A report recently published in CA Cancer Journal Titled “Silica: A Lung Carcinogen” highlights the latest toxicity information relative to silica and lung cancer. In thinking about silica, its toxicity, and OSHA’s disgraceful regulatory history also brings to mind the many other contaminants that workers are being exposed to that either do not have exposure limits or have inadequate limits.
Silica is, unfortunately, an excellent example of a regulation that has failed to adequately protect workers for over 40 years. It has been known for many years that when workers are exposed to respirable crystalline silica dust they could develop silicosis a disabling lung disease. More recently, epidemiological data has shown that exposure to crystalline silica dust can result in the exposed worker developing lung cancer. The report indicates that silica is not as potent a carcinogen as arsenic or asbestos. However, the sheer volume of workers potentially exposed makes silica exposure a serious occupational health issue.
OSHA is attempting to address the issue by reducing the OSHA Silica Standard to 0.05 mg/m3 which is about half of what is now the general industry standard. The proposed OSHA Silica Standard is two times higher than the current Threshold Limit Value recommended by the American Conference of Governmental Industrial Hygienists (0.025mg/m3).
The proposed OSHA Crystalline Silica Standard will be a major upgrade over the current construction industry standard that was adopted in 1970 when the agency first started. The construction industry Crystalline Silica Standard uses an out dated particle counting method that reported results as millions of particles per cubic foot of air. It required that samples be collected in a liquid media and the collected particles counted under a microscope. The form of the standard (particle counting) was out of date from the moment it was adopted by OSHA. It has been 43 yards and counting since OSHA issued the inadequate standard. It is a disgrace that a standard, that affects so many workers and was out dated since its adoption has still not been updated. How many workers have been disabled or have died in the past 43+ years due to the inadequate regulation? Hopefully, the newly proposed Silica Standard will bring OSHA closer to what toxicologists consider an acceptable exposure level. But OSHA has rules to live by. One rule is that the standard must be economically feasible. In the case of the Silica Standard, that means a compromise. The proposed Silica Standard is better than the current limit but may still be lacking due to the economic feasibility limitation.
All project managers, owners, safety professional and industrial hygienists must look at silica and all OSHA standards as minimum requirements. If changes can be implemented that will reduce the worker exposures to levels below the standard without causing undue economic stress, then by all means, the changes should be made.
Worker health is a long term commitment between workers and management. Small reductions in exposures to any contaminant day in and day out over a working lifetime could make a big difference to the worker’s quality of life as they approach the end of their careers. Will a retired worker be able to climb a flight of stairs, go for a walk, breath normally or be able to do the things they hoped to do during retirement? Those are questions that we all need to address at the start of a career rather than later in life.
Safety is mostly dealing with acute problems such as amputations, falls or thousands of other incidents that have an immediate impact on the workers life. Industrial hygiene deals more with chronic problems that take years to develop, but can be just as devastating as an industrial accident.
Industrial hygienists must become more involved.They need to become an integral member of the management team. Safety audits are done almost daily on construction projects and industrial facilities. It is equally important that industrial hygiene audits be done on a regular basis (weekly, monthly, semi annually) on all major construction projects and industrial facilities by a qualified industrial hygienist. The IH can identify hazards that may go unnoticed, prevent major exposures that could violate OSHA standards or minimize smaller, unnecessary exposures that accumulate over a lifetime to create an occupationally induced disease.
Often times problems exist that managers are not aware of. A qualified IH working as part of the management team can identify problems and recommend solutions. If used properly the IH adds value to a management team.
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