If a commercially-available dust-suppression sweeping compound contains crystalline silica, does the standard permit employers to use it in conjunction with dry sweeping and brushing? Read More If a commercially-available dust-suppression sweeping compound contains crystalline silica, does the standard permit employers to use it in conjunction with dry sweeping and brushing?
Does the standard prohibit the use of commercially-available dust-suppression sweeping compounds in conjunction with dry sweeping and brushing? Read More Does the standard prohibit the use of commercially-available dust-suppression sweeping compounds in conjunction with dry sweeping and brushing?
Under the standard, an employer may not allow the use of dry sweeping or dry brushing where such activity could contribute to employee exposure to silica unless wet sweeping, HEPA-filtered vacuuming, or other methods that minimize the likelihood of exposure are not “feasible.” 29 C.F.R. § 1926.1153(f)(1). The standard contains a similar prohibition on the use of compressed air to clean clothing or surfaces; such use is prohibited unless the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air or “[n]o alternative method is feasible.” 29 C.F.R. § 1926.1153(f)(2). What is the definition of “feasible” in this context? Read More Under the standard, an employer may not allow the use of dry sweeping or dry brushing where such activity could contribute to employee exposure to silica unless wet sweeping, HEPA-filtered vacuuming, or other methods that minimize the likelihood of exposure are not “feasible.” 29 C.F.R. § 1926.1153(f)(1). The standard contains a similar prohibition on the use of compressed air to clean clothing or surfaces; such use is prohibited unless the compressed air is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air or “[n]o alternative method is feasible.” 29 C.F.R. § 1926.1153(f)(2). What is the definition of “feasible” in this context?
Does the standard prohibit an employer from using compressed air as part of a task not related to cleaning clothing or surfaces? Read More Does the standard prohibit an employer from using compressed air as part of a task not related to cleaning clothing or surfaces?
If employee exposure will remain below the AL of 25 μg/m3 as an 8-hour TWA under any foreseeable conditions, does the prohibition on dry sweeping, dry brushing, and the use of compressed air for cleaning clothing and surfaces apply? Read More If employee exposure will remain below the AL of 25 μg/m3 as an 8-hour TWA under any foreseeable conditions, does the prohibition on dry sweeping, dry brushing, and the use of compressed air for cleaning clothing and surfaces apply?
Can an employer use the scheduled monitoring option, but then switch to the performance option? Read More Can an employer use the scheduled monitoring option, but then switch to the performance option?
Under the scheduled monitoring option, do employers have to monitor exposures every time a new job is started (and thus a new work area is created)? Read More Under the scheduled monitoring option, do employers have to monitor exposures every time a new job is started (and thus a new work area is created)?
For alternative exposure control methods, the standard requires employers to assess the exposure of each employee who is or may reasonably be expected to be exposed to silica at or above the AL using either the performance option or the scheduled monitoring option. See 29 C.F.R. § 1926.1153(d)(2)(ii) & (iii). If an employer reasonably expects its employee’s exposure to remain below the AL, does the standard require the employer to assess that employee’s exposure using one of these two options? Read More For alternative exposure control methods, the standard requires employers to assess the exposure of each employee who is or may reasonably be expected to be exposed to silica at or above the AL using either the performance option or the scheduled monitoring option. See 29 C.F.R. § 1926.1153(d)(2)(ii) & (iii). If an employer reasonably expects its employee’s exposure to remain below the AL, does the standard require the employer to assess that employee’s exposure using one of these two options?
Does an employer using alternative exposure control methods for compliance have to conduct sampling of all employees performing all job tasks? Read More Does an employer using alternative exposure control methods for compliance have to conduct sampling of all employees performing all job tasks?
