The guidelines are noteworthy for roofing contractors because they cover everything from exposure assessments to methods of compliance including the medical surveillance provisions. It also lays out possible penalties for failing to comply.

“During the first 30 days of enforcement, OSHA will offer compliance assistance for employers who make good faith efforts to comply with the new standard,” the organization said in a recent press release. “OSHA intends to issue interim enforcement guidance until a compliance directive on the new standards is finalized.” 

In a June 7 memorandum, Galen Blanton, acting deputy assistant secretary, OSHA, provided additional detail.

“If upon inspection, it appears an employer is not making any efforts to comply, compliance officers should conduct air monitoring in accordance with Agency procedures, and consider citations for non-compliance with any applicable sections of the new standard,” Blanton said in the memorandum. “Any proposed citations related to inspections conducted in this 30-day time period will require National Office review prior to issuance.”

The key provision of the rule with the greatest potential impact to roofing contractors is the reduction of the allowable exposure limit from 250 to 50 micrograms per cubic meter of air averaged over a traditional eight-hour shift.

Among other things, the standard also requires employers to:

• Assess employee exposures to silica if it may be at or above an action level of 25 µg/m3 (micrograms of silica per cubic meter of air), averaged over an 8-hour day;
• Protect workers from respirable crystalline silica exposures above the permissible exposure limit (PEL) of 50 µg/m3, averaged over an 8-hour day;
• Limit workers' access to areas where they could be exposed above the PEL;
• Use dust controls to protect workers from silica exposures above the PEL;
• Provide respirators to workers when dust controls cannot limit exposures to the PEL;
• Use housekeeping methods that do not create airborne dust, if feasible;
• Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers;
• Offer medical exams - including chest X-rays and lung function tests - every three years for workers exposed at or above the action level for 30 or more days per year;
• Train workers on work operations that result in silica exposure and ways to limit exposure; and
• Keep records of exposure measurements, objective data, and medical exams.