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Respirable Silica - Are You Ready for the New Rules?

As of September 23, 2017, contractors must be in compliance with the new OHSA regulation that greatly reduces the amount of silica dust a worker can be subjected to during an eight-hour work day. However, OSHA enforcement officers are holding off on issuing citations for 30 days IF the contractor is showing a good-faith effort to limit exposure, even though it might not be within the allowable exposure limits. If the contractor has completely ignored the rule, citations will be issued.

There are numerous ways that citations can be written in relation to this rule. First, the most obvious citation is the cutting, grinding, chipping, sanding, breaking-up, etc. of any product that contains silica without preventing the worker from inhaling dust created by these actions. If the worker can be kept from inhaling dust that does not reach the concentration of 50 micrograms/cubic meter in an eight-hour work day, then the worker is in compliance. However, this leaves us with the question of whether or not that exposure level has been reached.

OSHA's "Table 1" in the rules describes if or how a worker must be protected from inhaling silica dust when performing various activities. Any activity outside Table 1 must be presumed to expose a worker above the permissible exposure limit (PEL) until testing is done to determine that it does not.

Other areas in the rules from which citations can be written include employee training on the hazards of inhaling silica dust and where those hazards could be encountered in the workplace, as well as how to avoid and protect themselves from exposure. An employer must prepare a written "exposure control plan" that details all of this. The employer also must keep records of testing results of the exposures and of medical records pertaining to those workers who will be wearing respirators, which limit the amount of dust inhaled, for 30 or more days per year.

If your company has not prepared to limit the amount of silica dust your employees may inhale, you should immediately contact one of our safety professionals or OSHA Consultation to avoid any citations due to lack of compliance.
BEST PRACTICE
Electronic Submission of Injury/Illness Records

This summer, OSHA extended its requirement for employers to electronically submit their 2016 300A form until December 1st, 2017. This is the summary of injuries and illnesses of the previous calendar year that must be posted on job sites from February 1 through April 30 each year. Even though this requirement is being phased in for all employers across the country, the construction industry has historically high rates of occupational injuries and illnesses, resulting in an earlier compliance date than other industries.  
 
In August, OSHA implemented a secure website for this data submission. If you would like additional information about this recordkeeping rule or help with compliance, please contact one of our safety professionals
IOWA OSHA PERSPECTIVE
Plan Your Training Now for the Winter Months

The winter months are the best time to get your employees caught up or refreshed on their training needs. OSHA publishes a document of training that employees must have, and we are able to provide Training-on-Demand to help you meet these needs. For more information and to schedule training, please contact one of our safety professionals today!
ProfessionalsSafety Professionals
Brandon Black - (515) 577-5198 or [email protected] 
Troy Porter - (515) 681-5252 or [email protected]
Tom Suckow - (515) 250-0773 or [email protected]
New WORKSAFE Projects

PROJECT:
LLPFP MRI Accelerator Installation / LLPFP Gamma Knife Installation Vault D
CONTRACTOR:

McComas-Lacina Construction Co. LC - Iowa City, IA

PROJECT:
ISU Parks Library - Reroof 2017
CONTRACTOR:

Central States Roofing - Ames, IA

PROJECT:
UIHC Bone and Leukemia Relocation
CONTRACTOR:

Miron Construction Co., Inc. - Cedar Rapids, IA

PROJECT:
The Preserve at North Dakota
CONTRACTOR:

JCorp, Inc. - Huxley, IA

PROJECT:
Hancher Foot Bridge
CONTRACTOR:

Kraemer North America, LLC

PROJECT:
Tobacco Outlet Plus Grocery #519
CONTRACTOR:

Dean Snyder Construction - Ankeny, IA

PROJECT:
Coralville IRL - Drury Ramp
CONTRACTOR:

Knutson Construction Services, Inc. - Iowa City, IA

PROJECT:
East Buchanan School
CONTRACTOR:

Larson Construction Inc. - Independence, IA

PROJECT:
The Views
CONTRACTOR:

Larson Construction Inc. - Independence, IA

PROJECT:
Mid American Energy Company Fort Dodge Service Center
CONTRACTOR:

Woodruff Construction, LLC - Fort Dodge, IA

PROJECT:
Kalona Community Center Addition and Renovation
CONTRACTOR:

Carl A. Nelson & Company - Burlington, IA

PROJECT:
Grand Crossing Phase 2
CONTRACTOR:

Grand Investments, LLC - Cedar Falls, IA

PROJECT:
Coralville #2 Hy-Vee
CONTRACTOR:

Hy-Vee Construction, LC - Des Moines, IA


WORKSAFE is a partnership between Master Builders of Iowa and Iowa OSHA, with safety services provided by Construction Safety Specialists, Inc.

For more information on the WORKSAFE program or for safety inquiries, please contact Tom Suckow at 515-657-4384 or [email protected]
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