The new OSHA Silica Standard pertaining to silica exposure came into effect on June 23, 2016. All industries that involve silica exposure are now required to come into compliance within one to five years, depending on the specific industry. For those engaged in hydraulic fracking, such as that found in the oil and gas industry, the standard mandates compliance in two stages. The first stage gives two years to gain compliance, which will end in 2018 with the exception of engineering controls. The second stage gives engineering controls until 2021 to gain compliance.
Important Rule Provisions
With over 300,000 workers involved or exposed to silica in the course of drilling and hydraulic fracking processes, the overall impact of this final rule could be profound. Importantly, the key elements of this final rule are:
• Requires a PEL (Permissible Exposure Limit) of 50ug/8 hours
• Requires the use of engineering control methods to prevent reaching the PEL
• Requires the use of respirators when engineering controls are not used or available
• Reduce non-operating personal exposure to PEL areas
• Training for workers on effects of silica and how to limit exposure
• Produce a written control plan
• Provide medical exams to workers who have been exposed to higher levels than the PEL
For workers who are exposed to levels that exceed the PEL, the worker should also be provided with their current lung health data after the medical exam.
Compliance with the new PEL for the oil and gas industry is mandated by 2018, however, the implementation of silica control via engineering methods are not required until 2021. These controls can be engaged by using water methodology that controls dust, active ventilation that reduces confined exposure to below the PEL or vacuum methods that remove the dust to below PEL levels. Most engineering control technology currently exists and therefore it is expected that the costs per implementation should be low especially compared to the annual impact.
Economic Impact Summary For All Industries
The overall impact of this new standard as reviewed by OSHA is expected to have a per-site cost of approximately $1,200 using conventionally available technology. In companies with fewer employees, the expected cost is considerably less. This is in contrast to the potential net gain of 2.8 billion across all industries by reducing health care effects experienced with high exposure to silica. For the oil and gas industry, this can, in fact, be profound saving, especially given the expected rise in health care costs over the next decade. For more in-depth information on the role of silica and the hazards concerning silica in reference to hydraulic fracking see the OSHA-NIOSH Silica Alert fact sheet.
Silica exposure represents a direct hazard to the health of workers engaged in the oil and gas industry. By complying with the new OSHA final rule and standard concerning silica exposure, the industry can expect a net gain in costs related to the safety and healthcare of employees for a minimal cost outlay. An ancillary effect of compliance is that it also can potentially reduce other pollutants such as noise and effects that have created a negative image concern for the oil and gas industry as a whole. Compliance with this new rule provides many benefits, both known and unknown and thus all efforts should be engaged to meet the compliance sooner than recommended by the standard itself.