this section; or

(ii) For tasks not listed in Table 1, or where

the employer does not fully and properly

implement the engineering controls, work

practices, and respiratory protection

described in Table 1:

(A) Where exposures exceed the PEL during

periods necessary to install or implement

feasible engineering and work practice

controls;

(B) Where exposures exceed the PEL during

tasks, such as certain maintenance and

repair tasks, for which engineering and work

practice controls are not feasible; and

implemented all feasible engineering and

work practice controls and such controls

are not sufﬁcient to reduce exposures to or

below the PEL.

(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.

(3) Speciﬁed exposure control methods.

For the tasks listed in Table 1 in paragraph

and properly implements the engineering

controls, work practices, and respiratory

protection described in Table 1, the employer

shall be considered to be in compliance

with paragraph (e)(1) of this section and the

requirements for selection of respirators in 29

CFR 1910.134(d)(1)(iii) and (d)(3) with regard to

exposure to respirable crystalline silica.

(f) 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.

(g) Written exposure control plan. (1) The

employer shall establish and implement a

written exposure control plan that contains at

least the following elements:

(i) A description of the tasks in the workplace

that involve exposure to respirable crystalline

silica;

(ii) A description of the engineering controls,

work practices, and respiratory protection

used to limit employee exposure to respirable

crystalline silica for each task;

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(iii) A description of the housekeeping

measures used to limit employee exposure to

respirable crystalline silica; and

(iv) A description of the procedures used

to restrict access to work areas, when

necessary, to minimize the number of

employees exposed to respirable crystalline

silica and their level of exposure, including

exposures generated by other employers or

sole proprietors.

(2) The employer shall review and evaluate

the effectiveness of the written exposure

control plan at least annually and update it as

necessary.

(3) 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.

(4) The employer shall designate a

competent person to make frequent and

regular inspections of job sites, materials,

and equipment to implement the written

exposure control plan.

(h) 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 required under this

section to use a respirator for 30 or more

days per year.

(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 (FEV

) and

FEV

/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

(h)(2) of this section (except paragraph (h)

(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:

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

(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;

(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 (h)(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 (h)(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 (h)

(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 (h)(4) of this section.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(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 (h)(5) (except

paragraph (h)(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 (h)

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

this section.

(i) 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 (i)(2) of this

section. The employer shall ensure that at

least the following hazards are addressed:

Cancer, lung effects, immune system effects,

and kidney effects.

(2) 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;

(E) The identity of the competent person

designated by the employer in accordance

with paragraph (g)(4) of this section; and

(F) The purpose and a description of the

medical surveillance program required by

paragraph (h) of this section.

(ii) The employer shall make a copy of this

section readily available without cost to each

employee covered by this section.

(j) 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)(2) 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.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

(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.

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

make and maintain an accurate record for each

employee covered by medical surveillance

under paragraph (h) 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.

(k) Dates. (1) This section shall become

effective June 23, 2016.

(2) All obligations of this section, except

requirements for methods of sample analysis

in paragraph (d)(2)(v), shall commence

June 23, 2017.

(3) Requirements for methods of sample

analysis in paragraph (d)(2)(v) of this section

commence June 23, 2018.

Appendix A to § 1926.1153 – 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

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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:

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 § 1926.1153 – 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

(SiO

). 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).

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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

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.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

1.3.3. Spirometry - restrictive or mixed

restrictive/obstructive pattern.

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

lupus erythematosus, and rheumatoid

arthritis. Studies note an association between

employees with silicosis and serologic

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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

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

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(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;

(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

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

(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 (FEV

), and FEV

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

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).

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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

helpful to employees, such as construction

employees, who may change employers

frequently. The written medical opinion can

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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.

3.2.6. After evaluating the employee, the

Board Certiﬁed Specialist in Pulmonary

Disease or Occupational Medicine

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

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

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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

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

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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

OSHA’s Safety and Health Topics webpage

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

dsg/topics/silicacrystalline

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

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.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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

technical standards: spirometry in the

occupational setting. Am J Respir Crit Care

Med; 189, 984-994.

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

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117

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)

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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118

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)).

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119

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

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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.

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 ADMINISTRATION

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 kTake s,

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 sign up

visit

www. osha.gov/quicktakes.

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

SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION

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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