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THE GALSON BLOG

 

After many years in the making, OSHA announced today its highly anticipated but also controversial final Silica rule. This new rule brings worker health protection against silicosis and other silica-related diseases into the 21st century by replacing its 45 year old outdated permissible exposure limit (PEL).  Long time coming – but congratulations to OSHA for its hard work in pushing this into law.

Here at SGS Galson, we welcome the new rule and are ready to serve and assist our clients in coming into compliance with the new rule. We have anticipated and prepared for this new rule and are ready to serve you. We currently meet all the new laboratory qualifications and are ready to help.

There are many new provisions to the standard that will impact the Industry and could affect 2.3 million workers of which 2 million work in construction.  The new rule is actually two new standards. One for General Industry and Maritime, and the other for Construction.  Although there are two separate standards, there is a great deal of overlap in the requirements.

The highlights for each new standard:

Construction

  • Small-business employers can use specified dust control methods in lieu of sampling
  • Must have a written exposure plan
  • Defined housekeeping practices
  • Offer medical exams
  • Train workers
  • Keep records
  • New PEL (8 hour TWA) is 50 ug/m3 of crystalline silica (all 3 polymorphs)
  • New action level is 25 ug/m3
  • Timeline for implementation – employers have until June 23, 2017 –except for laboratory qualifications


Laboratory Qualifications:

  1. Implemented by June 23, 2018
  2. 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-3
  3. 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
  4. Uses the most current National Institute of Standards and Technology (NIST) or NIST traceable standards for instrument calibration or instrument calibration verification
  5. Implements an internal quality control (QC) program that evaluates analytical uncertainty and provides employers with estimates of sampling and analytical error
  6. 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
  7. 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:
  8. Each day that samples are analyzed, performs instrument calibration checks with standards that bracket the sample concentrations;
  9. 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
  10. 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.

General Industry and Maritime

  • Time line to comply – June 23, 2018 – exception – Hydraulic Fracking operations – June 23, 2021
  • Must have a written exposure plan
  • Defined housekeeping practices
  • Offer medical exams
  • Train workers
  • Record keeping
  • Written exposure plan
  • New PEL (8 hour TWA) is 50 ug/m3 of crystalline silica (all 3 polymorphs)
  • New action level is 25 ug/m3
  • Same laboratory qualifications and timeframe as in the Construction standard

The whole standard can be found here – https://www.federalregister.gov/articles/2016/03/25/2016-04800/occupational-exposure-to-respirable-crystalline-silica.   Happy reading – it is over 1700 pages long.

Before you have silica samples analyzed by your lab – be sure to ask them if they can comply with the new requirements.  Better yet, if you are not currently using SGS Galson as your IH lab, give us a call or send us an email and let us show you what we can do for you.  Free pumps, free media, 5 day guaranteed turnaround time, and much more.



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