Article Date: 09/13/2013

How Much Should It Cost to Protect Construction Workers from Respirable Crystalline Silica?

By Steve Rizer


The federal government’s new proposal for reducing the incidence of silicosis among construction workers already has spawned estimates about what it would cost to comply with the plan -- if it is adopted in its current form -- and the number of lives it would save. Various construction associations have shared their projections -- and complaints -- about the approximate amount of money it would take to ensure compliance, and the U.S. Occupational Safety and Health Administration (OSHA) has unveiled its statistical projections of the plan’s potential human health dividend. What ought to be the proper balance?


The National Association of Home Builders, a member of the Construction Industry Safety Coalition (CISC), recently cited independent studies estimating that compliance with the rule, which is intended to reduce workers’ exposure to respirable crystalline silica, would cost the construction industry more than $1 billion per year.


When ConstructionPro Week (CPW) asked Pete Stafford, Safety & Health Director, Building and Construction Trades Department, AFL-CIO, for his organization’s estimate of the proposal’s potential cost impact, he said, “At the current time, many employers of all sizes recognize that the methods needed to control silica are not overly burdensome, and some have also recognized that controlling dust at the source is cost effective in terms of extending the life of tools. We expect there to be a great deal of information that comes to light during the public rulemaking on the cost estimates that OSHA has used in its economic analysis, and this information will be used by the agency as they determine the economic feasibility of the final rule.”


As for the plan’s projected human health benefit, OSHA predicted that the rule will save more than 560 lives and prevent roughly 1,080 cases of silicosis among construction workers once the full effects of the measure are realized.


But all of these estimates are far from carved in stone.


In unveiling the proposal late last month, OSHA stressed that “this is a proposal, not a final rule. [We encourage] the public to participate in development of the rule by submitting comments and participating in public hearings. Your input will help OSHA develop a rule that ensures healthy working conditions for employees and is feasible for employers.”


And changes will be made, if CISC member American Subcontractors Association (ASA) has its way. ASA reported that it is “reviewing and studying” the 577-page proposal with its advisers “in order to submit informed comments to OSHA to help the agency revise the rule to better help contractors protect the health and safety of their employees.”


As currently envisioned by OSHA, the construction standard would require employers to do the following:

  • Measure the amount of silica that workers are exposed to if it may be at or above an action level of 25 μg/m3 (micrograms of silica per cubic meter of air), averaged over an eight-hour day.
  • Protect workers from respirable crystalline silica exposures above the permissible exposure limit (PEL) of 50 μg/m3, averaged over an eight-hour day.
  • Limit workers’ access to areas where they could be exposed above the PEL.
  • Use dust controls to protect workers from silica exposures above the PEL.
  • Provide respirators to workers when dust controls cannot limit exposures to the PEL.
  • Offer medical exams, including chest X-rays and lung function tests, every three years for workers exposed above the PEL for at least 30 days per year.
  • Train workers on work operations that result in silica exposure and ways to limit exposure.
  • Keep records of workers’ silica exposure and medical exams.

OSHA asserted that the proposed standard would provide “flexible alternatives, especially useful for small employers. Employers can choose to measure their workers’ exposure to silica and independently decide which dust controls work best in their workplaces.”


Silicosis, which crystalline silica dust is suspected of causing, is considered to be an incurable and progressive disease that can cause lung cancer, chronic obstructive pulmonary ailment, and kidney disease. Exposure to airborne silica dust occurs in operations involving cutting, sawing, drilling, and crushing of concrete, brick, block, and other stone products and in operations using sand products, such as in glass manufacturing, foundries, and sand blasting, according to the OSHA.


The ConstructionPro Network member version of this article includes transcripts of CPW's interviews with Stafford and ASA Chief Advocacy Officer Colette Nelson on this topic, as well as a link to the proposal. To sign up for a membership, click here.  



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