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SILICA (RCS) DUST LIMIT – THE ONLY WAY IS DOWN?

US regulator cuts RCS exposure standard to half UK limit

The US Occupational Safety and Health Administration (OSHA) has issued what it describes as “a final rule to curb lung cancer, silicosis, chronic obstructive pulmonary disease and kidney disease in America’s workers by limiting their exposure to respirable crystalline silica (RCS)”.

The rule is comprised of two standards, one for Construction and one for General Industry and Maritime.

OSHA estimates that the rule will save over 600 lives and prevent more than 900 new cases of silicosis each year, once its effects are fully realised. The Final Rule is projected to provide net benefits of about $7.7 billion, annually.

In the US some 2.3 million workers are exposed to RCS in the workplace, including 2 million construction workers who drill, cut, crush, or grind silica-containing materials such as concrete and stone.

In addition, there are 300,000 workers in general industry operations such as brick manufacturing, foundries, and hydraulic fracturing, also known as fracking.

Key Provisions

The OSHA changes include:

  • Exposure Limit Reduced – the permissible exposure limit for respirable crystalline silica is reduced to 0.05 mg per cubic metre of air, averaged over an 8-hour shift.

This new US limit is half the UK limit set at 0.1 mg per cubic metre.

  • Comprehensive Control Measures – where RCS cannot be eliminated a suite of control measures are required including: water or ventilation systems to limit worker exposure; RPE when engineering controls cannot adequately limit exposure; limited worker access to high exposure areas; written exposure control plans, medical examinations and worker training.
Comment

This new US limit has been planned for a number of years. The change comes at a time when the Health and Safety Executive has placed RCS at the centre of its Construction Sector Priorities.

The reduced US exposure limit is likely to increase pressure to reduce the RCS exposure limit in the UK.

Meanwhile, clients, designers and contractors in the UK would be advised to concentrate fully on eliminating, reducing or controlling exposure to RCS on all construction projects.

 

OSHA has provided the following background information:

“The U.S. Department of Labor first highlighted the hazards of respirable crystalline silica in the 1930s, after a wave of worker deaths.

The department set standards to limit worker exposure in 1971, when OSHA was created. However, the standards are outdated and do not adequately protect workers from silica-related diseases. Furthermore, workers are being exposed to silica in new industries such as stone or artificial stone countertop fabrication and hydraulic fracturing.

A full review of scientific evidence, industry consensus standards, and extensive stakeholder input provide the basis for the final rule, which was proposed in September 2013. The rule-making process allowed OSHA to solicit input in various forms for nearly a full year.

The agency held 14 days of public hearings, during which more than 200 stakeholders presented testimony, and accepted over 2,000 comments, amounting to about 34,000 pages of material. In response to this extensive public engagement, OSHA made substantial changes, including enhanced employer flexibility in choosing how to reduce levels of respirable crystalline silica, while maintaining or improving worker protection.”

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