SILICA STANDARD
“...companies are now required to keep records and
provide a medical examination every three years...”
maintains the equipment and ensures
that employees use it as directed by the
manufacturer—employers do not have
to provide objective data or conduct air
monitoring. This is the easiest way for
contractors to comply with the standard.
MEDICAL SURVEILLANCE
BMB has also received numerous
questions from our clients about the
requirements of Medical Surveillance.
The short answer to most of these
questions is that companies are now
required to keep records and provide a
medical examination every three years
for employees who are exposed to silica
and for employees who wear respirators
for at least thirty days a year.
The medical exam must be conducted
by a Physician or Other Licensed Health
Care Professional (PLHCP) and include
the following:
• a medical and work history;
• a physical exam with “special
emphasis on the respiratory system;”
• a chest X-ray interpreted by a
NIOSH-certified B Reader;
• a pulmonary function test
administered by a spirometry
technician with a current certificate
from a NIOSH-approved spirometry
course;
• a test for latent tuberculosis (only for
the initial test); and
• any “other tests deemed appropriate
by the PLHCP.”
This medical opinion only describes
limitations on respirator use. Any
additional information such as
limitations on exposure to respirable
crystalline silica or a referral to be seen
by a specialist can only be given if the
worker provides written consent.
RESPIRATORS
Which type of respirator do I offer to my
employees? is another question that a
lot of employers are asking. The answer,
of course, depends on the amount of
exposure in quantity and time. OSHA
rates respirators based on an Assigned
Protection Factor (APF), which means the
workplace level of respiratory protection
that a respirator or class of respirators
is expected to provide to employees.
According to Table 1, the type of required
respirator can vary from APF5 to APF25.
Using the APF chart below can assist you
in determining which type of respirator
to use.
CONCLUSION
Currently, the new standard only effects
the Construction Industry, but deadlines
for General Industry, Oil and Gas, and
Maritime are approaching. General
Industry and Maritime employers must
comply with all requirements of the
standard by June 23, 2018. Hydraulic
fracturing operations in the oil and gas
industry must implement engineering
controls to limit exposures to the new
PEL by June 23, 2021.
Sometimes just trying to decode an
abbreviation or acronym associated
with OSHA’s standards may leave you
even more confused. You can find
this information as well as additional
resources at www.osha.gov/silica.
If you need assistance with complying
with the new silica standard or have
additional questions regarding the
new standard, please give the Risk
Management Department at BMB a call
at (713) 867-5350 or (713) 867-5306.
Our staff is trained and ready to assist
you. +
Jeff Russell, J.D – CRM is the Corporate
Legal Consultant & Director of Loss
Control/Training Services at Bowen,
Miclette & Britt Insurance Agency, LLC
TABLE 1
The construction standard’s PLHCP
reporting requirements differ from other
health standards. The new silica dust
standard requires the PLHCP:
1. provide the employee with a detailed
written medical report within 30 days of
the exam; and
2. provide the employer with a more
limited written medical opinion.
31