OSHA posted its Interim Enforcement Guidance for the Respirable Crystalline Silica in General Industry standard, 29 CFR 1910.1053 on June 26, providing interim enforcement guidance to compliance safety and health officers for enforcing the new silica rule for general industry.
AFS recommends metalcasters review the agency’s interim enforcement guidance document, which can be found here: https://www.osha.gov/laws-regs/standardinterpretations/2018-06-25.
OSHA began enforcing its silica rule for general industry on June 23. OSHA will evaluate good faith efforts taken by employers to comply with the new standard during the first 30 days of enforcement. In other words, in these circumstances, citations likely will not be issued for noncompliance. However, if an employer has made no effort to comply, OSHA may inspect, collect air samples and consider employers for citation, but the Washington enforcement office will have to review.
The interim enforcement guidance allows industry to use HEPA filtered industrial sweepers, although employers still need to consider silica exposures related to sweeper use in the exposure control plans. Originally, OSHA had essentially banned sweepers. AFS continues to be involved in ongoing discussions with OSHA attorneys on industrial sweepers, as well as issues related to feasibility.