Interim Enforcement Guidance for Respirable Crystalline Silica for Construction-January 2018

Monthly Round Up of Important Ideas and Standards in
Industrial Hygiene and Safety

January 2018

IN THIS ISSUE: Interim Enforcement Guidance for Respirable Crystalline Silica for Construction

As of September 23, 2017, the Occupational Safety & Health Administration (OSHA) began enforcing the new Respirable Crystalline Silica in Construction. In order to give employers some additional time to comply, it offered compliance assistance instead of enforcement for the first thirty days. This period is now over and employers involved in construction must fully implement the standard. This should not be a surprise, since the original standard, 29 CFR 1926.1153, became effective on June 23, 2016.In October, the Acting Deputy Assistant Secretary, Thomas Galassi, issued a memorandum to OSHA Compliance Officers (CSHO) for conducting inspections. Here are some of the key points:

  • Where employers fully comply with Table 1 of the standard, there is no requirement to collect air samples.
  • If there are additional tasks listed in Table 1 or if the employer has not implemented necessary engineering, work practices, and respiratory protection, air sampling is required.
  • The employer may choose the performance option but must provide objective data that their controls are effective. These will be reviewed by the CSHO.
  • The employer may also choose the scheduled monitoring option that includes initial and periodic air sampling. This data will also be reviewed by the CSHO.
  • Where the employer has fully implemented the provisions of Table 1, the company will not be cited.
  • However, if the employer has not fully implemented Table 1 and has not conducted an exposure assessment, citations will be issued by the CSHO.

In 2018, the Respirable Crystalline Silica in Construction standard should be in full swing. Employers who have not fully implemented their program should make sure it is a priority in their safety goals for the new year.

For  more information on this topic and to discuss your company’s safety and industrial hygiene needs call OccuSafe at (214) 662-6005 or visit us at
OccuSafe Industrial Hygiene & Safety, Inc. provides skills and expertise to recognize, evaluate and control hazards and injuries in the areas of industrial hygiene, occupational safety and health. OccuSafe services companies of all sizes in a range of industries.

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