OccuSafe Industrial Hygiene Consulting

Many of my clients use sweeping compounds to reduce airborne dust when cleaning their facilities. A number of these clients want to know if this practice is acceptable under the new OSHA Respirable Crystalline Silica (RCS) Standard when cleaning up dust that may contain Silica. From my reading of the OSHA standard, guidelines, and training materials along with a personal interview with an OSHA compliance officer, I conclude the following:

• Dry floor sweeping using sweeping compounds is not permitted unless wet methods, HEPA vacuuming or wet sweeping are not feasible and it can be demonstrated through air sampling they are more effective in controlling silica dust.
• The use of wet floor sweeping compounds are not wet sweeping even if there are manufacturer claims to the contrary.

In the housekeeping section of the new OSHA general industry standard, 1910.1053 it states.“The employer shall not allow dry sweeping or dry brushing where such activity could contribute to employee exposure to respirable crystalline silica unless wet sweeping, HEPA-filtered vacuuming or other methods that minimize the likelihood of exposure are not feasible.” In addition, the Interim Enforcement Guidance for the Respirable Crystalline Silica in General Industry and Maritime under Housekeeping Practices states:

• “Dry sweeping and dry brushing are prohibited where such activities could contribute to employee exposures to respirable crystalline silica, unless wet sweeping, HEPA-filtered vacuuming, or other methods that minimize the likelihood of exposure are not feasible (i.e., other cleaning methods would not be effective, would cause damage, or would create a greater hazard in the workplace).  §1910.1053(h)(1).”
• “The employer bears the burden of showing that the alternative methods (not dry sweeping) are not feasible.”
• “The use of sweeping compounds (e.g., grit, non-grit, oil- or waxed or water-based) is an acceptable dust suppression housekeeping method provided the employer can demonstrate that such compounds do not create additional exposures.”

The Oregon Occupational Safety & Health Division Technical Guidance of April 14, 2017 states the following:
“The use of a dry sweeping compound does not in and of itself violate the rule because the particle size of the sweeping compound is typically larger than the particle size of concern, unless there is some activity that would fracture the particles.” It further states: “when there is silica-containing debris, dry sweeping is still prohibited unless other methods, such as wet sweeping or HEPA vacuuming are not feasible. When other methods are not feasible and dry sweeping is the only cleaning method that can be used, there is no prohibition on using a dry sweeping compound, but the initial exposure assessment must include this activity to determine employee exposure levels to silica.” In a telephone interview with an industrial hygiene compliance officer in the OSHA Denver area office, the officer stated that the use of floor sweep is not wet sweeping and would not be allowed as a method of controlling silica dust.

Employers should not allow the use of the floor sweep to clean up silica dust under almost any circumstances. The OSHA designated methods are to be used.

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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