OSHA’S FINAL RULE ON CRYSTALLINE SILICA EXPOSURE
In effect since September 23, 2017, OSHA’s respirable crystalline silica rule is a comprehensive health standard that can greatly impact the way mason contractors do business and keep records on their employees. It significantly reduces the Permissible Exposure Limit (“PEL”) for crystalline silica and requires construction employers to implement engineering and work practice controls and follow several other additional provisions, such as medical surveillance, a written exposure control plan, and housekeeping practices.
The standard sets a PEL of 50 μg/m3 (from the previous PEL of approximately 250 μg/m3) measured as an eight-hour time- weighted average (“TWA”). If workers are exposed to crystalline silica above the new PEL, employers must implement engineering controls to reduce exposures to below that level, before using respiratory protection. In other words, if workers are exposed above the PEL, employers must investigate and implement engineering solutions (such as wet methods, vacuums, shrouds, enclosures, or cabs) to reach levels below the PEL. Employers are not permitted to rely on respiratory protection to protect employees.
In addition to compliance with the PEL, under the rule all construction employers must have a written exposure control plan, that identifies the tasks that can result in silica exposure, the engineering controls, work practices, and respiratory protection that will be used to protect workers, and the procedures to restrict access to work areas where high exposures may occur.
Recent advances in vacuum and tool technology are designed to help contractors address the silica issue without making drastic changes on the job site.
INNOVATION AS SOLUTIONS
The healthiest air in a world of invisible, odorless, tasteless gases recycled an infinite number of times over, is the air that has been treated by the highest quality tools of the industry which have been tested and perfected to be in compliance of OSHA’s standard.
Companies such as Bosch Power Tools and Husqvarna Construction Products have taken steps to meet the new code requirements. Bosch features a PRO+GUARD system, which offers the industry’s largest dust solution lineup. Director of Bosch North America, Jim Bohn, who manages Strategic Development, works closely with functional areas to encourage innovative thought processes and new products. He tells us that the new system includes solutions for drilling and anchoring, chiseling and demolition, grinding, and masonry tuckpointing.
The line’s products also include hammers, grinders, dust extractors, and attachments and accessories to help protect not just the user, but everyone on the jobsite. Bohn believes that Bosch PRO+GUARD dust solutions allow construction professionals to have increased safety, compliance and productivity.
Aside from the PRO+GUARD line, the Bosch VAC series dust extractors have been another recent and thriving innovation. Bohn claims, “They come with [a] combination of air flow and suction power, which makes these units ideal for dust extraction.” With a plethora of benefits and high reviews from pros, the Bosch VAC090AH and VAC140AH are capable of both wet and dry pick up.
“When paired with a HEPA filter and fleece bag, these units are able to meet the necessary factors for HEPA compliancy standards. The automatic filter cleaning system cleans the filter every 15 seconds, ensuring the dust extractor is always working at maximum efficiency. Power tool activation reduces the need for a second extension cord. The tool can be plugged directly into the dust extractor. Heavy duty wheels, a locking castor, a metal frame, and L-BOXX compatibility make this more than just a typical dust extractor.”
While Bosch has not had to frantically respond to the OSHA regulation, Bohn says the company will only continue to make user’s jobs easier and more comfortable. Their dust solutions have not just been to limit respirable crystalline silica, but to boost productivity. An example is that the Bosch dust extractors keep the air cleaner by using HEPA filters that capture 99.97% of dust particles, eliminating additional clean up requirements. The Bosch Speed Clean dust-extraction drill bits are another product that is in compliance with the rule, when used to set adhesive anchors, it reduces installation time by up to 50%. They say “the key is using a comprehensive dust-management system.”
Similarly, Husqvarna Construction Products has created a number of vacuum attachments for their saws to comply with the new silica rule. Attachable to angle grinders, cut-off saws and masonry saws, this innovative adaptation enables dust to be captured at the source before it has a chance to be airborne. Product Manager Jamie Krueger advises using the portable MS 360 and MS 360 G, which are highly efficient masonry saws for cutting bricks or blocks. The addition of the MS 360 Vac Attachment makes it possible to cut dry, which he claims makes it helpful. “This way it keeps the brick or block dry, which makes it easier to install as well as control silica dust.” The MS 360 even has additional engineering controls to reduce exposure, with data testing currently in the works to include a dust shroud and extractor.
With these technological advancements, Krueger says Husqvarna has seen both positive and negative responses since the silica rule implementation. While negativity may potentially lie in product cost and time spent on adjusting to new regulations, feedback has been mainly positive, “as the majority of the contractors know that a healthier work environment is a benefit.”
Benjamin Franklin was not only a commendable founding father to our beloved country, but was also a firm believer in virtue, including equality, education, and industry. He once claimed, “They who can give up essential liberty to obtain a little temporary safety deserve neither liberty nor safety.” Of course, this was in regard to the right to bear arms, the basic principle lies in individuals taking advantage of their rights and being responsible for themselves. In this day and age, with respect to Franklin, mankind aims to take responsibility for itself as a whole by strengthening ourselves in any way that we can.
Is it with the virtues of equality, education and industry that companies have been working, innovating, and succeeding not only to comply with the new silica rule, but to make construction sites safer for all workers. Krueger from Husqvarna has enlightened us on the impact of the Silica Rule on the company. He says “OSHA has been working on a final ruling for the past several years, and since the first ruling on silica exposure, Husqvarna Construction Products has been working to develop ways to suppress the silica and keep workers more safe. So for us, the largest impact has been to help train contractors on the ruling and how our products can help with compliance. Helping contractors to work smarter, not harder.”
Additionally, the Mason Contractors Association has taken the lead on asking for changes to the rule, but also on keeping contractors educated and within compliance. To help contractors and MCAA members to comply with the new rule, the MCAA has developed a silica “train-the-trainer” program, along with a template Written Exposure Control Plan. MCAA also has developed a template written silica program. There resources are excellent places for mason contractors to start their compliance efforts.
CONTACT IS KEY
Jim Bohn expressed the great interest Bosch has in communication with their clients. Acknowledging feedback from their customers has led them to believe the greatest challenge for most companies is the reality of having to make the needed resource investments. According to Bohn these investments include, “1) product purchases, 2) record keeping and 3) associate training. There are some companies who are frustrated with the OSHA regulation, but do understand in the end what effect it has on workers’ health and our environment.”
Another form of Bosch’s communication has been their investment in three main resources to help customers and the market become engaged, trained, and compliant-ready.
Bohn explains “First, we initiated a national tour where Bosch associates traveled in dedicated vehicles to distribution companies, and trained them about the OSHA silica regulation and the product systems Bosch has that allow them to become compliant. This included actual hands-on use of products to realize the difference a proper system makes for the user during their application(s). Second, we provided information product booklets, ran webinars and provided other social media information to incentivize companies to get prepared before the enforcement date of September 23, 2017.
Finally, our sales and marketing teams were trained and prepared to provide a consistent and targeted message to distribution and user about understanding the steps required under the OSHA silica regulation and how those users can become compliant (whether with Bosch or another competitor). This included unique company training programs to meet individual customer needs for training associates and further advancing their progress in moving toward compliancy under the OSHA silica regulation.”
As human instinct goes, when there’s a problem we fix it. We perform, discover, make attempts, iterate, and hammer away to a point of satisfaction… and then the process continues. Scientists, designers, health activists, and achievers of all professions are cycling through this on a daily basis to improve the health and safety among all people. Some human instincts are a little more advanced, taking preventative measures before their time.
Pulse-Bac vacuums seem to have taken a lead in compliance. For about 15 years before the rule was enforced, Pulse-Bac was developing units that comply with requirements that would eventually be set forth in Table 1, such as the Automatic Pulse-Clean Technology and HEPA filtration.
According to Marketing Director Benjamin Kruse, “We already had HEPA-certified filtration, our patented Easy Empty System on our Longopac Baggers which allows the vacuum to continue running while dust is being dumped and our patented filter cleaning technology. Actually, we still overshoot the Silica Rule by quite a bit. We do this not to just meet a regulation but to give our customers the best performance and safety for their job.”
“We really jumped on educating ourselves about the rule early so we could be a resource to help people find the right solution, even if it’s not a vacuum,” Kruse admits. Pulse-Bac has it right when it comes to their attitude toward regulation— education on the topic is the best way to provide equipment guidance.
“We work with contractors from all types of trades to help find compliance solutions,” Kruse explains. “Plus our video on the subject has been viewed over 43,000 times.”
As I mentioned, we really started educating everyone here early on before the rule was even finalized to make sure we had the information to help contractors get compliant. We’ve also worked with OSHA inspectors to make sure the solutions we’re providing are acceptable, just as an added safety measure.”
Keeping up with simple, regular maintenance like filter changes has been a cornerstone of advice from Pulse-Bac is in response to mason contractors using these products. Kruse mentioned, “A large part of the service calls we get can either be fixed by or prevented with a filter change. When you’re busy trying to get a job done it’s hard to think about the filters, but concrete and masonry dusts will really beat them up. We build them pretty tough, but when you think about it they’re basically getting sandblasted for several hours every day.”
Each and every person on this planet wants to be safe and happy, and healthy air is one of the three essentials that make it possible. Maintaining this fundamental thought is crucial to the continuity of technological advancements in our society. For example, to ensure this education and advancement Husqvarna has held 900+ lunch and learns with mason contractors, general contractors, and construction equipment dealers over the past 18 months alone. Bosch has also been engaged in multiple educational activities, including OSHA silica regulation training in regards to their product systems.
Without the eagerness to accomplish more, and the required knowledge to better common practices, the industry could stagnate. With an increase in regulation aimed at making job sites safer, innovation must thrive.
Words: Megan Rajner
Photos: Bosch, Pulsebac