Less than two weeks ago, OSHA released its final silica rule or permissible exposure limit (PEL). NAPA has reviewed the rule and developed interim guidance for our members and industry on how the rule impacts asphalt pavement mix production and asphalt pavement road construction activities.
Recognizing that roadway milling operations have the potential to create silica-laden dust, NAPA worked for more than a decade with its members, labor, milling machine manufacturers, academia, and government to devise engineering solutions that would control these emissions.
Through its hard work, the Asphalt/Silica Milling Machine Partnership developed efficient solutions to this potential hazard. OSHA recognized the effectiveness of these engineering controls by specifying their use in Table 1 of the standard. Many newer existing milling machines already have these controls in place, and manufacturers have pledged to have them on all half-lane and larger mills starting in January 2017. In addition, retrofits will be made available for many older model milling machines.
NAPA's interim guidance provides an overview of the rule and identifies how OSHA-approved equipment controls can be used to comply with some aspects of the rule. For asphalt pavement road construction activities where OSHA has not identified specific controls, the guidance provides additional information that will assist companies with their compliance efforts.
In addition, NAPA has assembled a small task group to review existing exposure data during various asphalt plant operations and road construction activities. This data will be compiled to better understand potential emissions. The group will also focus on identifying simple controls to help ensure potential exposure is below the newly revised PEL.
The Silica PEL is slated to be effective June 2017 for the construction industry (e.g., milling operations) and June 2018 for general industry (e.g., at an asphalt mix facility).
NAPA will continue to update its members on the status and implementation of the rule.
In addition, OSHA's silica rule webpage includes fact sheets forconstruction and general industry, along with other materials to aid in complying with the new standard.
If there are any questions, please contact NAPA Vice President for Environment, Health & Safety Dr. Howard Marks.