Cal-OSHA News

California appears to be leading the way when it comes to Dust Suppression in the work place.

Cal-OSHA has proposed standards for dust control in the work site. These standards are directed towards the use of powered tools or equipment to cut, grind, core, or drill concrete or masonry materials. Standards for dust control are listed in Title 8 Section 1530.1.

Environmental Safety Solutions LLC is dedicated to saving lives and protecting the environment. These standards are important to us as they should be to you the American worker.

We have attached highlights of the Cal-OSHA standards. The full version can be found on the Cal-OSHA site.

Cal-OSHA Highlights

Subsection (a) Scope & Application

 "directed to the use of powered tools or equipment to cut, grind, core, or drill concrete or masonry materials." "exceptions are listed to exclude certain activities that fall within the stated scope and application. These operations are proposed to excluded either because they are believed not to present significant risk of exposure to silica and other dust above applicable PELs or, the information on their potential for excessive exposures is limited." "contains a note clarifying that the proposed standard does not preclude application of other Title 8 requirements applicable to operations covered by the proposed standard.  "This note is necessary to fully inform employers that compliance with the proposed standard does not negate their responsibility to be aware of and to comply full with other Title 8 sections applicable to control of dust from operations conducted on concrete and masonry materials.

 Concrete or Masonry Material - "unless evidence is presented by the employer that a mixture or material that is stone-like in appearance and texture and otherwise appearing to be within the proposed definition does not contain any of a number of materials know to contain crystalline silica, the material shall be presumed to be concrete or masonry material and therefore within the scope and application of the standard."

Powered Tools or Equipment - "the term means tools in which the motive force that disrupts concrete or masonry is provided by a source other than human energy." Dust Reduction System - "means the application of either water or local exhaust ventilation to reduce airborne dust generated by the use of powered tools or equipment.

 "states the basic requirement around which the entire proposed standard is centered that during operations covered by the stand a dust reduction system be applied to effectively reduce employee exposures to airborne particulate. These engineering controls are the primary methods available to control exposure to dust generated by the covered operations.

"3 exceptions to this requirement 1st "to exclude operations that have been shown to be unlikely to exceed the PEL for silica dust as demonstrated reliably by air sampling data applicable to the specific operations being performed. These operations are excluded because sampling has demonstrated that they do not require the protective measures called for by this proposed standard."2nd "is for roofing operations with roofing tile, roofing pavers, or similar materials. This exception is based on a conclusion that the prospect of using dust reduction systems appears at this time, considering the currently available technology and lack of information about it compatibility with roofing operations, to raise legitimate concerns about its feasibility, effectiveness, and susceptibility to creating slipping, tripping, and falling hazards when used in conjunction with roof work on structures where fall distances can be fatal or seriously injurious.

"3rd "emergency operations of significant importance, as described in the proposed subsection, where the requirements of this subsection could impair the timeliness of initiation of such an operation. This exception would applicable only to the first 24 hours of the emergency operation."

Subsection (d)(1) "requires that procedures be implemented to ensure that dust reduction systems maintain their effectiveness for dust reduction throughout the work shift. This subsection is necessary to ensure that measures are taken to ensure that dust reduction system

Subsection (d)(2) "requires that dust reduction systems used to comply with requirement of subsection c be installed, operated, and maintained in accordance with manufacturer recommendations to the extend they exist... "some dust reduction systems, particularly water systems, ay be fabricated by employers, and thus there may not be any manufacturer recommendations."

Subsection (d)(3)" requires that local exhaust ventilation systems be designed, tested , maintained, used, and the waste materials they collect disposed of, in compliance with applicable requirements of Section 1530 and 5143.

Subsection (d)(4)"requires that where electrical tools are used with water as a dust reduction system this be done in accordance with applicable requirement of the Electrical Safety Orders. This requirement is necessary to ensure that electrical tools used with water as a dust reduction systems do no create an electrical hazards.

Subsection (e)(1) Employee Training "requires an employer whose operations include using powered tools or equipment to cut, grind, core, or drill concrete or masonry materials provide training to all employees prior to their assignment to jobs or work areas where the employer is conducting operations." In addition to training prior to assignment to covered operations, this subsection would also require that employers conduct the training required by this section at least annually.

HIGHLIGHTS Control of Dust Exposure from Concrete and Masonry Operations Section 1530. 1

Comments from the INITIAL STATEMENT OF REASONS SUMMARYOSHSB

Comments from the FINAL STATEMENT OF REASONSSUMMARYOSHSB

"concrete or masonry" title is changed to promote internal consistency and clarity Exception 7...add the work "powered" before shears to clarify operation to which the exception applies

Exception 1 modified to make it clear that PPE is not to be considered in the exposure assessment.

Comment: Fed OSHA has no specific dust reduction criteria during concrete and masonry activity, therefore, the proposed stand is more effective than the federal standard.

Subsection (e)(2)Supervisor training...prior to engaging in supervision of employees who will be cutting, grinding, drilling or coring concrete or masonry materials takes place, supervisory employee be provided the same training required for non-supervisory employees as state in subsection (e)(1). In addition, they would require to received training on how to identify the tasks employees will perform that may result in exposure to concrete or masonry dust, and the procedure for implementing the measure used by the employ to reduce these dust exposures. This subsection is necessary to ensure that supervisory personnel are able to carry out fully and effectively their responsibilities to supervise employees in a manner consistent with the requirements.

Subsection (e)(3)Periodic training....employers with operations covered by the standard conduct the training required at least annually.

Exception 2 applies only to roofing operations with roofing tile, roofing pavers, or similarly materials where such operations cannot be conducted safely. When employees work on scaffolds, on the ground, or on other surfaces on which dust control measures do not significantly increase physical safety risk, the exception is not warranted. The exception has been modified by substituting "rooftop" for roofing". Employers must be mindful tha even if they cannot feasibly conduct these operations on surfaces other than roof surfaces, they are still obligated by Section 5155 to control employee exposures to hazardous dusts.

Oral Comments Public Hearing Dec. 13,2007 Response to Board Member Frisch

Subsection (e)(1)(B). clarify the originally proposed term "process isolation." The term is to be modified to "isolation of the process," this clarifies that it refers to the use of distance, enclosure or other methods to physically remove the process of concern, as applicable, from the immediate proximity of the operator or other employees.