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Is an employer following Table 1 required to “minimize dust emissions”? What does it mean to “minimize dust emissions” in this context?

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  • Is an employer following Table 1 required to “minimize dust emissions”? What does it mean to “minimize dust emissions” in this context?

Although many of the entries on Table 1 require employers to “[o]perate and maintain” tools “in accordance with manufacturer’s instructions to minimize dust emissions,” 29 C.F.R.
§ 1926.1153(c)(1)(i)-(vii), (x)-(xiii), (xvi), or to “[o]perate and maintain machine[s] to minimize dust emissions,” 29 C.F.R. § 1926.1153(c)(1)(xiv)-(xv), the standard does not separately require employers to minimize dust emissions. An employer generating a limited amount of dust when engaging in a task listed on Table 1 would not be in violation of the standard if it is fully and properly implementing the engineering controls, work practices, and respiratory protection specified on the Table (including operating and maintaining controls so as to minimize emissions). A small amount of dust can be expected even with new equipment that is operating as intended by the manufacturer. However, a noticeable increase in dust emissions may indicate that the dust control system is not operating properly.


October 2018

Tags: OSHA, Exposure Control Methods

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