This article is from RISQ Consulting’s Zywave client portal, a resource available to all RISQ Consulting clients. Please contact your Benefits Consultant or Account Executive for more information or for help setting up your own login.
On Sept. 22, 2023, the Occupational Safety and Health Administration (OSHA) launched a new initiative focused on enhancing enforcement and providing compliance assistance to protect workers in the engineered stone fabrication and installation industries. This policy is effective as of the date of this memorandum and will be ongoing until otherwise directed.
Silica Hazard
OSHA and the National Institute for Occupational Safety and Health identify silica dust exposure as a health hazard for workers involved in manufacturing, finishing and installing natural and manufactured stone, including man-made, engineered artificial and cultured types of stone.
When inhaled, tiny crystalline silica particles expose workers to the risk of silicosis, an incurable, progressively disabling and sometimes fatal lung disease. Unsafe silica dust exposure can also lead to chronic obstructive pulmonary disease or kidney disease.
Compliance Initiative Overview
Supplementing OSHA’s current National Emphasis Program for Respirable Crystalline Silica, this initiative focuses enforcement efforts on industry employers to ensure they’re following required safety standards and providing workers with the protections required to keep them healthy. It establishes procedures for prioritizing federal OSHA inspections to identify and ensure prompt abatement of hazards in covered industries where workers face exposure to high levels of silica dust.
Industries subject to the prioritized programmed inspections include those engaged in cut stone and stone product manufacturing, as well as brick, stone and related construction material merchant wholesalers. Outreach efforts will continue to include additional industries that may work with engineered stone. Programmed inspections will be prioritized in the following two NAICS codes:
- 327991 – Cut Stone and Stone Product Manufacturing; and
- 423320 – Brick, Stone, and Related Construction Material Merchant Wholesalers.
OSHA area offices will focus enforcement efforts on these two NAICS codes using the targeting and site selection procedures outlined below. This initiative requires each area office in regions 1 through 8 to complete a minimum of five programmed inspections (i.e., targeting sites selected from NAICS 327991 and 423320) of establishments working with engineered stone within 12 months from the date of this initiative.
Workers involved in manufacturing, finishing and installing manufactured stone countertops are at risk for significant crystalline silica exposure. Facilities in NAICS codes 327991 or 423320 may be selected for inspection under this initiative if they meet one of the following criteria for work processes:
- Manufacturing and/or finishing engineered or manufactured stone products at the facility; and
- Finishing and/or installing engineered or manufactured stone products off-site.
Activities occurring at manufacturing, finishing engineered or manufactured stone facilities include:
- Cutting, grinding, chipping, sanding, drilling and polishing engineered or manufactured stone products
- Opening bags of ground quartz, moving or mixing bulk raw materials, cleaning and scraping mixers, or cleaning dust collector bag houses
- Changing filters on dust collectors
- Making the engineered or cultured slabs—involves mixing crystalline silica, resins and pigments
- Operating powered hand tools such as saws, grinders and high-speed polishers
- Casting departments that mix and heat raw materials, including silica sand (which comprises more than 70% of each countertop by weight), epoxy resin, PA (a known respiratory sensitizer) and pigments
Employer Next Steps
Affected employers and stakeholders should become familiar with this OSHA initiative by studying the memorandum and the fact sheets on dust control methods and safer work practices for engineered stone manufacturing, finishing and installation operations. These employers should also review the OSHA silica standards and ensure their operations comply with the required regulations and prevent employee exposure to silica.
