4 • ROCK products • May 2016 www.rockproducts.com
C
rystalline silica exposure has been a workplace health concern in
some industries for a long time. No one is debating the seriousness
of the health hazards associated with over-exposure to crystalline silica.
But quite simply, the Occupational Safety and Health Administration's
(OSHA) new silica regulation is overkill. It is not a good example for the
Mine Safety and Health Administration (MSHA) to emulate.
The National Stone, Sand and Gravel Association (NSSGA), in conjunc-
tion with the Georgia Construction Aggregates Association, filed a peti-
tion in the 11th U.S. Circuit Court of Appeals for review of the crystalline
silica rule. The American Road & Transportation Builders Association
(ARTBA) filed suit in the 5th U.S. Circuit Court of Appeals challenging
the final regulation as well.
They are right to do so.
Despite the fact that silica-related illnesses have dropped dramatical-
ly the past four decades, the rule reduces the workplace exposure limit
by half (from 100 micrograms per cu. meter to 50 micrograms per cu.
meter over an eight-hour work shift).
In-the-field evidence has demonstrated that there is no additional
health benefit to further reducing current exposure limits.
The rule is based on outdated health data. In setting the new standard,
OSHA relied on studies from as early as the 1930s. According to the Cen-
ters for Disease Control, deaths due to silicosis have declined 93 percent
over the past 39 years, ARTBA said.
The regulation creates air sampling requirements that are unworkable,
requiring time consuming sampling and testing procedures that will
yield virtually meaningless results, since, by the time the results are
known, the "workplace" location and conditions tested will have moved
and/or changed.
In addition, let's not discount the work the industry already does to
remain in compliance with the current standard. NSSGA regularly part-
ners with MSHA to conduct noise and dust workshops that provide guid-
ance on how to accurately monitor worker exposure to respirable silica.
Also, NSSGA's Occupational Health Pro-
gram aids operators to effectively safe-
guard worker health through exposure
monitoring and medical surveillance.
Let's protect our workers, and without
question, send them home each day in
the same condition they arrived. But lets
not regulate simply to regulate.
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