Table 1 vs Objective Data – OSHA Silica Rules

Concrete Dust Cloud

Now that we are less than a month away from the September 23rd deadline we are seeing a lot more interest about the new OSHA Silica Rules which is good that people are taking this seriously. One of the big debates that has recently popped up, some manufacturers are telling their own customers that they will not support “Objective Data” and everything must be “Table 1”. This is also a commitment to not look at all the options for the safest possible solutions or to develop new tools/solutions in many key areas. The good news is OSHA (the people who make the decisions) wrote a pretty clear 26 page document §1926.1153 which provides 3 ways to be compliant for companies who will continue to innovate in this space; Table 1, Objective Data and Self-Monitoring Program.   

Why would OSHA offer 3 ways to meet the standard and not just Table 1? We certainly cannot speak to their exact reasoning but if their goal is to protect as many workers as possible from exposure to crystalline silica dust and to keep all exposure levels to a minimum (Action Level: 25 μg/m³ over an 8-hour period) clearly providing multiple ways to achieve these targets helps in meeting that big picture goal of a safer work place. With multiple ways to meet the standard it means tool manufacturers and inventors can continue to develop new solutions all with the same goal to further protect its users and provide even lower levels of exposure moving forward.

One example in Table 1 “Equipment/Task” list is “(ii) Handheld power saws (any blade diameter)” the only option for an “Engineering and Work Practice Control Methods” provided in Table 1 is “Use saw equipped with integrated water delivery system that continuously feeds water to the blade. Operate and maintain tool in accordance with manufacturer’s instructions to minimize dust emissions.” Does this mean OSHA does not want anyone to invent new 4″, 7”, 10”, 12”, 14” or larger saws for concrete, tile, etc that can collect all the silica dust with an integrated vacuum solution? Probably not, however at the time Table 1 was written perhaps not enough solutions existed that showed this would consistently and universally meet their standards. The goal is to protect more workers from exposure to crystalline silica so if new products could do this better they should be considered. This seems like a very logical reason as to why “Objective Data” would be part of §1926.1153 to create a clear and necessary path to meet compliance for new tools, equipment and technologies.

Table 1 compliance control methods is of course always a great option and easier for everyone. It is possible Table 1 could be updated in the future with new products and solutions like “vacuum handheld power saws” but only once proven they can safely and consistently protect the work force. That will only happen by those manufacturers who use both Table 1 & Objective Data bring them to the market. Through focus on end-users safety, continued develop, test, retest and prove they can provide better user experiences while exceeding OSHA’s silica standards.

To meet the Objective Data qualifications is not a simple process and you should not necessarily trust “Objective Data” testing from anyone, without the proof. There is a lot of work behind doing this in accordance with the OSHA standards; testing, verification, documentation, commitment to record-keeping, updating and making the information easily accessible for the public but if done correctly it should be very easy on the end-users. Here is an example that is done correctly, from Milwaukee Tool one of their Objective Data Fact Sheets but many manufacturer’s from various industries are all using Objective Data for their compliant products.

Objective Data Sheet Milwaukee

It would be easier for all tool manufacturers to simply say they will only use Table 1 but again that is also a commitment to not innovate and look for all the possible options for safer, faster and more user friendly tools/solutions which we don’t want to see. Hopefully tool manufacturer’s will not turn off innovation possible though “Objective Data” simply because it’s easier, users certainly want to see options of vacuum solutions for all these categories not covered in Table 1 (i) Stationary masonry saws, (ii) Handheld power saws (any blade diameter), (iii) Handheld power saws for cutting fiber-cement board (blade diameter of greater than 8 inches), (iv) Walk-behind saws, & (vi) Rig-mounted core saws or drills. If your company chooses not to be a leader in silica safety and makes the commitment not to work towards solutions in any of these areas that is fine. But please don’t work against those companies who are actively working to bring new, better, safer products to market that comply with OSHA’s standards.

We recently interviewed Dianne from Safex on the topic of Silica Compliance, company assessment and monitoring check out the video below for more on that topic. See our full post on that topic here.

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