In April 2018, Washington State adopted a rule that further regulates employee exposure to respirable crystalline silica (RCS), following OSHA’s publication of a similar—but less stringent—rule in 2016. Washington’s rule went into effect for the construction industry in October 2018 and will go into effect for occupations outside of construction on July 1, 2019.
Many companies are familiar with OSHA’s version of these rules and the general issues surrounding employee exposure to RCS. But with tighter regulation looming in Washington, here’s what you should know.
First, A Brief Introduction to RCS and Its Health Effects
Crystalline silica is a mineral found in stone, soil, sand, concrete, brick, paints, plaster, and other materials often used in construction and industrial activities. It becomes respirable when those materials are cut, ground, drilled, crushed, or otherwise manipulated in a way that creates dust.
Inhaling dust that contains crystalline silica particles can lead to several health issues, including silicosis (an incurable lung disease), lung cancer, pulmonary disease, and kidney disease.
Who is at Risk for RCS Exposure?
According to OSHA, 2.3 million people in the U.S. are exposed to silica in the workplace. Industries with high exposure risk include construction, refining, mining, and manufacturing.
Washington State Regulation of RCS
Washington State’s rule is similar to the federal rule, but more stringent in some ways. In addition to setting standards on what concentration of RCS employees can be exposed to, the rule also lays out specific requirements related to:
- Required assessment of employee exposure to RCS, including personal air sampling.
- Exposure control methods, which define engineering controls and work practices related to 18 specific work tasks with high RCS exposure risk, including use of certain tools.
- Required respiratory protection for employees.
- Housekeeping/cleaning practices to minimize exposure risk.
- Medical surveillance.
- Training and recordkeeping.
What This All Means in Practice
Not only should companies operating in Washington consider a review to ensure that they are in compliance with the new rule, but there are permitting issues at hand as well. New permits may be required if a company is installing pollution control devices in response to the rule, or additional reporting on related emissions may be necessary.
The South Sound Environmental Managers Forum