On occasion, construction employees remove and clean filters used in dust collection systems and dispose of the dust, as appropriate. Are there specific engineering or work practice controls employers must implement during this task?

No. The standard does not specify the engineering or work practice controls to be used during filter cleaning and dust disposal. The tasks of filter cleaning and dust disposal are not separately listed on Table 1, but will often be performed as part of a Table 1 task. An employer following Table 1 must operate and maintain the relevant tool in accordance with the manufacturer’s instructions to minimize dust emissions, which may include instructions for removing and cleaning filters and disposing of dust.

In some circumstances, the employee cleaning the filter and disposing of the dust may not be performing the task that is being done in accordance with Table 1. In such cases, unless employee exposure will remain below 25 μg/m3 as an 8-hour TWA under any foreseeable conditions, the employer must comply with paragraph (d) (alternative exposure control methods), which includes assessing the exposures of employees who are or may reasonably be expected to be exposed at or above the AL and ensuring that employees cleaning filters and disposing of dust are not exposed to silica above the PEL. See 29 C.F.R. § 1926.1153(a), (d).

Generally, filters and dust should be handled so as to minimize worker exposures to silica dust. This could involve disposing of filters and dust in sealed containers, such as heavy-duty plastic bags, to prevent the release of dust into the air. Employers must also ensure that filter cleaning and dust disposal are covered in their written exposure control plans, when required by paragraph (g)(1)(i).