OSHA Launches New Silica Enforcement Initiative
OSHA is stepping up enforcement of health and safety standards for respirable crystalline silica (RCS) exposure in the stone cutting, fabrication, and installation industries. An inspection initiative announced last month will target workplaces categorized in NAICS 327991 and NAICS 423320 in most US states.
OSHA has directed each regional office to inspect at least five workplaces covered by the new initiative, with more inspections likely in areas with a high concentration of covered sites. The existing OSHA National Emphasis Program (NEP) on respirable crystalline silica took effect in February 2020 and covers dozens of general industry and construction industry sectors.
Targeted OSHA RCS Inspections
OSHA's new RCS enforcement initiative seeks to enhance enforcement and compliance assistance efforts in the stone fabrication industry by covering RCS hazards during every inspection performed at facilities in covered industries.
Workplaces likely to be selected for inspection are those where employees manufacture, finish, cut, grind, chip, sand, drill, or polish stone and stone products, install finished products off-site, or handle silica by opening bags, moving or mixing materials, cleaning or scraping mixers, or changing or handling dust filters/bag houses.
Facilities covered by the NEP launched in 2020 will be inspected even if they do not meet of the inspection targeting criteria for the new enhanced RCS enforcement effort.
RCS-Related OSHA Standards & Regulations
In the memo announcing the RCS enforcement plan, OSHA provides a list of general industry (Part 1910) and construction industry (Part 1926) regulations that apply to silica dust.OSHA standards that may be applicable to work involving RCS include, but are not limited to:
- 29 CFR § 1910.1053, Respirable Crystalline Silica.
- 29 CFR § 1926.1153, Respirable Crystalline Silica (Construction)
- 29 CFR § 1910.94, Ventilation
- 29 CFR § 1926.57, Ventilation
- 29 CFR § 1910.95, Occupational noise exposure
- 29 CFR § 1910.132, General Requirements-Personal Protective Equipment.
- 29 CFR § 1910.134, Respiratory Protection.
- 29 CFR § 1910.1020, Access to Employee Exposure and Medical Records.
- 29 CFR § 1910.1200, Hazard Communication.
- 29 CFR Part 1904, Recording and Reporting Occupational Injuries and Illness.
The memo also says this about targeted RCS inspections:
“In addition to the hazards associated with RCS, and hazards that may be the subject of the programmed or unprogrammed inspection, other hazards (e.g., crushing hazards from unsecured slabs, guarding of grinders, exposure to resins, adhesives and pigments) that may be encountered in engineered stone fabrication and installation include but are not limited to occupational noise; hazardous chemicals; fall hazards; and lockout/tagout hazards…
when such additional hazards come to the attention of the compliance officer, where plain-view hazards are identified during the walkaround, or where information obtained from workers or worker representative(s) indicated deficiencies in compliance, the scope of the inspection may be expanded to include those hazards.”
OSHA Memo. Respirable Crystalline Silica Focused Inspection Initiative in the Engineered Stone Fabrication and Installation Industries. 9/22/23.
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