ASSE Backs Silica Rule, For the Most Part

President Kathy Seabrook's comments submitted Jan. 31 endorse the proposed 50 µg/m3 PEL and the 25 µg/m3 action level but say implementation on small, short-term construction sites will be a challenge.

American Society of Safety Engineers President Kathy A. Seabrook, CSP, on Jan. 31 submitted comments on behalf of ASSE about OSHA's respirable crystalline silica proposed rule. The comments generally endorse the proposed rule and are far more detailed and thorough than most other comments that have been submitted about the rule; Seabrook's answer many of the nearly 90 specific questions posed in it.

The key questions are whether the proposed 50 µg/m3 PEL and the 25 µg/m3 action level are feasible and whether OSHA's proposed hierarchy of mandating engineering and workplace controls while barring job rotation as a way to achieve compliance is sound policy. ASSE's comments endorse the lower exposure limits but not the rejection of job rotation: "For tasks that involve some levels of silica exposure but are performed in an infrequent basis, job rotation may be warranted as an alternative to other, more burdensome, engineering or administrative controls," they state. "We urge OSHA to reconsider this issue, especially given the fact that every person on earth is exposed to some degree of crystalline silica as a main constituent of the planet’s crust and due to its presence in so many construction materials."

The comments also say implementation of the lower exposure limits and the necessary controls on small, short-term construction sites will be a challenge, and that "technological and economic infeasibility is likely to be the subject of many affirmative defenses to silica citations in the future."

But because OSHA has stated that the rule is viewed as a "technology forcing" standard, it should go ahead with the lower limits and should continue to monitor new technological advances, the comments state. They mention one specific new technology developed in conjunction with NIOSH and being used in the mining and oil and gas industries -- mobile air shower technology – and say its use should be deemed compliant under this rule rather than requiring a variance.

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