If you are in the countertop industry you have most likely heard about silicosis.
The issue has come to the forefront since Australia decided to ban quartz (effective July 1, 2024) and Cal-OSHA implemented their ETS in December of 2023.
So what is Silicosis?
The American Lung Association defines silicosis as “a type of pulmonary fibrosis, a lung disease caused by breathing in tiny bits of silica a common mineral in sand, quartz, and many other types of rock. Over time, exposure to silica particles causes scarring in the lungs which can harm your ability to breathe.”
NOTE: Silicosis develops from Silica exposure over time. Could someone develop Silicosis from breathing in Silica one time? Perhaps, but it would be extremely rare and the individual would most likely have another health issue that accelerated the disease. If someone develops Silicosis, it is because they have been exposed to Silica for long periods of time.
As an employer your responsibility is to protect your employees and provide them a safe place to work.
You can learn more about silicosis here:
https://www.lung.org/lung-health-diseases/lung-disease-lookup/silicosis
https://www.webmd.com/lung/what-is-silicosis
The bottom line is Silicosis is on the radar. People have died due to carelessness in the workplace and now California is cracking down on the situation. If you are a fabricator in California, it is not a matter of “if” you get an OSHA inspection, but “when” you get an inspection. It would be wise to take some time and learn about the subject at hand and take the necessary steps to protect your business and your employees.
If you are a fabricator in a state other than California, I would highly advise you to learn everything you can and start implementing best practices to protect your business and your employees. First off, protecting your employees and providing a safe work environment is your responsibility and the right thing to do and secondly, it is only a matter of time before your state government follows California’s lead.
So what is the CAL-OSHA ETS that went into effect December of 2023?
On December 14, 2023 the Occupational Safety and Health Standards Board approved Cal/OSHA’s emergency
temporary standard (ETS) on respirable crystalline silica (RCS). This ETS includes important revisions to protect
workers engaged in high-exposure trigger tasks (cutting, grinding, polishing, clean up, etc.) involving artificial stone
and natural stone containing more than 10% crystalline silica.
This includes countertop fabricators that work with natural stone and quartz countertops. Right now quartz materials are in the hot seat, but virtually all countertop materials contain some silica with the exception of wood and solid surface countertops like Corian, HiMacs, Avonite and Livingstone.
CLICK HERE for the CAL-OSHA executive summary
CLICK HERE for what employers need to know about the ETS
CLICK HERE for what workers need to know about the ETS
CLICK HERE to visit CAL-OSHA Silica standards and resources
What are best practices I need to take to protect my business and employees?
- Learn and Share – Learn everything you can about Silicosis and the best practices you can implement to work more safely. Then share what you have learned with your team. If you just start implementing policies with no explanation, you will face push back from your team. You need knowledge so that you can articulate “why” you are putting the policies in place. It would be smart to assign a key employee in the shop to get trained on silicosis and the best practices needed to get better team buy-in. Employees tend to accept one of their peers making suggestions instead of “the man” telling them what to do.
- Have a written safety/exposure plan – If is not enough to say you are taking safety seriously. You MUST have a written plan that states the risks and steps you are taking. It needs to contain how to properly use PPE, documentation of proper report of carcinogen use to Cal/OSHA, training procedures and air quality inspection reports.
- Post this Sign – No this warning sign is not going to stop Silicosis, but it is a requirement in the CAL-OSHA ETS and you will be fined if it is not posted. Also posting this sign is a good way to initiate the sharing in step 1. Let your team know you are taking this extremely seriously and you will be implementing best practices they must follow or they will die. So they must follow them of find another place to work. CLICK HERE TO SEE SIGN.
- Cut/Polish with Water – You should never be cutting or polishing any quartz or stone materials without using water. ALWAYS use water to cut or polish. Dry cutting or polishing fills the air with silica that is breathed in.
- Use a water collection/filtration system – Implement a water reclaimation system to filter sediments out of the water you are using. Most shops are recycling a portion of their water, but if you are not filtering that used water, you are just repeatedly pushing silica around your shop. When the water evaporates all that silica will be left behind and go airborne when it is disturbed.
- Keep everything wet and clean – Keep all of your floor areas where dust or sediment will build up wet and clean the area regularly by spraying and squeegying the water and sediment to your collection pit to be filtered. Do not let the sediment build up and do not let the water evaporate and leave dust behind. As soon as the dust is disturbed it goes airborne and straight to your lungs.
- Never Sweep or Blow Dry dust with air – Tell your employees they can never blow off or disrupt any dust with compressed air. This will fill the air with Silica particles.
- Air quality monitoring – There are companies that will help you monitor your air quality so that you know where you stand. While you may think you are in compliance, you may be surprised to discover that you are not. The standards are very high and it is highly advisable to pay a small price now to ensure you are in compliance rather than find out from OSHA that you do not comply and pay a large fine. If you can prove that your air quality meets the standards by testing every 6 months you are wear a standard mask like an N95. If you cannot demonstrate that your air quality complies with the silica requirements, your employees will be required to wear a full-face, tight-fitting powered air-purifying respirator (PAPR) NOTE: these run roughly $2000 each.
- Wear a mask – I know this is the last thing anyone wants to hear after the last 3 years, but unlike Covid – that was just classified as a normal respiratory virus to be treated just like the flu by the CDC (SEE HERE) – silica itself will kill you if it is breathed in long enough. Even if you can prove your air quality is acceptable, you still need to wear a quality mask and have it fitted properly. The “any mask will work” approach that was espoused during the COVID pandemic will not work with Silica. You also need to make sure you are healthy enough to wear a mask for extended periods of time as they can create further complications if you are not. I know, I know this goes completely against everything you were told for 3 years…… it is almost like you were lied to.
- Check your employees health – Make sure your employees are healthy and are not at risk of developing Silicosis in the future. There are two tests to do this 1) Pulmonary Function Test and 2) B-Read X-Ray. These test can help you determine if an employee already has or is on their way to developing Silicosis so that they can get the treatment they need.
- Review your insurance – Silicosis is a workers comp issue. General liability does not cover silicosis. You will need to get a rider on your GL policy to cover it. Call your broker or agent and make sure you have the coverages you need to protect your business.
- Get a 3rd Party Safety Inspection – There are 3rd party safety compliance companies that will come to your shop and make sure you are in compliance for OSHA. They will inspect everything and let you know where you are failing or need improvement. If you have never done this, I highly recommend this step as they will give you a comprehensive overview of what you need to improve on so that should OSHA show up at your shop you will have already taken the steps needed to be in full compliance and hopefully avoid any fines.
- Request an OSHA consultation inspection – I know the idea of inviting OSHA to your shop is not a pleasant thought. However, you need to understand it is only a matter of time before they show up – do you want it on your terms or on theirs? I highly recommend you bring in a 3rd party inspection company and make all the corrections they presented you BEFORE you invite OSHA. When you invite OSHA for a consultative visit, you will need to agree to correct any violations the find within an agreed upon timeframe. There are no fines. The benefit of a consultative OSHA visit is that you will now have a 1 year grace period for an OSHA enforcement visit where they will fine you. The only exception to this grace period is if someone is injured at your shop or somebody files a complaint against you for an unsafe working condition.
- CA ONLY – Complete the required carcinogen form – This is a requirement so that you are in compliance with the state. CLICK HERE To learn more.
Here are a few resources to help you implement the best practices above:
Written Plan
CLICK HERE to download a sample plan you can modify for your business
Air Quality Monitoring
SGS Galson will send out the collection pumps needed to test your air and do the analysis. SGS Galson is an approved vendor by OSHA for air quality analysis.
CLICK HERE to visit SGS Galson
Check Employee Health
It would be wise to not only test your current employees, but also any new hirers so that you can ensure you are not exposing yourself to any potential liabilities.
You need to get a pulmonary function test and a B-Read X-ray.
Here are a few options for testing:
Pulmonary Function Tests:
Concentra
UCLA Health
UC Davis Health
B-Read X-Ray
Concentra
K&T Diagnostics
3rd Party Safety Inspection
Safety Compliance Company
SCM
Just search “safety compliance inspection + ‘your state'” in google. There are many.
