Answer Library / Respirators & Air

If we follow Silica Table 1 for a task, what else does the construction silica standard still require?

Quick answer

Table 1 relieves you of exposure assessment, not of the rest of the standard. For a task on Table 1 you must fully and properly implement the engineering controls, work practices and respiratory protection the table specifies (29 CFR 1926.1153(c)(1)), and indoors provide exhaust to minimize visible dust (1926.1153(c)(2)(i)). You still need a written exposure control plan (1926.1153(g)) and medical surveillance for anyone required to wear a respirator 30 or more days a year (1926.1153(h)(1)(i)). Tasks not on the table, or done without the table's full controls, fall under the alternative route with its action level and exposure assessment (1926.1153(d)).

Table 1 is the most used and most misunderstood part of the construction silica rule. It is a deal: do exactly what the table says and you do not have to measure. It is not an exemption from the standard.

The deal. For each employee engaged in a task identified on Table 1, the employer shall fully and properly implement the engineering controls, work practices and respiratory protection specified for that task — unless the employer instead assesses and limits exposure under paragraph (d) (29 CFR 1926.1153(c)(1)). "Fully and properly" is the operative phrase: a saw with the water feed turned off is not Table 1 compliance. When implementing the table's controls, the employer must also provide a means of exhaust for tasks indoors or in enclosed areas as needed to minimize visible airborne dust (29 CFR 1926.1153(c)(2)(i)).

What the deal does not cover. The written exposure control plan is required regardless (29 CFR 1926.1153(g)(1)): the tasks involving exposure, the controls for each, housekeeping measures, and procedures to restrict access. Medical surveillance must be made available at no cost to each employee who will be required to use a respirator for 30 or more days per year (29 CFR 1926.1153(h)(1)(i)) — and several Table 1 entries require a respirator for shifts over four hours, so a crew doing those tasks regularly is in the program.

Off the table. For tasks not listed on Table 1, or where the employer does not fully and properly implement the table's controls, paragraph (d) applies (29 CFR 1926.1153(d)): the employer must assess the exposure of each employee who is or may reasonably be expected to be exposed at or above the action level, by either the performance option or the scheduled monitoring option (29 CFR 1926.1153(d)(2)(i)), and keep exposures at or below the PEL.

The practical test for a Table 1 task is simple: open the table to the row, read the control, and look at the tool. If what the row says and what the tool is doing differ, you are on the paragraph (d) route whether you planned to be or not.

29 CFR 1926.1153(c)(1)29 CFR 1926.1153(c)(2)(i)29 CFR 1926.1153(d)29 CFR 1926.1153(d)(2)(i)29 CFR 1926.1153(g)(1)29 CFR 1926.1153(h)(1)(i)
Source: An analysis from the respirable crystalline silica standard for construction, 29 CFR 1926.1153. Primary reference: read it on osha.gov →

Federal rule shown. If the workplace is in one of the 29 State Plan states and territories, the state standard governs and may differ — see Known Limitations.

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