Silica Exposure Control Plan Builder

What the plan must contain

In construction, 29 CFR 1926.1153(g)(1) requires a written plan with at least four elements:

1. A description of the tasks in the workplace that involve exposure to respirable crystalline silica.
2. A description of the engineering controls, work practices and respiratory protection used to limit exposure for each task.
3. A description of the housekeeping measures used to limit exposure.
4. A description of the procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed and their level of exposure, including exposures generated by other employers or sole proprietors.

Paragraph (g) then adds three duties. The employer reviews and evaluates the plan's effectiveness at least annually and updates it as necessary. The plan is made readily available for examination and copying, on request, to each covered employee, their designated representatives, OSHA and NIOSH. And the employer designates a competent person to make frequent and regular inspections of job sites, materials and equipment to put the plan into effect.

In general industry and maritime, 29 CFR 1910.1053(f)(2) asks for the first three elements only, with the same annual review and availability. There is no access-restriction element and no competent person. Instead, where exposure is or can reasonably be expected to be over the PEL, the employer must set up a regulated area under paragraph (e). The builder switches between the two when you choose the standard.

What OSHA's silica exposure control plan must include goes through each element, the mistakes that show up in inspections, and how the plan changes in California and in manufacturing.

Tasks from Table 1

In construction, a task picked from Table 1 brings that row's engineering controls and work practices into the plan word for word, with the respirator the Table requires. The respirator column depends on the hours: if the Table 1 tasks a worker does add up to more than four hours a shift, the over-4-hours column applies to every one of them. Enter the hours a typical shift has. A task that is not on Table 1, or is done without all of its listed controls, has to have its controls described in your own words and its exposure assessed by air monitoring or objective data. The Table 1 checker shows each row in full, and the exposure calculator reads a monitoring result.

Write controls an operator can check: "water on at the blade before the cut starts," not "dust suppression as needed." The plan's job is to say what is actually done on each task, so the crew and an inspector can see whether it is.

Housekeeping

The plan must describe how silica dust is cleaned up. The standard limits two methods. Dry sweeping and dry brushing are not allowed where they could contribute to exposure unless wet sweeping, HEPA-filtered vacuuming or other methods that minimize the likelihood of exposure are not feasible. Compressed air is not allowed for cleaning clothing or surfaces where it could contribute to exposure, unless it is used with a ventilation system that effectively captures the dust cloud, or no alternative method is feasible. The builder writes both limits into every plan; tick the methods you do use. Is compressed air banned for silica dust cleanup? and the HEPA rating OSHA requires go further.

Restricting access and the competent person

The construction standard does not list the access procedures; it asks the employer to describe the ones used. The choices in the builder are common ways to do it, not requirements: mark the zone, keep out workers not needed for the task, post signs, schedule dusty work for quieter times, and warn other employers before starting near their crews. The standard does require that the procedures cover exposures generated by other employers and sole proprietors, which on a shared site is the part most often missed.

The standard defines a competent person as someone capable of identifying existing and foreseeable silica hazards, with authorization to take prompt corrective measures to eliminate or minimize them. Name a person who is on site and can stop the work.

Regulated areas in general industry

Tick the box if any area is over the PEL of 50 µg/m³ as an 8-hour average, or can reasonably be expected to be. The plan then sets out what 1910.1053(e) requires: the area marked off, signs at every entrance with the legend the standard prescribes (DANGER, RESPIRABLE CRYSTALLINE SILICA, MAY CAUSE CANCER, CAUSES DAMAGE TO LUNGS, WEAR RESPIRATORY PROTECTION IN THIS AREA, AUTHORIZED PERSONNEL ONLY), access limited to people authorized and required to be there, and a respirator for everyone who enters.

Keeping the plan current

The builder sets the next review a year from the plan's date. Review it sooner when the work changes: a new tool or material, a new task, or a monitoring result over the limit. Each of those is also a reason the standard requires exposure to be reassessed. Your draft is saved in this browser so you can come back to it; nothing you type is sent to Academy of Occupational Health & Risk Sciences or anyone else. The OSHA silica standard explained sets out the rest of the rule, including training, medical surveillance and records.

A starting draft from the federal standards, not legal advice. Check every line against the work on site. States with their own OSHA-approved plans, including California, can require more.
Sources: 29 CFR 1926.1153 (construction), paragraphs (b), (c), (f) and (g); 29 CFR 1910.1053 (general industry and maritime), paragraphs (e), (f), (h) and (j)(2); OSHA, Silica, crystalline.