On February 4, 2020, OSHA published an updated National Emphasis Program (NEP) regarding Respirable Crystalline Silica (RCS)
OSHA studied over 10 years of data and tens of thousands of air samples for silica. The results were shocking. 14.1% of personal air samples from at-risk work areas registered above the acceptable Permissible Exposure Limit (PEL). After a revised silica rule introduced in October of 2017, OSHA conducted a follow up 1-year study and found that the silica exposure rate for that year was even higher with 17.6% of samples registering above PEL.
This increasing rate of non-compliance with existing silica rule means exposure to silica continues to be a very serious risk to a large percentage of the construction workforce.
As a result, OSHA has deemed that this new NEP is necessary to move towards compliance to the 2016 standards for general industry, maritime and construction.
From now on, 2% of inspections each year will target silica exposure. OSHA expects most of these to occur in construction.
The new NEP requires inspectors to increase their focus on RCS exposure and OSHA will be providing its field agents with some new tools and methods to determine the most likely targets for inspection.
Master Lists will be generated using NAICS codes (North American Industry Classification System). It should be noted that there are four trades being added to the NAICS codes up for inspection:
- 237130 - Power and Communication Line and Related Structures Construction
- 238170 – Siding Contractors
- 238320 - Painting and Wall Covering Contractors
- 238390 - Other Building Finishing Contractors
The OSHA Field Operations Manual lists four priority levels for inspections:
- Imminent Danger
- Programmed Inspections