Crystalline Silica

It shall be the policy of ESCO Group to implement the various requirements of the respirable crystalline silica protection regulation as required by the U.S. Department of Labor, Occupational Safety and Health Administration. 

It shall be the policy of ESCO Group to fulfill its obligations under 29 CFR OSHA 1926.1153 to implement a hazard and accident prevention program which addresses all of the hazards present to the workplace applicable to this standard. ESCO Group is committed to an effective respirable crystalline silica protection program. 

1. Scope and Application

a) ESCO Group has conducted applicable air monitoring and sampling in accordance to the American Conference of Governmental Industrial Hygienists (ACGIH) for respirable crystalline silica.  Air monitoring and sampling have yielded results less than the mandated Action Level (AL) 25 μg/m3 in an 8-hour time-weighted average (TWA).  ESCO Group does not meet the minimum requirements required to be subject to the 29 CFR OSHA 1926.1153 standard per 1926.1153(a) and is therefore not required to follow the standard any further.  This policy and herein is strictly for awareness purposes.

b) ESCO Group’s respirable crystalline silica protection program applies to all construction work where an employee may be occupationally exposed to respirable crystalline silica hazards. All work related to construction, alteration, or repair is included. Under our plan, construction includes but is not limited to the following:

i. Demolition or salvage of structures

ii. Removal or encapsulation of materials 

iii. New construction, alteration, repair, or renovation of structures or substrates 

iv. Maintenance operations associated with construction activities described above

2. General Requirements 

a) ESCO Group shall be responsible for the respirable crystalline silica protection program to be followed throughout all phases of construction and will provide the safety equipment as required.

b) If and when required, ESCO Group will provide access to all available respirable crystalline silica protection and prevention equipment and shall maintain equipment as per the appropriate standard. 

c) All respirable crystalline silica protection equipment provided by ESCO Group shall be conspicuously located. 

d) All respirable crystalline silica protection equipment shall be periodically inspected and maintained in operating condition. Defective equipment shall be immediately replaced. 

3. Action Level (AL)

a) ESCO Group shall ensure that no employee is exposed to an airborne concentration of respirable crystalline silica of 25 μg/m3 or more in an 8-hour time-weighted average (TWA). 

b) ESCO Group shall comply with Specified Exposure Control Methods: 1926.1153(c)(1) Table 1 or 1926.1153(d) Alternative Exposure Control Methods if the Action Levels are met or exceeded.

4. Permissible Exposure Limits (PEL)

a) ESCO Group shall ensure that no employee is exposed to an airborne concentration of respirable crystalline silica of 50 μg/m3 or more in an 8-hour time-weighted average (TWA). 

b) ESCO Group shall comply with Specified Exposure Control Methods: 1926.1153(c)(1) Table 1 or 1926.1153(d) Alternative Exposure Control Methods if the Permissible Exposure Limits are met or exceeded.

c) ESCO Group shall comply with respiratory protection requirements from 1926.1153(c)(1) Table 1 when Permissible Exposure Limits are met or exceeded based upon the Required respiratory protection and minimum assigned protection factor (APF) from Table 1. 

5. Monitoring

a) ESCO Group shall perform monitoring in accordance to the standard, 1926.1153(d)- 1926.1153(d)(2)(vii)(B) when Alternate Exposure Control Methods are utilized. 

b) ESCO Group has conducted applicable air monitoring and sampling in accordance to the American Conference of Governmental Industrial Hygienists (ACGIH) for respirable crystalline silica.  Air monitoring and sampling have yielded results less than mandated Action Level (AL) 25 μg/m3 in an 8-hour time-weighted average (TWA).  ESCO Group does not meet the minimum requirements required to be subject to the 29 CFR OSHA 1926.1153 standard per 1926.1153(a) and is therefore not required to follow the standard any further.  This policy and herein is strictly for awareness purposes. 

6. Control Methods 

a) Engineering and work practice controls shall be used by ESCO Group to reduce and maintain employee exposure at or below the TWA Action Level.  ESCO Group will supplement these controls by the use of respiratory protection when Permissible Exposure Limits are met and in accordance to Table 1. 

7. Respiratory Protection 

a) ESCO Group shall furnish and monitor use of respirators per 29 CFR OSHA 1910.134 in the following circumstances: 

i. Where required by 29 CFR OSHA 1926.1153.

ii. Where specified by Table 1 of 1926.1153(c).

iii. For tasks not listed in Table 1; or where: engineering controls are not fully and properly implemented, work practices, and respiratory protection described in Table 1.

iv. Where exposures exceed the PEL during periods necessary to install or implement feasible engineering and work practice controls.

v. Where exposures exceed the PEL during tasks, such as certain maintenance and repair tasks, for which engineering and work practice controls are not feasible. 

vi. During tasks for which an employer has implemented all feasible engineering and work practice controls and such controls are not sufficient to reduce exposures to or below the PEL.

8. Housekeeping 

a) Employees shall not use compressed air, dry sweep or dry brush materials that could disturb respirable crystalline silica, such actions shall be completed with wet sweeping, HEPA-filtered vacuuming or methods that minimize the likelihood of exposure are not feasible. 

9. Exposure Control Plan

a) ESCO Group does not meet the requirements of the standard to maintain the obligatory exposure control plan set forth by 29 CFR OSHA 1926.1153(g).  Below are voluntary requirements ESCO Group has implemented to provide additional safeguarding of their employees for exposure prevention to respirable crystalline silica.  ESCO Group satisfies the exemption requirements set forth by 29 CFR OSHA 1926.1153(a) and does not meet or exceed the designated Action Level of 25 μg/m3  for respirable crystalline silica.

b) Employees shall immediately vacate the work area when others create an exposure to respirable crystalline silica.  Tasks that may require ESCO Group employees to vacate the work area may include, but are not limited to:

i. Concrete/masonry demolition: removal of walls, floors, ceilings, structural supports, etc. 

ii. Concrete resurfacing projects.  Schedule coordination must be in place with contractors to allow adequate project time to vacate the area when such work is taking place. 

iii. Concrete sawing: panel division, block cutting, demolition, etc.

iv. Housekeeping or sweeping that involves dry process for removal of concrete dust or other material that contains respirable crystalline silica. 

c) Use of rotary hammer drill for anchor setting or wall/floor penetrations requires the use of factory designed vacuum, cup or watering system. 

d) Core drilling applications requires the use of water tank and appropriate drill chuck supply valves and fittings per drill design. 

e) Mixing of concrete or masonry patch requires a well ventilated area and adequate water for mixing process. 

10. Medical Surveillance

a) ESCO Group does not meet the requirements of the standard to provide the obligatory medical surveillance plan set forth by 29 CFR OSHA 1926.1153(h).  

11. Employee Training 

a) ESCO Group will utilize an employee awareness training to educate and maintain a safe work environment to prevent employee exposure to respirable crystalline silica.  ESCO Group has conducted task specific air monitoring and does not meet the action level enforcement requirements of this standard, however; ESCO Group will maintain an annual review of their crystalline silica standard with all applicable employees.  The ESCO Group safety director will review and monitor the workplace for changes to the tasks and exposure to respirable crystalline silica.  The annual awareness review will be directed by the ESCO Group safety director and will contain the following information: 

i. Health hazards related to exposure to respirable crystalline silica. 

ii. List of tasks that may lead to these health hazards: 

1. Concrete/masonry demolition: removal of walls, floors, ceilings, structural supports, etc. 

2. Concrete resurfacing projects.  Schedule coordination must be in place with contractors to allow adequate project time to vacate the area when such work is taking place. 

3. Concrete sawing: panel division, block cutting, demolition, etc.   

4. Housekeeping or sweeping that involves dry process for removal of concrete dust or other material that contains respirable crystalline silica. 

5. Use of rotary hammer drill for anchor setting or wall/floor penetrations requires the use of factory designed vacuum, cup or watering system. 

6. Core drilling applications requires the use of water tank and appropriate drill chuck supply valves and fittings per drill design. 

7. Mixing of concrete or masonry patch requires a well ventilated area and adequate water for mixing process.