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CSDA testifies on proposed silica rule

Words: Patrick Abou-chrouchThe Concrete Sawing & Drilling Association (CSDA) continues to be the voice of the concrete sawing and drilling industry and proactively work in the best interests of workers. Representatives from the association recently testified at public hearings at the Department of Labor in Washington D.C. as the Occupational Safety and Health Administration (OSHA) looks to implement its proposed new rule for respirable crystalline silica.

On March 26 and 31 respectively, CSDA Silica Sub-Committee chair, Kellie Vazquez of Holes Incorporated, a contractor based in Houston, Texas, and CSDA Executive Director Patrick O’Brien gave testimony on behalf of the industry. Both provided explanations as to why this rule is just unworkable for the sawing and drilling industry and will be economically unfeasible to implement.

The proposed silica rule, released by OSHA in September 2013, would cut the current permissible exposure limit (PEL) in half, from 100 to 50 μg/m3, and demand the execution of set procedures at or above 25 μg/m3. The arguments made by Vazquez and O’Brien described how silica-related deaths continue to decrease with the existing PEL in place. In 1968, the U.S. Centers for Disease Control and Prevention (CDC) and the National Institute of Occupational Safety and Health (NIOSH) reported silica was a contributing factor in just under 1,200 deaths nationwide. By 2012, the U.S. Bureau of Labor Statistics reported there were just 102 deaths potentially related to silica in the construction industry. It is anticipated that the number will continue to fall as silica dust collection is integrated into more construction-related equipment, while contractors continue to adopt better personal protective equipment policies and invest in improved respiratory devices.

“CSDA has taken a proactive approach to protect workers from possible silica exposure,” stated O’Brien. “Our contractors might be on five or six jobsites in one day and the proposed rule with on-site sampling is not set up to address this unique situation.” CSDA has introduced an analysis chart for contractors that is based upon 10 years of data collection. The data in the chart makes it simple for an operator identify the recommended respiratory protection required for cutting with diamond tools in several environments.

CSDA-BP-016 Silica Data Analysis Chart is based on extremely thorough data collection from member jobsites and from NIOSH. Representatives of NIOSH attended CSDA training classes at St. Petersburg College in Florida, and recognized that the use of water during cutting operations produced very little silica exposure problems for contractors. CSDA-BP-016 is available to anyone in the industry at www.csda.org/?211.
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