Photo Credit: https://ccicomply.net/date-changes-to-oshas-silica-standard-for-construction
“I cut wet, so I don’t need to worry about the new silica standard.”
Myth #1: “Cutting Wet is all I Need to Do”
So is this true? That if we cut wet, we don’t need to worry about the OSHA Respirable Crystalline Silica Standard for construction? It’s only partially true.
Let’s first look at the Table 1 requirements. Table 1 has very strict criteria for engineering controls (water or vacuum), and if you adhere to them you don’t need to do exposure testing. OSHA has already conducted extensive testing and determined exposure levels for these tasks using specific engineering controls. For a table saw, the only Table 1 method is cutting with water. You can cut a full 8 hour shift with a table saw without wearing a respirator.
Handheld Gas Saw and Respirator
For a handheld gas saw (like the popular Stihl or Husqvarna models), Table 1 limits you to a 4 hour shift without a respirator. If you exceed 4 hours of cutting in a shift, then you must wear a respirator. Most hardscapers will cut much more than 4 hours per day, especially when building a seating wall!
If you are required to wear a respirator more than 30 days per year, then the employer must also comply with the medical surveillance portion of the law. The medical surveillance is very complicated and expensive… avoid it at all costs!
Cutting Wet is an Engineering Control
Finally, cutting wet is an engineering control. That is an important first step, as OSHA considers engineering controls the first line of defense! Even if you manage to avoid the medical surveillance portion of the law by using table saws or short shifts, it doesn’t excuse you from complying with the administrative controls
Administrative controls include hazard communication training, written control plan, and more. Don’t forget this part of the law, as many hardscapers have been cited for that!
Myth #2: Using a Respirator for Cutting Concrete
Many people think good respirators is all that is required. OSHA also requires engineering controls that eliminate dust hazards.
“I bought my crew high quality respirators, so we’re good.”
This is completely false! First, OSHA requires engineering controls to be the first and primary control. Engineering controls reduce or eliminate the hazard itself, and the only recognized methods for the hardscape industry is water and vacuum. Administrative controls change how the worker interacts with the hazard.
Finally, Personal Protective Equipment (PPE) is the last line of defense, protecting only the person wearing it. PPE is used when engineering & administrative controls are insufficient to fully reduce the hazard to permissible levels.So if you use PPE as the first line of defense, you are at a high risk of being cited for lack of engineering and administrative controls.
Aside from not complying with the law, you need to be aware that (if no engineering controls are used) you would need to wear a full face respirator in order to reduce the exposure.
There’s several issues here…
- Any respirator, especially a full face respirator, is very hot & bulky!
- If you are required to wear a respirator more than 30 days per year, you must also comply with the complicated and costly medical surveillance requirements.
- A rough estimate is that close to 50% of the men in our industry are bearded! You cannot get a good seal with facial hair, so you’re limited to wearing a goatee that won’t interfere… or wearing a loose fitting full face respirator with powered air supply purifier, or a hood.
When is a respirator a good idea?
If you have a very short duration task, such as drilling a couple holes, you are likely fine just wearing a respirator without using a an engineering control. OSHA does recognize that certain tasks generate exposure, but the task is so short that the exposure levels don’t reach dangerous levels.
Again, PPE is the last line of defense… while it is likely part of your silica dust control plan, it cannot be the primary hazard control!