Do You Have Your Written Silica Plan?

The not-so-new Cal/OSHA Crystalline Silica regulation for construction (8CCR1532.3) includes several required elements for the contractor. Over the past year, many contractors have called us and requested air sampling so that they can make a determination of potential exposure levels, controls needed, etc., but surprisingly, we rarely see contractors preparing their written Exposure Control Plan which is one of the required parts of the regulation [see 1532.3(g)].  The Control Plan must be in writing and include several items, as follows:

1. Identification of the Competent Person who will conduct the inspections and ensure the plan is properly implemented. We’ve previously discussed who should be a competent person under this regulation.
2. A description of the tasks that involve silica exposure.
3. A description of the controls used to minimize exposure. Controls may include engineering controls, work practices and respiratory protection.
4. A description of the housekeeping measures again to minimize exposure to silica.
5. A description of procedures to restrict access to affected work areas, when needed to minimize the number of employees potentially exposed to silica and minimizes their level of exposure. This should include information regarding exposures that may be created by other employers.

The Control Plan is to be reviewed and updated at least annually and made available to employees.  Be sure you have your Exposure Control Plan. If needed, call us and we can assist putting a compliant program together for you.