From: Monona Rossol <actsnyc**At_Symbol_Here**cs.com>
Re: New Silica Standard--air monitoring
Ralph: can we start a new thread?
I just read the new Silica Standard and unless I'm missing something it looks like most universities and colleges with an art department will be doing some silica monitoring before June 23, 2018.
In order not to do a written program and medical surveillance, you can be exempted if you have "objective data demonstrating that employee exposure to respirable crystalline silica will remain below 25 micrograms per cubic meter of air (25 ug/m3) as an 8-hour time-weighted average (TWA) under any foreseeable conditions." 1910.1053(a)(2)
The kicker is "any foreseeable conditions" since they do such crazy things there. And if your school mixes clay from scratch from 50 pound bags of powdered clay, ooops. Or if they sand dry clay, mix glazes without local exhaust, if custodians clean up with a broom, etc., that may mean you will be writing another program and doing medical surveillance by 2018.
While the PEL is 50 ug/m3, the action limit for the exemption is 25 ug/m3.
Same goes for stone sculpture, some types of ceramic shell casting, jewelry and metal workers use of investment mold materials (~80% respirable silica), and on and on.
Always the bearer of glad tidings I remain,
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062
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