Concrete and brick manufacturers are preparing for increased federal scrutiny when the Occupational Safety and Health Administration’s regulations protecting workers from the potentially fatal lung disease silicosis become enforceable.
While construction contractors have had to comply with the breathable silica regulations since September 2017, companies manufacturing building materials have until June 23 to meet the mandate.
“This is something we’ve been talking about for a long, long time,” Ty Gable, president of the National Precast Concrete Association in Carmel, Ind., told Bloomberg Environment.
OSHA had predicted in 2016 that when the rule became fully implemented across industries, including construction and manufacturing, it would save 642 lives annually and prevent 918 moderate to severe cases of silicosis, a disease caused by silica scarring the lungs. It’s expected to cost the concrete and brick makers about $43.3 million annually to comply.
The U.S. Chamber of Commerce had challenged OSHA’s cost estimates as too low.
The covered industries include precast concrete fabricators, companies producing and delivering ready-mix concrete, and brick kilns. In size, employers range from international producers Boral Ltd. and LafargeHolcim Ltd. to family-owned plants employing 20 people.
OSHA issued the silica rule in 2016 after more than a decade of debate. The requirements cut by 50 percent the amount of airborne silica to which manufacturing workers can be exposed. A federal appeals court in North America’s Building Trades Unions v. OSHA upheld the stricter OSHA requirements on Dec. 22, 2017.
Construction Material Focus
While the silica rule covers all general industry work sites—from clothing stores to auto plants—OSHA put the concrete and brick industry on notice that it believed their workers were among those mostly likely to be exposed to silica dust.
When OSHA inspects the work sites, management may be expected to prove that air samples were taken to measure silica levels and show precautions taken.
Gary Mullings, executive vice president of operations and compliance for the National Ready Mix Concrete Association in Silver Spring, Md., told Bloomberg Environment that while the association objected to OSHA’s designation, employers are preparing to comply.
With 100 sites around the country, LafargeHolcim is one of the largest ready mix concrete producers.
The company will have completed employee training and written compliance plans for all of its ready mix sites by June 23, Dave Dziubinski, the Chicago-based head of health and safety for the company’s U.S. aggregates construction material operations, , told Bloomberg Environment.
Mullings said the first step to comply is an assessment of a plant, determining where silica levels exceed OSHA exposure levels. While larger companies have the staff to perform the work themselves, owners of smaller plants often call in consultants to take air samples.
In virtually all the plant samplings he’s aware of, Mullings said, measurements were below levels at which OSHA requires companies to take preventative actions.
Several factors lead to that, Mullings said: The sand containing silica used at ready-mix plants isn’t fine enough to easily produce dust, ready-mix plants typically have vacuum systems to satisfy clear air environmental regulations, and ready-mix concrete is delivered wet—“plastic” in industry terms—to customers.
Where dust exposure is an issue, Dziubinski said, water misters and vacuum systems are common ways to limit airborne silica.
One potentially hazardous job is cleaning the inside of truck-mounted drums by chipping away dried concrete, the OSHA rule said.
Typically, the drums are cleaned every six months by workers who enter them and chisel away dried concrete, Mullings said. Because the cleaning work is specialized, infrequent, and also requires compliance with OSHA confined space entry rules, contractor cleaning firms often do the work.
While LafargeHolcim contracts out drum cleaning, Dziubinski said, the company expects subcontractors to adhere to the rule’s requirements.
For precast concrete product manufacturers, whose products range in size from concrete blocks to bridge supports, the compliance concerns focus on sawing, cutting, and drilling of concrete components, the National Precast Concrete Association’s Gable said.
Like in the ready mix industry, the first compliance step is measuring silica levels and then taking steps to keep the dust from becoming airborne, often by using water sprays.
“It was something most members were already doing,” Gable said.
Bloomberg Environment contacted the Brick Industry Association and several brick manufacturers. All declined to discuss their preparation or didn’t return calls.
In online materials, the brick association highlights using misters and curtains in production areas to limit dust as well as vacuuming floors, machinery, and paved outdoor storage areas.
The OSHA rule (29 C.F.R. 1910.1053) sets a permissible exposure limit (PEL) for airborne crystalline silica of 50 micrograms per cubic meter of air, half the old general industry standard of 100 micrograms per cubic meter.
The regulation also sets an action level at 25 micrograms per cubic meter, meaning employers must regularly measure exposure if the amount of breathable silica exceeds that level.