News & Press: General

The Silica Rule is Coming! Are You Prepared, or Is Your Head Buried in the Sand?

Friday, February 2, 2018   (0 Comments)
Posted by: Erin Russell
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With the defeat of the legal challenge against the Silica Rule in December 2017, non-ferrous foundries now have certainty that the Silica Rule (and its June 23, 2018 compliance date) is the law of the land. NOW is the time to begin work on your own silica program if you have not already done so. To help define the path forward, here are the steps you should be thinking about, and how NFFS can help:


1) Review your existing ventilation system design and operations. Prior to conducting ANY air sampling in your foundry, you will always want to review your ventilation system to ensure it is operating properly. A faulty or poorly operating system can cause bad sampling results, indicating overexposures that may not exist when the system is properly functioning. Remember, you can NEVER throw away sampling data, even if you discover ventilation system performance issues after the test is conducted!


2) Conduct air sampling for respirable silica. Do not be lured into complicated and expensive zone sampling for silica! Many other industry associations and private firms are recommending zone sampling and software, usually at price points well over $10,000. NFFS is strongly recommending to its members that you perform sampling based on the job description and not a specific area. Failure to follow this advice can result in the regulation of entire areas within the foundry, such as the cleaning department, when simply controlling exposures for specific jobs in that area may suffice. If you need help in conducting your own air sampling for silica, or recommendations on outside firms, contact NFFS.


3) Implement feasible engineering controls. For areas where you have employee exposure levels above the Permissible Exposure Limit (PEL) of 50 μg/m3, you will need to implement all feasible engineering controls before you consider personal protective equipment such as respirators. NFFS and its Silica Steering Committee have developed guidance documents to help the foundry determine what is feasible in areas that could have exposure levels above the PEL. These documents are FREE and available only to NFFS members on our website. This is a complex area, and implementing engineering solutions could take many months depending on the needs for new ventilation controls and air permits, for example.


4) Develop a written Silica Control Plan. Just like other airborne contaminants, such as lead, a written control plan is required that defines your foundry’s efforts to protect employees from respirable silica. NFFS is actively working on a template silica control plan for its members, and expects to have this available for NFFS members by the beginning of March 2018.

NFFS has a long and proven track record of assisting our members with compliance with OSHA regulations. Just like NFFS did for its members with the Lead Remand back in the 1980s, NFFS has what your foundry needs to comply with the new rule in the most efficient and cost-effective way possible. You simply cannot wait any longer to begin focusing your foundry on compliance with the new rule. If you have any questions on where to start, you should call NFFS immediately!

Silica resources for NFFS members are available at www.nffs.org/silica.


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