What OSHA's Silica Exposure Control Plan Must Include

A written exposure control plan is required under paragraph (g) of OSHA's construction silica standard, 29 CFR 1926.1153. The plan has a fixed content list at 1926.1153(g)(1): the silica-generating tasks the employer performs, the engineering controls and work practices assigned to each of those tasks, the housekeeping methods used, and the procedures for restricting access to areas where high exposures may occur. Paragraph (g) also requires the employer to designate a competent person and to review the plan at least annually. This page is for the person who has to produce or update that document: the safety manager, the HR lead carrying the safety file, or the owner of a small construction or fabrication business.

The mistake that shows up most often is writing the plan as a statement of policy about silica. The standard does not ask for a policy. It asks for a list of the tasks actually performed and the control actually used on each one, and a plan that names a task the crew no longer does, or omits one the crew does daily, does not match the site. The second common error is assuming that using Table 1 removes the plan requirement. It does not. Table 1 removes the exposure monitoring obligation when its controls are followed exactly; the written plan is required either way.

Last updated: September 21, 2026.

The silica standard sets a permissible exposure limit of 50 µg/m³ of respirable crystalline silica as an 8-hour time-weighted average, and an action level of 25 µg/m³ as an 8-hour TWA. A 2026 construction compliance guide describes the action level as the trigger for exposure monitoring, medical surveillance and written plan obligations. Those two numbers set the size of the problem. The written plan is the document that records how the employer keeps each task below them.

The standard gives construction employers two routes to control, and the plan has to say which route is used for each task. The same guide counts 18 pre-approved tasks on Table 1, each paired with a specified engineering control such as water delivery or local exhaust ventilation. Employers who follow a Table 1 entry exactly are not required to conduct exposure monitoring for that task. Employers who do not follow Table 1, or who cannot implement it fully, use the alternative exposure control methods route and must assess exposure.

The plan content list does not change between the two routes. Housekeeping, restricted access and the competent person designation are required in both.

Gather the following before the document is started. A plan written without the equipment list and the existing monitoring data has to be rewritten once those arrive.

1. Inventory the tasks

List every silica-generating task performed by employees, by operation and material. Done correctly, the result is a table with one row per task, not a paragraph. The count of rows should match the operations an inspector would see in a week on site.

2. Assign each task to Table 1 or to alternative methods

For each row, decide whether the work matches a Table 1 entry and whether the specified control can be implemented in full. If any part of the specified control is missing, the task moves to alternative exposure control methods and exposure assessment applies to it. You have done this correctly when every row has one route marked and no row is blank.

3. Write the engineering control and work practices beside each task

The requirement at 1926.1153(g)(1) is a description of the engineering controls, work practices and respiratory protection used for each task. Name the control in terms an operator can check: water on at the blade, shroud fitted, vacuum running, filter changed. A control stated as "dust suppression as needed" cannot be verified on site or in a hearing.

4. Write the housekeeping methods

The plan must describe how silica dust is cleaned up. Dry sweeping of silica dust is prohibited under the housekeeping rules. Name the permitted method for each area instead: wet sweeping, wet methods, or HEPA-filtered vacuuming. The section is complete when every place dust accumulates has a named method and the tools for that method exist on site.

5. Write the access restriction procedure

The plan must state the procedures used to restrict access to work areas where high exposures may occur. That means who is allowed in, how the boundary is marked, and who takes the boundary down. In the general industry version of the standard the equivalent control is a designated regulated area, and OSHA has cited employers for not establishing them. In the citation issued against a Pennsylvania brick plant on August 26, 2026, the Department of Labor listed the failure to establish regulated areas among the violations.

6. Designate the competent person in the document

The plan names the competent person. Write the name, the title and the authority: which tasks they inspect, what they are empowered to stop, and who they report to. The sources used on this page do not set a qualification standard or an inspection frequency for the role, so check the text of 1926.1153 for those details before finalizing the wording.

7. Cross-reference respiratory protection and medical surveillance

The plan describes the respiratory protection used for each task. The program behind it has to exist. Annual respirator fit testing is required, and medical surveillance applies to employees exposed at or above the action level for 30 or more days a year. The initial medical exam is due within 30 days of assignment and periodic exams follow every 3 years, at the employer's expense. The 2026 exposure limits, the surveillance schedule and the compliance dates that surround this plan are set out in the 2026 OSHA silica standards reference on this site.

8. Record where the exposure and medical records are kept

The silica standard does not set its own retention periods for air monitoring and medical records. It ties them to 29 CFR 1910.1020, the access to employee exposure and medical records standard. The plan should state where those records live and who releases them, and the retention periods should be read from 1910.1020 itself.

9. Review the plan at least annually, and whenever the work changes

An annual review is part of the plan requirement. Record the date of each review and the initials of the reviewer on the document. A new task, a new tool, a new material or a new site is a reason to revise it before the annual date arrives.

The sources used here give no figure for the cost or the hours of drafting a plan. They do establish one cost that is fixed: the medical examinations triggered by the 30-day threshold are paid for by the employer.

The failures below are drawn from OSHA's published enforcement record, not from a general list of mistakes.

The overexposure is known and the plan is not changed. In the case OSHA announced on August 26, 2026, the agency alleged that General Shale Brick Inc. knew of silica overexposure at its Watsontown, Pennsylvania plant and failed to correct it. Three willful violations were issued. Recognize it by any monitoring result above the limit with no corresponding revision date on the control plan. Fix it by dating the revision to the result and recording what changed.

Exposure is assessed for some jobs and not others. OSHA alleged that the employer did not assess silica exposure levels for all jobs with a silica hazard. Recognize it by comparing the task inventory in the plan against the list of jobs with sampling data. Any task on the alternative methods route with no sample is the gap.

Respirators are named in the plan and not required on the floor. OSHA alleged that affected workers were not required to wear respirators despite known exposure. A plan that assigns respiratory protection to a task creates an obligation to enforce its use.

Fit testing lapses. OSHA alleged a failure to conduct annual respirator fit testing. That item was issued as a repeat violation, tied to a prior fit-testing citation at the company's Augusta, Georgia facility. Recognize it by a fit test date more than 12 months old on any employee assigned a respirator. EHS Today's account of the case traces the repeat designation to that earlier Georgia citation.

Restricted access exists only in the document. OSHA alleged that the employer did not establish regulated areas for silica-exposed employees. A written access procedure with no barrier, sign or entry control on site is the same condition.

The medical surveillance roster is missing. OSHA alleged a failure to provide required medical examinations to employees exposed 30 or more days a year. Recognize it by the absence of a roster that identifies who crosses the 30-day threshold.

Dry sweeping continues. The housekeeping rules prohibit dry sweeping of silica dust. A plan that specifies vacuuming while brooms are the only equipment on the truck fails on the floor before it fails on paper.

Construction versus general industry. The plan content list described on this page sits in the construction standard, 29 CFR 1926.1153. The Watsontown citations were issued at a molded brick manufacturing plant and turned on regulated areas, exposure assessment, respirator use, fit testing and medical examinations. Manufacturing employers should work from the general industry silica standard rather than from 1926.1153(g).

California. California has been running a separate track. The state adopted an emergency temporary silica standard in December 2023 and a permanent standard, Title 8 Section 5204, in February 2025. Senate Bill 20, signed in October 2025, classifies silicosis as a serious illness under state law. On May 22, 2026, the Occupational Safety and Health Standards Board voted unanimously to begin rulemaking that would prohibit the fabrication and installation of artificial stone products containing more than 1% crystalline silica, and directed Cal/OSHA to prepare emergency findings for expedited rulemaking and to convene advisory committees, including a scientific advisory committee. The Department of Industrial Relations notice names cutting, grinding, polishing and cleanup of artificial and natural stone as the targeted tasks. California employers in stone fabrication should treat the federal plan content list as a floor.

The 25 µg/m³ action level. Below the action level, monitoring and medical surveillance obligations are not triggered by the 2026 guidance cited above. The task list, controls, housekeeping and restricted access still have to be described if employees perform covered tasks.

The 30-day threshold. Medical surveillance attaches to employees exposed at or above the action level for 30 or more days a year. An employee at 29 days is outside it. The roster has to be counted, not estimated.

How the inspection starts. The Watsontown inspection, conducted February 12, 2026, was opened under OSHA's Site-Specific Targeting inspection plan combined with the National Emphasis Program on silica, and included a review of the company's injury and illness records. No complaint and no accident is needed. Employers whose recordable rates place them in the targeting program should expect the plan to be requested.

Construction firms received more than 400 silica-related citations in 2025. Penalty exposure from a single inspection is put at $50,000 to $130,000 in the same 2026 guide, which also counts more than 2 million construction workers exposed to silica each year. The Watsontown case sits above that range because of the willful and repeat classifications.

California's enforcement figures are separate. Cal/OSHA's Silica Special Emphasis Program has produced more than 900 citations and roughly $1.9 million in proposed penalties. The same program conducted 465 onsite consultations, reaching 27,665 employees.

The health figures behind the standard are concentrated in one trade. Around 98% of California silicosis patients in the stone fabrication industry are Latino men. The average age at death from silicosis in that population is under 50.

The cost of producing the plan itself is not reported in any of the sources used here. The documented costs are the medical examinations, which the employer pays for, and the penalties above.