OSHA recently released an interim enforcement guidance for the new silica standard. The guidance will be in place until the official compliance directive is available.
The interim guidance doesn’t address all parts of the new standard, but it does include housekeeping, answering some of big questions about enforcement, like whether sweeping compounds are acceptable for dust suppression.
Housekeeping Practices [paragraph (f)]
- The paragraph prohibits dry sweeping and dry brushing where such activities could contribute to employee exposures to respirable crystalline silica, unless wet sweeping, HEPA-filtered vacuuming, or other methods that minimize the likelihood of exposure are not feasible (i.e., the other cleaning methods would not be effective, would cause damage, or would create a hazard in the workplace). The employer bears the burden of showing that the alternative methods are not feasible.
- Using sweeping compounds (e.g., non-grit, oil- or waxed-based) is an acceptable dust suppression housekeeping method.
- The use of compressed air for cleaning is allowed where the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air, or where no alternative method is feasible.
- The employer’s exposure control plan must include the description of the housekeeping measures.
The interim guidance also addresses air sampling, exposure assessments, written exposure and control plans, and hazard communication. Read the full guidance here.