As reported previously, the Occupational Safety and Health Administration (OSHA) issued a Notice of Proposed Rulemaking in 2013 concerning worker exposure to silica. Silica is a naturally occurring mineral; it also is a known human carcinogen. For the roofing industry, silica is a concern primarily with tile roof applications and concrete pavers (when the materials need to be cut). We know exposure levels with these activities can be problematic.
We also know previous OSHA regulations have worked. In fact, there has been a dramatic decline in illness resulting from worker exposure to silica during the past decade; some of the decline is no doubt attributable to increased attention being paid to the issue.
Still, OSHA's new notice fails to provide any flexibility to employers for reducing exposures. As the rule is proposed, employers would be required to use engineering controls first and always before being able to provide respiratory protection. For our industry, engineering controls essentially include wetting and vacuuming, two activities that not only are infeasible but also are likely to introduce new hazards, such as slipping. Imagine roofing workers, already required to wear fall-protection equipment, having to maneuver around vacuum lines or hoses.
And respirators are not much better. In some cases, the proposed rule would require they be worn even when engineering controls are being used. We know respirators impair vision, cause shortness of breath and are just plain miserable on a hot summer day. And, of course, OSHA has a separate standard regulating respirator use.