Option 1 – Check the Label
OSHA's Respirable crystalline silica standard for the construction industry - 29 CFR 1926.1153 - paragraph (i)(1) Hazard communication states: "The employer shall include respirable crystalline silica in the program established to comply with the hazard communication standard (HCS) (29 CFR 1910.1200). The employer shall ensure that each employee has access to labels on containers of crystalline silica and safety data sheets, and is trained in accordance with the provisions of HCS and paragrapch (i)(2) of this section. The employer shall ensure that at least the following hazards are addressed: Cancer, lung effects, immune system effects, and kidney effects."
OSHA's hazard communications standard (HCS) requires manufacturers or producers of materials, which contain a chemical that can cause health or physical hazards to make users aware of the potential hazard(s) through safety data sheets (also referred to as material safety data sheets) and labels.
For silica, the Standard requires the labeling of materials containing “more than 0.1 percent crystalline silica by weight or volume which have anticipated downstream uses where crystalline silica may become airborne and present an inhalation hazard to employees working with that material.”(Letter of interpretation February 11, 1991)
This label should identify the hazardous material, the type of hazard – health or physical – and the manufacturer, producer, or importer’s name and address. The label must be in English and may also be in another language.
The Standard requires construction employers to “ensure that the label is not removed or defaced.” In addition, employers are required to provide employees who may be exposed to the hazardous material with training and education on how to identify the hazard, protective measures, and an explanation of the label and the safety data sheet.
Update to the Standard …. In March 2012, OSHA revised the Hazard Communication Standard to align it with the United Nations' global chemical labeling system. Under the revised Standard, “Employers are required to train workers by December 1, 2013 on the new labels elements and safety data sheets format to facilitate recognition and understanding.” By 2016, the Health Hazard pictogram shown below will be used to label materials, such as silica, that present a health hazard for users.
Please note: OSHA’s Health Hazard pictogram lists several risks that would require a product to be labeled a Health Hazard. In the case of silica, the two from this list that apply are “Carcinogen” and “Respiratory Sensitizer”.
Health Hazard- Carcinogen
- Mutagenicity
- Reproductive Toxicity
- Respiratory Sensitizer
- Target Organ Toxicity
- Aspiration Toxicity
Note: Workers doing maintenance, renovation, or repair work may be required to work with existing, already installed materials for which no Safety Data Sheets are available. In this situation, it is the employer’s responsibility to make sure the workers are safe and made aware of hazards as required under CFR 1926.20. In addition, it is their responsibility under Subpart C to determine whether materials pose hazards. Until that determination is made, when working with materials known to contains silica, such as mortars, cement, concrete or grout, if possible, engineering controls should be used to avoid generating dust. If not, wear respiratory protection.
To Learn more…
- Letter of Interpretation – September 20, 1988
- Letter of Interpretation – August 21, 1989
- Letter of Interpretation -- February 11, 1991
- Modification of the Hazard Communication Standard (HCS) to conform with the United Nations' (UN) Globally Harmonized System of Classification and Labeling of Chemicals (GHS) –2012 – Questions and Answers --
- What is Hazard Communication?
- Hazard Communication – OSHA Standards
