ASSE Comments on OSHA’s Silica Proposed Rule
In comments submitted for the record, ASSE generally supported OSHA’s proposed rule on Occupational Exposure to Crystalline Silica. If adopted, a new standard would lower OSHA’s PEL for exposures to silica in the workplace to 50 micrograms per cubic meter of air (µg/m3), putting into place a long-standing NIOSH recommendation. It would also set an action level of 25 µg/m3, the TLV set by ACGIH. Implementation of feasible engineering and administrative controls, improved medical surveillance and proactive exposure monitoring in situations where exposures above the PEL can be anticipated are also covered. These requirements are generally consistent with the recommended best practices established in the ASTM E1132 Standard Practice for Health Requirements Relating to Occupational Exposure to Respirable Crystalline Silica, (general industry) and the ASTM E2625 Standard Practice for Controlling Occupational Exposure to Respirable Crystalline Silica for Construction and Demolition Activities. The rulemaking covers the three forms of crystalline silica – quartz, cristobalite, and tridymite – and applies to general industry as well as the construction and maritime industries.