Regulated Areas Concerning Silica Activities
With the recent silica standards being put into full effect, many companies who work with respirable crystalline silica have been solving the problem of how to create regulated areas for workers and non-workers of silica. However, some may run into problems whether it is due to lack of space or regular maintenance tasks performed in an area that require the regulated area to be set. In this letter OSHA explains that “Regulated areas can also be associated with intermittent or temporary activities. For example, an area could be a regulated area on days when a particular silica-generating activity causes exposures to exceed the PEL. However, on other days, when that activity is not occurring and exposures do not exceed the PEL, and are not reasonably expected to exceed the PEL, employers do not need to treat the area as a regulated area. Thus, the key determination is whether employee exposure in the area exceeds the PEL or can be expected to exceed the PEL.” So employers may set up specified regulated areas but the company may choose to de-regulate the area as long as it is reasonably expected exposures are to be below the PEL. If unsure, companies should conduct sampling to ensure that they are below the PEL before de-regulating silica areas.
Read the full letter of interpretation for more information