In the wake of OSHA’s new silica rule, foundries and other effected industries have raised many new questions of interpretation. Among those at the top of the list are questions related to housekeeping, control feasibility, and employee exposure assessment.
Following the efforts of the American Foundry Society to understand which types of sweepers are acceptable under the rule, a new clarification has been made. As of early October, OSHA has agreed to allow for the ongoing use of non-HEPA filtered mechanical sweepers in industries to which the new standard applies.
Why is the agreement on the use of non-HEPA sweepers important?
First, the cost of new sweepers can be noteworthy at best and an infeasible major expense at worst. Whenever possible, foundries must be conservative with overhead expenses in the face of numerous requisite controls they are compelled to install.
Secondly, this may indicate a willingness on the part of OSHA to work with employers to reduce respirable silica, rather than holding to a hard-lined interpretation of the original language.
However, an important factor in this new agreement is what it does not say. OSHA is not allowing employers to neglect the remaining requirements of the standard.
The ban on dry sweeping and use of uncollected compressed air for housekeeping is still in full effect.
The requirement of employers to implement all feasible engineering controls is still in full effect.
The exposure threshold which triggers medical surveillance requirements is still in full effect.
Again, this agreement does not nullify any of the language found in the final rule.
KERAMIDA has developed extensive experience in many types of foundries both large and small. One thing that we have found to be true of every facility is that it is better to reduce silica sources than to capture silica once it is released and suspended in air. Of course this is not always the most cost effective or the most technically feasible, but it is better for the health of employees and compliance with standards. That said, the use of HEPA-filtered mechanical sweepers does lead to a reduction in the amount of silica which becomes airborne; a primary intention of sweepers from the outset. Finally, whatever silica-reducing controls are currently placed in your facility should be referenced in your silica exposure control plan.
For assistance with understanding your regulatory obligations and corresponding options, or to begin development of your required silica exposure control plan, contact us or call KERAMIDA today at (800) 508-8034 to speak directly with a silica compliance professional.