The written exposure control plan must describe the tasks that involve silica exposures in sufficient detail to enable the employer and employees to consistently identify and control silica- related hazards. See 29 C.F.R. § 1926.1153(g)(1)(i); 81 Fed. Reg. at 16800-1. Thus, for example, if the materials being disturbed or the conditions under which the tasks are performed are relevant to the level of exposure related to a particular task, that information must be included (e.g., using a stationery saw outdoors to cut concrete). The standard permits construction employers to develop a single comprehensive plan that includes all of the tasks the employer will perform on all of its worksites. However, using a broad term that could describe multiple tasks, such as “construction” or “demolition,” would not be sufficiently descriptive.
Note that in addition to describing the silica-generating tasks, the exposure control plan must also include a description of the engineering controls, work practices, and respiratory protection used to limit exposure to respirable crystalline silica. See 29 C.F.R. § 1926.1153(g)(1)(ii).
October 2018
Tags: OSHA, Exposure Control Plan