Respirable Crystalline Silica Rule — What You Need to Know: Training Requirements & Breather Boxes

Respirable Crystalline Silica Rule — What You Need to Know: Training Requirements & Breather Boxes

What exactly does the Occupational Exposure to Respirable Crystalline Silica final rule mean for employers? Who must be trained? On what precisely? And should you require breathable air?

There are so many questions, we’ll try to break down some of them for you.
Under the rule, what do employees need to be trained on?

First of all, OSHA says the training requirement for the respirable crystalline silica final rule is performance-based. This means that during an OSHA inspection, compliance will be judged based on an employee’s ability to “perform,” or demonstrate knowledge of the rules. (This is similar to how OSHA enforces the workplace container labeling rule under HazCom 2012. It doesn’t matter what’s on the container label . . . it matters how much your employee can tell the inspector about what’s inside the container.)

With this performance-based approach in mind, OSHA says that training should “ensure that each employee covered . . . can demonstrate knowledge and understanding of at least the following”:

• “The health hazards associated with exposure to respirable crystalline silica”
• “Specific tasks in the workplace that could result in exposure to respirable crystalline silica”
• “Specific measures the employer has implemented to protect employees from exposure to respirable crystalline silica, including engineering controls, work practices, and respirators to be used”
• “The purpose and a description of the medical surveillance program” intended to monitor workers for exposure to silica

Workers in the construction industry must also be able to identify:

• “The identity of the competent person designated by the employer”

In short, OSHA is saying we don’t care exactly how you do it, but we want to see your employees being able to show that they can provide this basic information.

I’ve heard some workplaces are exempt from the rule if they have lower-levels of silica dust. Does this mean they’re also exempt from the new training requirements?

It’s true that employers who have established that the silica in their workplaces stays beneath certain levels are exempt from the new silica rule. According to OSHA, the rule does not apply in general industry and maritime where the employer has “objective data” demonstrating that employee exposure to respirable crystalline silica will remain below 25 micrograms per cubic meter as an 8-hour time-weighted average “under any foreseeable conditions” and does not apply in construction where employee exposure will remain below 25 micrograms per cubic meter as an 8-hour time-weighted average under any foreseeable conditions.

These businesses are exempt from the new rule, and thus also from the training portion. However, OSHA says that when these reduced exposure levels are achieved through engineering controls, then the exemption does not apply. OSHA explains its reasoning thusly:

“OSHA intends the requirements for training on control measures, housekeeping, and other ancillary provisions of the rule to apply where engineering controls are used to limit exposures. Without effective training on use of engineering controls, for example, it is unreasonable to expect that such controls will be used properly and consistently. Thus, the exception does not apply where exposures below 25 mg/m3 as an 8-hour TWA are expected or achieved, but only because engineering or other controls are being used to limit exposures; in that circumstance, but for the controls, exposures above 25 mg/m3 as an 8-hour TWA would be foreseeable, and are foreseeable in the event of control failure or misuse.”

Does OSHA give other hints as to what the training should involve, or how it should be conducted, or how long it should take?

Yes, in a limited way. OSHA makes clear that it is giving employers considerable latitude in the training method(s) because 1.) compliance is performance-based, and 2.) OSHA believes “the employer is in the best position to determine how the training can most effectively be accomplished.”

However, in the text of the rule, OSHA does suggest that “Hands-on training, videotapes, slide presentations, classroom instruction, informal discussions during safety meetings, written materials, or any combination of these methods may be appropriate.” OSHA also says it expects “that a full hour of training, on average, will be required for all covered workers.”

The only hard and fast requirement is that employees must be able to ask questions. OSHA says these questions can be answered live, as the training happens, or at a later time.

As OSHA puts it: “to ensure that employees comprehend the material presented during training, it is critical that trainees have the opportunity to ask questions and receive answers if they do not fully understand the material that is presented to them. OSHA reiterates that when videotape presentations or computer-based programs are used, this requirement may be met by having a qualified trainer available to address questions after the presentation, or providing a telephone hotline so that trainees will have direct access to a qualified trainer. Although it is important that employees be able to ask questions, OSHA finds that the employer is in the best position to determine whether an instructor must be available for questions during training or if a trainer can answer questions after the training session.”

Who precisely do I have to train?

You have to train all workers whose workplaces are covered by the silica rule.

OSHA spells out that this “applies to newly hired workers who would require training before starting work, workers who change jobs within their current workplace or are assigned new tasks or exposure protection, and any covered worker an employer believes needs additional training.”

Can breathing air provide an extra level of safety and security?

Absolutely, especially when the employee exposure to respirable crystalline silica will remain above 25 micrograms per cubic meter as an 8-hour time-weighted average and the employee is working in either a confined space or limited access area. In most cases the requirement under these conditions is for the employer to provide the use of half-face piece particulate respirators with N95 or better filters. However, the use of a breather box can provide and extra level of safety, coverage, and security.

The Breather Box is a portable Grade-D filtration system designed to provide breathing air for a specific number of workers utilizing a portable compressor that may already be in use for air tools. The system filters incoming air from a compressor to provide ­respirator users with Grade-D quality air and ­monitors for CO and/or Oxygen.

The first stage element filters bulk water and particulate and has an auto drain. The second stage coalescing filter eliminates atomized oils, mists, ultra-fine particulates, and has an auto drain. The third stage filter removes organic vapors and odors and has a manual drain. Filter change indicators are standard on all three stages of filtration. Filtration efficiency is 99.99% @ .01 micron.

The standard carbon monoxide (CO) airline monitor operates on disposable 9-volt batteries, 8-16 volt DC, or 115 VAC for continuous air monitoring. An external audible alarm and light signals the workers of high CO content.

If an IDLH work environments exist, the Auto-Air Breather Box option should be considered. The Auto-Air filtration system was developed to provide Grade-D breathing air with full automatic reserve air in the event of either electrical failure or reduced pressure from the main air source while working in hazardous environments. Reserve air activation occurs at 60 psi and/or loss of electrical supply, the system automatically switches to the reserve air cylinder(s). Local and optional remote alarms signal the workers that the primary air system has failed and has switched to the back-up air system

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