The Occupational Safety and Health Administration (OSHA) began a new initiative to conduct enhanced enforcement and compliance assistance efforts in the engineered stone fabrication and installation industries.
The September 22, 2023 Memorandum supplements a February 4, 2020 National Emphasis Program addressing “Respirable Crystalline Silica.” OSHA’s recognition of engineered stone as a hazard to workers goes as far back as 2015, when OSHA and the National Institute of Occupational Safety and Health (NIOSH) issued a Joint Hazard Alert. The new initiative is in response to new studies on the lethality of inhaled silica.
The most common illness resulting from inhaled silica is silicosis. Silicosis is the result of breathing tiny bits of silica which overtime may cause permanent lung scarring, called pulmonary fibrosis.[1] Asthma is also a common disease associated with silica inhalation.
The Memorandum references a 2019 Center for Disease Control (CDC) study where 18 cases of silicosis were reported among engineered stone fabrication workers, with two resulting in fatalities. The Memorandum also references a JAMA Network study, which showed grim results for those workers with silicosis. Of the 52 male subjects diagnosed, 20 patients had advanced disease, 11 were referred for lung transplants, and 10 had died. The study found those exposed to higher levels of silica may cause silicosis to occur in acute and accelerated forms over shorter periods of time.
OSHA identifies two North American Industry Classification System (NAICS) codes where enforcement will be prioritized: 327991 (Cut Stone and Stone Product Manufacturing) and 423320 (Brick, Stone, and Related Construction Material Merchant Wholesalers). The Memorandum limits its application to OSHA Regions 1 – 8, which includes almost every state but the pacific coast, Arizona, and Idaho. To be selected under this initiative, the company must meet one of the following criteria: (1) Manufacturing and/or finishing engineered or manufactured stone products at a facility, with activities at these facilities including: cutting, grinding, chipping, sanding, drilling, and polishing engineered or manufactured stone products; opening bags of ground quartz, moving or mixing bulk raw materials, cleaning and scraping mixers, or cleaning dust collector bag houses; changing filters on dust collectors; making the engineered or cultured slabs – involves mixing crystalline silica, resins, and pigments; operating powered hand tools, such as saws, grinders, and high speed polishers; casting department that mixes and heats raw materials including silica sand, epoxy resin, PA, and pigments; or (2) finishing and/or installing engineered or manufactured stone products off-site.
Inspections will assess compliance with standards 29 CFR §1910.1053 and/or 29 CFR §1926.1153 (construction industry), and may include other standards concerning ventilation, noise exposure, personal protective equipment, respiratory protection, hazard communication, and recordation procedures.
During inspections, CSHOs may:
- verify how employers determine the amount of silica workers are exposed to;
- observe and interview workers regarding use and maintenance of controls and respiratory protection;
- inquire as to the location of regulated areas and ensure that employer demarcates and limits access to regulated areas and requires used of respirators by employees;
- verify the dust controls and safer work methods employers use to protect workers from silica exposures;
- request and review the employer’s written Exposure Control Plan (ECP).
- observe housekeeping practices to ensure employer avoids housekeeping practices that expose workers to silica;
- ensure employers offer medical examinations and tests as required under the standard;
- verify that employers train employees on the health effects of silica exposure, workplace tasks that can expose workers to silica, and ways to limit exposure; and
- ensure employers properly maintain accurate air monitoring data, objective data, and medical surveillance.
Employers who work with or produce manufactured stone should ensure they have controls and programs to identify and comply with the standards. Importantly, an Exposure Control Program should be reviewed to ensure compliance.
[1] https://www.lung.org/lung-health-diseases/lung-disease-lookup/silicosis/learn-about-silicosis