In Part 4, we took a look at Table 1 of the OSHA Silica Construction Standard and looked at a couple of examples to show how to use it. In Part 5, we looked at an example where we couldn’t use Table 1.
Now, we want to delve further in the OSHA Construction Standard and talk about the rest of the requirements.
First up, the Exposure Control Plan (ECP).
Exposure Control Plan
The Exposure Control Plan is required for any work where the potential for silica exposure can exceed the Action Level (25 micrograms). The requirements for the Plan are not overly extensive, but there are a few things to be done. The minimum requirements for the Exposure Control Plan include:
- It must be written.
- It must contain: a description of the tasks where employees can be exposed to silica; controls implemented to limit exposure; housekeeping measures to limit exposure; measures taken to restrict access to silica work areas.
- It must be reviewed and updated at least annually.
- It must be readily available. Although OSHA doesn’t define “readily available,” as a practical matter, the Plan should be at the job site.
As you can see, there’s not really all that much that’s required. The name of the competent person isn’t required, exposure results aren’t required, medical screening results aren’t required, audit results aren’t required, etc. The Exposure Control Plan’s purpose is to identify specific procedures used to minimize exposure. I expect that your Exposure Control Plan usually will be only a few pages, and each site will have its unique Plan.
Have an overall silica program which outlines all the things required by the Silica Standard. Use this as a guidance document for the silica competent person(s). Within the program, have individual Exposure Control Plans for each project site where silica-exposure tasks are outlined along with engineering controls, measures to limit exposure, and all other necessary elements. That way, the competent person(s) will have an overall guidance document (like a user’s manual) and site-specific guidance for specific compliance.
Having an overall silica program will make implementation much easier to implement and maintain.
Next: Medical Exams
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