Small Entity 

Compliance Guide

for the Respirable Crystalline 

Silica Standard for Construction

OSHA 3902-02R 2024
Occupational Safety and Health Act of 1970

“To assure safe and healthful working conditions for working men 

and women; by authorizing enforcement of the standards developed 

under the Act; by assisting and encouraging the States in their 

efforts to assure safe and healthful working conditions; by providing 

for research, information, education, and training in the field 

of occupational safety and health.”

Material contained in this publication is in the public domain and may 

be reproduced, fully or partially, without permission. Source credit is 

requested but not required.

This information will be made available to sensory-impaired individuals 

upon request. Voice phone: (202) 693-1999; teletypewriter (TTY) number: 

1-877-889-5627.

This publication provides a general overview of a particular standardsrelated topic. This publication does not alter or determine compliance 

responsibilities which are set forth in OSHA standards and the 

Occupational Safety and Health Act. Moreover, because interpretations 

and enforcement policy may change over time, for additional guidance 

on OSHA compliance requirements the reader should consult current 

administrative interpretations and decisions by the Occupational Safety 

and Health Review Commission and the courts.

Cover photo courtesy of OSHA, International Masonry Institute.
Small Entity 

Compliance Guide

for the Respirable Crystalline 

Silica Standard for Construction

Occupational Safety and Health Administration

U.S. Department of Labor

OSHA 3902-02R 2024
This guidance document provides an 

overview of OSHA’s Respirable Crystalline 

Silica Standard for Construction. It is 

advisory in nature and informational in 

content. It is not a standard or regulation, 

and it neither creates new legal obligations 

nor alters existing obligations created 

by the Occupational Safety and Health 

Administration (OSHA) standards or the 

Occupational Safety and Health Act of 

1970 (OSH Act). Pursuant to the OSH Act, 

employers must comply with safety and 

health standards and regulations issued and 

enforced either by OSHA or by an OSHAapproved state plan. In addition, the Act’s 

General Duty Clause, Section 5(a)(1), requires 

employers to provide their workers with a 

workplace free from recognized hazards that 

are causing or likely to cause death or serious 

physical harm.

In addition, Section 11(c)(1) of the Act 

provides that “No person shall discharge 

or in any manner discriminate against any 

employee because such employee has filed 

any complaint or instituted or caused to be 

instituted any proceeding under or related 

to this Act or has testified or is about to 

testify in any such proceeding or because 

of the exercise by such employee on behalf 

of himself or others of any right afforded by 

this Act.” Reprisal or discrimination against 

an employee for reporting an incident, injury, 

or workplace violation, for participating 

in medical surveillance, or because of 

the results of medical surveillance would 

constitute a violation of Section 11(c) of the 

OSH Act.
TABLE OF CONTENTS

INTRODUCTION.......................................................................................................................................1

SCOPE – PARAGRAPH (A) OF THE STANDARD ..................................................................................3

DEFINITIONS – PARAGRAPH (B) OF THE STANDARD........................................................................5

SPECIFIED EXPOSURE CONTROL METHODS – PARAGRAPH (C) OF THE STANDARD.................5

ALTERNATIVE EXPOSURE CONTROL METHODS – PARAGRAPH (D) OF THE STANDARD........34

Permissible Exposure Limit (PEL)..................................................................................................34

Exposure Assessment ....................................................................................................................34

Methods of Compliance .................................................................................................................38

RESPIRATORY PROTECTION – PARAGRAPH (E) OF THE STANDARD ...........................................40

HOUSEKEEPING – PARAGRAPH (F) OF THE STANDARD ................................................................41

WRITTEN EXPOSURE CONTROL PLAN – PARAGRAPH (G) OF THE STANDARD ........................42

MEDICAL SURVEILLANCE – PARAGRAPH (H) OF THE STANDARD...............................................48

COMMUNICATION OF HAZARDS – PARAGRAPH (I) OF THE STANDARD ....................................56

RECORDKEEPING – PARAGRAPH (J) OF THE STANDARD ..............................................................59

DATES – PARAGRAPH (K) OF THE STANDARD.................................................................................60

APPENDIX I: OSHA RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION.....61

WORKERS’ RIGHTS...............................................................................................................................93

OSHA ASSISTANCE, SERVICES, AND PROGRAMS .........................................................................93

OSHA REGIONAL OFFICES ..................................................................................................................94

HOW TO CONTACT OSHA....................................................................................................................95
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 1

INTRODUCTION

This guide is intended to help small 

businesses understand and comply 

with the Occupational Safety and Health 

Administration’s (OSHA) Respirable Crystalline 

Silica standard for Construction. Workers 

exposed to respirable crystalline silica are at 

increased risk of developing serious adverse 

health effects including silicosis, lung cancer, 

chronic obstructive pulmonary disease, 

and kidney disease. This guide describes 

the steps that employers are required to 

take to protect employees in construction 

from the hazards associated with exposure 

to respirable crystalline silica. Employers in 

industries other than construction should 

refer to the small entity compliance guide for 

occupational exposure to respirable crystalline 

silica in general industry and maritime.

What is Respirable Crystalline Silica? 

Crystalline silica is a common mineral found 

in many naturally occurring and man-made 

materials used at construction sites. Materials 

like sand, concrete, brick, block, stone and 

mortar contain crystalline silica. Amorphous 

silica, such as silica gel, is not crystalline silica.

Respirable crystalline silica – very small 

particles typically at least 100 times smaller 

than ordinary sand found on beaches or 

playgrounds – is generated by high-energy 

operations like cutting, sawing, grinding, drilling 

and crushing stone, rock, concrete, brick, block 

and mortar, or when abrasive blasting with sand.

This document provides guidance only, 

and does not alter or determine compliance 

responsibilities, which are laid out in OSHA 

standards and the Occupational Safety and 

Health Act. This guide does not replace the 

official respirable crystalline silica standard 

for construction. The employer must refer to 

the standard to ensure that it is in compliance. 

Moreover, because interpretations and 

enforcement policy may change over time, 

for additional guidance on OSHA compliance 

requirements the reader should consult 

current administrative interpretations and 

decisions by the Occupational Safety and 

Health Review Commission and the courts. 

Overview of the Standard 

and Guide

This guide is divided into sections that 

correspond to the major provisions 

(paragraphs) of the silica standard for 

construction. Each section describes the 

provision and gives additional details to 

help employers better understand the 

requirements of the standard. 

The first step for an employer is to determine 

if the standard applies to its work. If its work 

is covered by the standard, an employer has 

two options for limiting employee exposure 

to respirable crystalline silica:

■ Specified exposure control methods; or

■ Alternative exposure control methods.

Employers who choose the specified 

exposure controls option must fully and 

properly implement protections for the 

tasks or equipment listed in Table 1 of the 

standard. Employers who fully and properly 

implement the controls in Table 1 do not have 

to assess employees’ silica exposure levels 

or keep employee exposures at or below the 

permissible exposure limit (PEL).

Employers who follow alternative exposure 

control methods must:

■ Determine the levels of respirable crystalline 

silica that employees are exposed to;

■ Limit employee exposures to a PEL of 

50 micrograms per cubic meter of air 

(50 μg/m3) as an 8-hour time-weighted 

average (TWA);

■ Use engineering and work practice 

controls, to the extent feasible, to limit 

employee exposures to the PEL, and 

supplement the controls with respiratory 

protection when necessary.

■ Keep records of employee exposure to 

respirable crystalline silica.
2 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Roadmap for Meeting the Requirements of the Respirable Crystalline Silica Standard

1. Determine if the silica standard applies to your employees. 

Could employees be exposed to respirable crystalline silica at or above 25 μg/m3

 as an 8-hour TWA under any 

foreseeable conditions, including the failure of engineering controls, while performing construction activities?

No: No further action is required under the silica standard.

Yes: Choose to comply with the standard using either the: 

• Specified exposure control methods in Table 1, or 

• The alternative methods of compliance

2. Determine what additional requirements you must meet under the standard, based on the compliance 

method you are following. 

Requirement

Must the Employer Follow this Requirement?

If Fully and Properly 

Implementing Table 1

If Following Alternative 

Exposure Controls 

PEL No Yes

Exposure Assessment No Yes, when exposures are 

reasonably expected to be 

above the action level. 

Methods of Compliance No Yes

Respiratory Protection Yes, if respirator use is 

required by Table 1

Yes, if respirator use is 

required to reduce exposures 

to the PEL

Housekeeping Yes Yes

Written Exposure Control Plan Yes Yes

Medical surveillance Yes, for employees who must wear a respirator under the silica 

standard for 30 or more days a year.

Communication of Hazards Yes Yes

Recordkeeping Yes, for any employees who are 

getting medical examinations

Yes, for exposure assessments 

and for any employees who are 

getting medical examinations

All employers covered by the standard must:

■ Provide respiratory protection when required;

■ Restrict housekeeping practices that expose 

employees to respirable crystalline silica 

where feasible alternatives are available; 

■ Establish and implement a written 

exposure control plan, including 

designating a competent person;

■ Offer medical exams to employees who 

will be required to wear a respirator under 

the standard for 30 or more days a year;

■ Communicate hazards and train 

employees; and

■ Keep records of medical examinations.

See the roadmap listed below for more 

information.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 3

SCOPE – PARAGRAPH (A) OF THE STANDARD

The standard applies to all occupational 

exposures to respirable crystalline silica in 

construction work, except where employee 

exposure will remain below 25 μg/m3 as 

an 8-hour TWA under any foreseeable 

conditions. Exposures to respirable 

crystalline silica occur when the following 

tools are used on concrete, brick, block, 

stone, mortar, and other materials that 

contain crystalline silica:

■ Stationary masonry saws;

■ Handheld power saws;

■ Walk-behind saws;

■ Drivable saws;

■ Rig-mounted core saws or drills;

■ Handheld and stand-mounted drills 

(including impact and rotary hammer drills);

■ Dowel drilling rigs;

■ Vehicle-mounted drilling rigs;

■ Jackhammers and handheld powered 

chipping tools;

■ Handheld grinders;

■ Walk-behind milling machines and 

floor grinders;

■ Drivable milling machines;

■ Crushing machines; and

■ Heavy equipment and utility vehicles 

when used to abrade or fracture silicacontaining materials (such as hoeramming or rock ripping) or during 

demolition activities, and for tasks such as 

grading and excavating.

Exposures to respirable crystalline silica also 

occur during tunneling operations and during 

abrasive blasting when sand or other blasting 

agents containing crystalline silica are used, 

or when abrasive blasting is performed on 

substrates that contain crystalline silica, such 

as concrete.

Where Employee Exposure Will Remain 

Below 25 μg/m3 as an 8-Hour TWA

The standard does not apply where employee 

exposure will remain below 25 μg/m3 as an 

8-hour TWA under any foreseeable conditions. 

The phrase “any foreseeable conditions” 

refers to situations that can reasonably 

be anticipated. OSHA considers failure of 

engineering controls to be a situation that is 

reasonably foreseeable. Although engineering 

controls are usually a reliable means for 

controlling employee exposures, equipment 

does occasionally fail. Thus, the standard 

applies where exposures below 25 μg/m3 as 

an 8-hour TWA are expected or achieved, but 

only because engineering controls are being 

used to limit exposures.

Employee exposure can reasonably be 

anticipated to remain below 25 μg/m3 as 

an 8-hour TWA when performing certain 

tasks that involve only minimal exposure to 

respirable crystalline silica. Such tasks include:

■ Mixing concrete for post holes;

■ Pouring concrete footers, slab foundation, 

and foundation walls; and

■ Removing concrete formwork.

When these tasks are performed in isolation 

from tasks that generate significant exposures 

to respirable crystalline silica, the standard 

does not apply. These examples are not 

exclusive, and there may be other tasks that 

involve exposure under 25 μg/m as an 8-hour 

TWA under any foreseeable conditions.
4 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Some employees in the construction sector 

perform tasks involving occasional, brief 

exposures to respirable crystalline silica that 

are incidental to their primary work. These 

workers include carpenters, plumbers, and 

electricians who occasionally drill holes 

in concrete or masonry or perform other 

tasks that involve exposure to respirable 

crystalline silica. Where employees perform 

tasks that involve exposure to respirable 

crystalline silica for a very short period 

of time, exposures for many tasks will be 

below 25 μg/m3 as an 8-hour TWA. For 

example, for hole drillers using hand-held 

drills, if the duration of exposure is 15 

minutes or less, the 8-hour TWA exposure 

can reasonably be anticipated to remain 

under the 25 μg/m3 threshold (assuming no 

exposure for the remainder of the shift), and 

the standard would not apply.

This exception for situations where 

exposures are not likely to present significant 

risk to workers allows employers to focus 

their resources on exposures of greater 

occupational health concern.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 5

DEFINITIONS – PARAGRAPH (B) OF THE STANDARD

Definitions are included in the standard 

to describe the meaning of terms used. 

Some of these terms are further explained 

as follows:

Action level means an airborne concentration 

of 25 μg/m3 calculated as an 8-hour TWA. 

Exposures at or above the action level trigger 

requirements for exposure assessment. 

Competent person means an individual 

who is capable of identifying existing and 

foreseeable respirable crystalline silica 

hazards in the workplace and who has 

authorization to take prompt corrective 

measures to eliminate or minimize them. 

The competent person must have the 

knowledge and ability necessary to 

implement the written exposure control 

plan required under the standard. 

Employee exposure means the exposure 

to airborne respirable crystalline silica that 

would occur if the employee were not using 

a respirator. 

High-efficiency particulate air (HEPA) filter

means a filter that is at least 99.97 percent 

efficient in removing mono-dispersed 

particles of 0.3 micrometers in diameter. 

HEPA-filtered vacuuming is an example 

of a housekeeping method that minimizes 

employee exposure to respirable crystalline 

silica, and some Table 1 tasks require HEPAfiltered vacuuming. 

Objective data means information, such 

as air monitoring data from industrywide surveys or calculations based on the 

composition of a substance, demonstrating 

employee exposure to respirable crystalline 

silica associated with a particular product 

or material or a specific process, task, or 

activity. The data must reflect workplace 

conditions closely resembling or with a 

higher exposure potential than the processes, 

types of material, control methods, work 

practices, and environmental conditions in 

the employer’s current operations. 

Physician or other licensed health care 

professional [PLHCP] is an individual whose 

legally permitted scope of practice (i.e., 

license, registration, or certification) allows 

him or her to independently provide or be 

delegated the responsibility to provide some 

or all of the particular health care services 

required by this standard. 

Specialist means an American Board 

Certified Specialist in Pulmonary Disease 

or an American Board Certified Specialist in 

Occupational Medicine. 

SPECIFIED EXPOSURE CONTROL METHODS – PARAGRAPH (C) 

OF THE STANDARD

The silica standard for construction provides 

a flexible approach for construction 

employers to achieve compliance. The 

standard includes Table 1, which lists 18 

common tasks using various types of tools 

or equipment found at construction sites. 

For each employee engaged in a task in 

Table 1, employers who choose to follow the 

Table for that task are required to fully and 

properly implement the engineering controls, 

work practices, and respiratory protection 

specified in Table 1. Employers who comply 

with Table 1 are not required to conduct 

exposure assessments or comply with a PEL 

for those employees. 

Employees engaged in the Table 1 task 

means the equipment operator; helpers, 

laborers and other employees who are 

assisting with the task; or any other 

employee responsible for completing the 
6 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

task. For example, an employee operating 

a walk-behind saw and another employee 

helping the operator guide the saw are both 

engaged in the task. An employee operating 

a jackhammer would be engaged in the 

task, but another employee directing traffic 

near the employee jackhammering would 

not be engaged in the task. When Table 1 

requires respiratory protection, employers 

must provide respirators to all employees 

engaged in the task. Employers must 

describe procedures for restricting access of 

employees not engaged in the task as part of 

its Written Exposure Control Plan. 

Fully and properly implemented means that 

controls are in place, are properly operated 

and maintained, and employees understand 

how to use them. Several factors required 

for full and proper implementation of 

controls are listed in the discussion for each 

Table 1 entry below. The presence of large 

amounts of visible dust generally indicates 

that controls are not fully and properly 

implemented. A small amount of dust can be 

expected from equipment that is operating 

as intended by the manufacturer; however, a 

noticeable increase in dust generation during 

the task is a sign that the dust controls are not 

operating correctly. The difference between 

the small amounts of dust generated when 

control measures are working properly and 

the large amount of dust generated during 

tasks when control measures are not used or 

not operated effectively is easily observed. 

When this happens, prompt corrective 

actions are required.

As part of full and proper implementation, 

many Table 1 tasks require the employer 

to operate and maintain tools according to 

manufacturers’ instructions for minimizing 

dust emissions. Manufacturer’s instructions 

for minimizing dust can include: 

■ Water flow rates, 

■ Vacuum equipment air flow rate and 

capacity, 

■ Rotation of the blade (speed, direction), 

■ Maintaining and changing blades, and 

■ Frequency for changing water.

See sections on Water Delivery Systems and 

Dust Collection Systems for more information 

about the use of controls for respirable 

crystalline silica. 

Several entries in Table 1 have requirements 

for the use of respiratory protection with 

a minimum “assigned protection factor” 

(APF). Paragraph (d)(3)(i)(A) of the Respiratory 

Protection standard (29 CFR 1910.134) includes 

a table that can be used to determine the 

type or class of respirator that will provide 

employees with a particular APF, and it 

can help employers determine the type of 

respirator that would meet the required 

minimum APF specified by Table 1. Employers 

have the flexibility to provide a more 

protective respirator to those employees who 

request one or require the employees to use 

a more protective respirator. See section on 

Determining Task Duration and Requirements 

for Respirator Use for information on how 

to measure task duration to determine 

respiratory protection requirements for 

employees doing one or more Table 1 task. 

Description of Table 1 Entries

This section lists each Table 1 entry and 

explains the requirement for that entry.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 7

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(i) Stationary masonry saws Use saw equipped with integrated water 

delivery system that continuously feeds 

water to the blade. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions.

None None

Stationary masonry saws must be equipped 

with an integrated water delivery system 

(supplied by the equipment manufacturer 

and developed specifically for the tool in 

use) that continuously feeds water to the 

blade. The water delivery system usually 

includes a nozzle for spraying water attached 

near the blade that is connected to a water 

basin by a hose and pump. The tool must 

be operated and maintained in accordance 

with manufacturer’s instructions to minimize 

dust emissions. Stationary masonry saws 

equipped with an integrated system for blade 

cooling also suppress dust and meet the 

requirements of Table 1. 

Full and proper implementation of water 

controls on stationary masonry saws requires 

the employer to ensure that: 

■ An adequate supply of water for dust 

suppression is used; 

■ The spray nozzle is working properly 

to apply water at the point of dust 

generation;

■ The spray nozzle is not clogged or 

damaged; and 

■ All hoses and connections are intact.

Table 1 does not specify a minimum flow 

rate; however, water must be applied at the 

flow rates specified by the manufacturer.

When using a stationary masonry saw 

indoors or in an enclosed space (areas 

where airborne dust can buildup, such as 

a structure with a roof and three walls), 

employers must provide additional exhaust 

as needed to minimize the accumulation of 

visible airborne dust. 

See the section on Indoors or Enclosed Areas

for more information. 

Respiratory protection is not required for 

work with stationary masonry saws 

regardless of task duration. 

Worker cutting masonry block on a stationary masonry saw equipped with 

integrated water delivery system that continuously feeds water to the blade. 

Note water supply hose attached to top of shroud around blade.

Photo courtesy of OSHA, International Masonry Institute. The equipment 

shown in this picture is for illustrative purposes only and is not intended as 

an endorsement by OSHA of this company, its products or services.
8 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(ii) Handheld power saws 

(any blade diameter)

Use saw equipped with integrated water 

delivery system that continuously feeds 

water to the blade. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10 

APF 10

APF 10

Handheld power saws with any blade 

diameter must be equipped with an 

integrated water delivery system (supplied 

by the equipment manufacturer and 

developed specifically for the tool in use) 

that continuously feeds water to the blade. 

The water delivery system usually includes 

a nozzle for spraying water attached near 

the blade that is connected to a water basin 

via a hose and pump. The tool must be 

operated and maintained in accordance with 

manufacturer’s instructions to minimize dust 

emissions. Handheld power saws equipped 

with an integrated water delivery system for 

blade cooling also suppress dusts and meet 

the requirements of Table 1.

Full and proper implementation of water 

controls on handheld power saws requires 

the employer to ensure that: 

■ An adequate supply of water for dust 

suppression is used; 

■ The spray nozzle is working properly to 

apply water at the point of dust generation;

■ The spray nozzle is not clogged or damaged; 

■ All hoses and connections are intact. 

Table 1 does not specify a minimum flow 

rate; however, water must be applied at the 

flow rate specified by the manufacturer. 

When working with handheld power saws 

of any blade diameter, respiratory protection 

with a minimum APF of 10 is required for 

work done outdoors for 

more than four hours per 

shift and for work done 

indoors, or in an enclosed 

location, regardless of 

task duration.

When using a handheld 

saw indoors or in 

enclosed spaces (areas 

where airborne dust 

can buildup, such 

as a structure with a 

roof and three walls), 

employers must provide 

additional exhaust, as 

needed to minimize the 

accumulation of visible 

airborne dust. See the 

section on Indoors or 

Enclosed Areas for more 

information. 

A worker cutting a concrete 

block using a handheld 

masonry saw with an 

integrated water delivery 

system.

Photo courtesy Husqvarna. 

The equipment shown in 

this picture is for illustrative 

purposes only and is not 

intended as an endorsement 

by OSHA of this company, its 

products or services.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 9

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(iii) Handheld power saws 

for cutting fiber-cement 

board (with blade diameter 

of 8 inches or less)

For tasks performed outdoors only:

• Use saw equipped with commercially 

available dust collection system. 

• Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

• Dust collector must provide the air flow 

recommended by the tool manufacturer, 

or greater, and have a filter with 99% or 

greater efficiency.

None NoNE

Specialty handheld power saws for cutting 

fiber-cement board (with a blade diameter 

of 8 inches or less) must be equipped with 

commercially available dust collection 

systems and a filter with a 99 percent or 

greater efficiency. The saws must be operated 

and maintained in accordance with the 

manufacturer’s instructions to minimize 

dust emissions, and provide the air flow rate 

recommended by the manufacturer or greater. 

When employers are complying with Table 1, 

the saws must only be used outdoors.

Full and proper implementation of dust 

collection systems on handheld power saws 

for cutting fiber-cement board requires the 

employer to ensure that:

■ The shroud or cowling is intact and 

installed in accordance with the 

manufacturer’s instructions; 

■ The hose connecting the tool to the vacuum 

is intact and without kinks or tight bends; 

■ The filter(s) on the vacuum are cleaned 

or changed in accordance with the 

manufacturer’s instructions to prevent 

clogging; and 

■ The dust collection bags are emptied to 

avoid overfilling.

Respiratory protection is not required for 

work outdoors with specialty handheld 

power saws while cutting fiber-cement board 

regardless of task duration. 

Worker cutting fiber-cement board outdoors using a handheld power saw 

and dust collection system. The dust collection system consists of the shroud 

on the saw, hose, and dust collector positioned between the saw horses.

Photo courtesy of NIOSH. 
10 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(iv) Walk-behind saws Use saw equipped with integrated water 

delivery system that continuously feeds 

water to the blade. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

None

APF 10

Walk-behind saws must be equipped 

with an integrated water delivery system 

(supplied by the equipment manufacturer 

and developed specifically for the tool in use) 

that continuously feeds water to the blade. 

The tool must be operated and maintained in 

accordance with manufacturer’s instructions 

to minimize dust emissions. Full and proper 

implementation of water controls on walkbehind saws requires the employer to ensure 

that: 

■ An adequate supply of water for dust 

suppression is used; 

■ The spray nozzles are working properly 

to apply water at the point of dust 

generation;

■ The spray nozzles are not clogged or 

damaged; and

■ All hoses and connections are intact. 

Table 1 does not specify a minimum flow 

rate; however, water must be applied at the 

flow rate specified by the manufacturer.

Walk-behind saws used to cut roads and 

cut pavement are most commonly used 

outdoors, though they can also be used 

indoors to cut concrete floors. When using 

walk-behind saws indoors or in enclosed 

areas (areas where airborne dust can 

buildup, such as a structure with a roof 

and three walls), employers must provide 

additional exhaust, as needed to minimize 

the accumulation of visible airborne dust. See 

the section on Indoors or Enclosed Areas for 

more information. 

When working outdoors, respiratory protection 

is not required for work with walk-behind saws 

regardless of task duration. When working 

indoors, or in an enclosed location, respiratory 

protection with a minimum APF of 10 is 

required regardless of task duration. 

Worker using a walk-behind saw with an integrated water delivery system 

to cut asphalt roadway.

Photo courtesy of OSHA.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 11

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(v) Drivable saws For tasks performed outdoors only:

• Use saw equipped with integrated water 

delivery system that continuously feeds 

water to the blade. 

• Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions.

None None

Drivable saws used to cut silica-containing 

materials (such as concrete, asphalt, granite 

and terrazzo) must be equipped with an 

integrated water delivery system (supplied 

by the equipment manufacturer and 

developed specifically for the tool in use) 

that continuously feeds water to the blade 

and must be operated and maintained in 

accordance with manufacturer’s instructions 

to minimize dust emissions. Employers 

following Table 1 must only allow the saws to 

be used outdoors. 

Full and proper implementation of water 

controls on drivable saws requires the 

employer to ensure that: 

■ An adequate supply of water for dust 

suppression is used; 

■ The spray nozzles produce a pattern 

that applies water at the point of dust 

generation;

■ The spray nozzles are not clogged or 

damaged; and

■ All hoses and connections are intact. 

Respiratory protection is not required for 

work with drivable saws regardless of task 

duration. 

Worker cutting a groove in concrete roadway with drivable saw using 

integrated water delivery system.

Photo courtesy of Husquvarna. The equipment shown in this picture is for 

illustrative purposes only and is not intended as an endorsement by OSHA of 

this company, its products or services.
12 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(vi) Rig-mounted core 

saws or drills

• Use tool equipped with integrated water 

delivery system that supplies water to 

cutting surface. 

• Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

None None

Rig-mounted core saws or drills must 

be equipped with an integrated water 

delivery system (supplied by the equipment 

manufacturer and developed specifically 

for the tool in use) that supplies water 

to the cutting surface, and must be 

operated and maintained in accordance 

with manufacturer’s instructions to minimize 

dust emissions. 

Full and proper implementation of water 

controls on rig-mounted core saws or drills 

requires the employer to ensure that:

■ An adequate supply of water for dust 

suppression is used; 

■ The spray nozzles produce a pattern 

that applies water at the point of dust 

generation;

■ The spray nozzles are not clogged or 

damaged; and 

■ All hoses and connections are intact. 

When using rig-mounted core saws or drills 

indoors or in enclosed areas (areas where 

airborne dust can buildup, such as a structure 

with a roof and three walls), employers must 

provide additional exhaust, as needed to 

minimize the accumulation of visible airborne 

dust. See the section on Indoors or Enclosed 

Areas for more information. 

Respiratory protection is not required for 

work with rig-mounted core saws or drills 

regardless of task duration.

A rig-mounted core drill with an integrated water delivery system. 

Photo courtesy of Hilti. The equipment shown in this picture is for illustrative 

purposes only and is not intended as an endorsement by OSHA of this 

company, its products or services.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 13

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(vii) Handheld and standmounted drills (including 

impact and rotary hammer 

drills)

• Use drill equipped with commercially 

available shroud or cowling with dust 

collection system. 

• Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

• Dust collector must provide the air flow 

recommended by the tool manufacturer, 

or greater, and have a filter with 99% or 

greater efficiency and a filter-cleaning 

mechanism. 

• Use a HEPA-filtered vacuum when 

cleaning holes.

None None

Handheld and stand-mounted drills (including 

impact and rotary hammer drills). Handheld 

and stand-mounted drills must be equipped 

with a commercially available shroud or 

cowling with a dust collection system that 

provides at least the minimum air flow 

recommended by the manufacturer. The dust 

collection system must include a filter cleaning 

mechanism and be equipped with a filter with 

99 percent or greater efficiency. In addition, 

the tool must be operated and maintained in 

accordance with manufacturer’s instructions 

to minimize dust emissions.

Full and proper implementation of dust 

collection systems on handheld drills requires 

the employer to ensure that:

■ The shroud or cowling is intact and 

installed in accordance with the 

manufacturer’s instructions; 

Worker drilling into concrete with a rotary hammer equipped with shroud and 

dust collection system. Note the shroud around drill bit, silver and black hose, 

and dust collector are attached conveniently to the drill.

Photo courtesy of DeWalt. The equipment shown in this picture is for 

illustrative purposes only and is not intended as an endorsement by OSHA of 

this company, its products or services.
14 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

■ The hose connecting the tool to the 

vacuum is intact and without kinks or 

tight bends; 

■ The filter(s) on the vacuum are cleaned 

or changed in accordance with the 

manufacturer’s instructions; and 

■ The dust collection bags are emptied to 

avoid overfilling.

A HEPA-filtered vacuum must be used when 

cleaning holes. Compressed air can be used 

to clean holes when used in conjunction with 

a HEPA-filtered vacuum to capture the dust 

or a hole cleaning kit designed for use with 

compressed air.

When using handheld and stand-mounted 

drills indoors or in enclosed areas (areas 

where airborne dust can buildup, such as 

a structure with a roof and three walls), 

employers must provide additional exhaust, 

as needed to minimize the accumulation 

of visible airborne dust. See the section 

on Indoors or Enclosed Areas for more 

information. 

Respiratory protection is not required when 

using handheld or stand-mounted drills 

equipped with a dust collection system, 

including for overhead drilling, regardless of 

task duration. 

Worker is drilling horizontal holes in a concrete wall using two standmounted drills, each equipped with a dust collector. Note the shrouds 

around drill bits, black hose, and dust collector are attached to the stand.

Photo courtesy of David Rempel, University of California, San Francisco.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 15

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(viii) Dowel drilling rigs for 

concrete

For tasks performed outdoors only:

• Use shroud around drill bit with a 

dust collection system. Dust collector 

must have a filter with 99% or greater 

efficiency and a filter-cleaning 

mechanism. 

• Use a HEPA-filtered vacuum when 

cleaning holes.

APF 10 APF 10

Dowel drills for concrete (i.e., gang drills) are 

drills equipped with multiple drill bits that are 

used to drill several holes at the same time. 

Dowel drills must be equipped with a shroud 

around the drill bit and a dust collection 

system that has a filter with 99 percent 

or greater efficiency. The dust collection 

equipment must be equipped with a filter 

cleaning mechanism. Employers following 

Table 1 must allow dowel drilling rigs to only 

be used outdoors.

Full and proper implementation of dust 

collection systems on dowel drilling rigs 

requires the employer to ensure that:

■ The shroud is intact and installed in 

accordance with the manufacturer’s 

instructions; 

■ The hose connecting the tool to the 

vacuum is intact and without kinks or 

tight bends; 

■ The filter(s) on the vacuum are cleaned 

or changed in accordance with the 

manufacturer’s instructions; and 

■ The dust collection bags are emptied to 

avoid overfilling.

A HEPA-filtered vacuum must be used when 

cleaning holes. Compressed air can be used 

to clean holes when used in conjunction with 

a HEPA-filtered vacuum to capture the dust 

or a hole cleaning kit designed for use with 

compressed air.

Respiratory protection with a minimum APF of 

10 is required for all work with dowel drilling 

rigs for concrete regardless of task duration. 

Worker drilling horizontal holes in concrete slab with a dowel drilling rig. 

The shroud surrounds the drill steel where it enters the concrete and the 

dust collector is the canister on the right. Worker is wearing respiratory 

protection.

Photo courtesy of NIOSH.
16 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(ix) Vehicle-mounted 

drilling rigs for rock and 

concrete

Use dust collection system with close 

capture hood or shroud around drill bit with 

a low-flow water spray to wet the dust at the 

discharge point from the dust collector. 

OR 

Operate from within an enclosed cab and 

use water for dust suppression on drill bit.

None

None

None

None

Vehicle-mounted rock and concrete 

drilling rigs must be equipped with a dust 

collection system with a close capture hood 

or shroud around the drill bit, and a lowflow water spray to wet the dust discharged 

from the dust collector. This combination 

of local exhaust ventilation (LEV) and water 

application controls dust at all emission 

points that can contribute to the operator’s 

and other employees’ exposures. 

Employers also have the option to have 

the drill operator work within an enclosed 

cab and, when necessary, apply water at 

the drill bit, as described above, to reduce 

exposures to other employees in the area. 

See the section on Enclosed Cabs for more 

information on how to make sure cabs meet 

the requirements of Table 1.

Full and proper implementation of dust 

collection systems on vehicle-mounted drilling 

rigs requires the employer to ensure that:

■ The shroud or hood is intact and installed 

in accordance with the manufacturer’s 

instructions; 

■ The hose connecting the tool to the vacuum 

is intact and without kinks or tight bends; 

■ The filter(s) on the vacuum are cleaned 

or changed in accordance with the 

manufacturer’s instructions; and 

■ The dust collection bags are emptied to 

avoid overfilling.

Full and proper 

implementation of 

water controls on 

vehicle-mounted 

drilling rigs requires 

the employer to 

ensure that: 

■ An adequate 

supply of 

water for dust 

suppression 

is used; 

■ The spray nozzles are working properly and 

produce a pattern that applies water on the 

discharge point from the dust collector;

■ The spray nozzles are not clogged or 

damaged; and

■ All hoses and connections are intact.

Respiratory protection is not required for 

work with vehicle-mounted drilling rigs 

regardless of task duration.

Vehicle-mounted drilling rig using water on the 

drill bit. The enclosed operator’s cab is on the 

right. 

Photo courtesy of NIOSH.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 17

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(x) Jackhammers and 

handheld powered 

chipping tools

Use tool with water delivery system that 

supplies a continuous stream or spray of 

water at the point of impact.

• When used outdoors.

• When used indoors or in an 

enclosed area.

OR 

Use tool equipped with commercially 

available shroud and dust collection system.

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

Dust collector must provide the air flow 

recommended by the tool manufacturer, 

or greater, and have a filter with 99% or 

greater efficiency and a filter-cleaning 

mechanism. 

• When used outdoors.

• When used indoors or in an 

enclosed area.

None

APF 10

None

APF 10

APF 10

APF 10

APF 10

APF 10

Jackhammers and handheld powered 

chipping tools must be operated using either 

a water delivery system that supplies a 

continuous stream or spray of water at the 

point of impact, or a tool equipped with a 

commercially available shroud and vacuum 

dust collection system. Jackhammers and 

other handheld powered chipping tools must 

be operated and maintained in accordance 

with manufacturer’s instructions to minimize 

dust emissions.

If using the shroud and dust collection 

system, the vacuum dust collection 

system must provide at least the air flow 

recommended by the tool manufacturer, 

and have a filter with 99 percent or greater 

efficiency and a filter cleaning mechanism. 

The water delivery system is not required to 

be integrated or mounted on the tool; it can 

be assembled and installed by the employer. 

However, it must deliver a continuous stream 

or spray of water at the point of impact. 
18 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Full and proper implementation of water 

controls on jackhammers and other handheld 

powered chipping tools requires the 

employer to ensure that: 

■ An adequate supply of water for dust 

suppression is used; 

■ The water sprays are working properly 

and produce a pattern that applies water 

at the point of dust generation;

■ The spray nozzles are not clogged or 

damaged; and

■ All hoses and connections are intact. 

Acceptable water delivery systems include 

direct connections to fixed water lines or 

portable water tank systems. These water 

delivery systems can be operated by one 

worker or could require a second worker to 

supply the water at the point of impact. 

Full and proper implementation of dust 

collection systems requires the employer 

to ensure that:

■ The shroud is intact and installed in 

accordance with the manufacturer’s 

instructions; 

■ The hose connecting the tool to the 

vacuum is intact and without kinks or 

tight bends; 

■ The filter(s) on the vacuum are cleaned 

or changed in accordance with the 

manufacturer’s instructions; and 

■ The dust collection bags are emptied to 

avoid overfilling.

Respiratory protection with an APF of 10 is 

required when the task is done outdoors 

for more than four hours per shift, or when 

the task is done indoors or in an enclosed 

location regardless of task duration. 

When working indoors or in an enclosed 

space (areas where airborne dust can 

buildup, such as a structure with a roof 

and three walls), employers must provide 

additional exhaust, as needed to minimize 

the accumulation of visible airborne dust. See 

the section on Indoors or Enclosed Areas for 

more information. 

Jackhammer equipped with water spray delivery system to control dust. The 

water nozzle is mounted on the jackhammer frame just to the right of the 

chisel. Note the wet concrete on left from the water spray.

Photo courtesy of CPWR, Norman Zuckerman.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 19

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xi) Handheld grinders 

for mortar removal (i.e., 

tuckpointing)

Use grinder equipped with commercially 

available shroud and dust collection 

system. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

Dust collector must provide 25 cubic feet 

per minute (cfm) or greater of airflow per 

inch of wheel diameter and have a filter 

with 99% or greater efficiency and a 

cyclonic pre-separator or filter-cleaning 

mechanism.

APF 10 APF 25

Handheld grinders for mortar removal 

(i.e., tuckpointing). Tuckpointing involves 

removing deteriorating mortar from between 

bricks using a handheld grinder and replacing 

it with fresh mortar. 

The handheld grinders must be equipped 

with a commercially available shroud and 

dust collection system and operated and 

maintained in accordance with manufacturer’s 

instructions to minimize dust emissions. The 

dust collection system must provide at least 

25 cfm of air flow per inch of wheel diameter 

and have a filter that has a 99 percent or 

greater efficiency and either a cyclonic preseparator or a filter-cleaning mechanism. 

Cyclonic pre-separators and filter-cleaning 

mechanisms improve the suction of dust 

collection systems by preventing debris from 

building up on the filter. 

Full and proper implementation of dust 

collection systems on handheld grinders 

requires the employer to ensure that:

■ The shroud is intact, encloses most of 

the grinding blade, and is installed in 

accordance with the manufacturer’s 

instructions; 

■ The hose connecting the tool to the 

vacuum is intact and without kinks or tight 

bends; 

■ The filter(s) on the vacuum are cleaned 

or changed in accordance with the 

manufacturer’s instructions; 

■ The dust collection bags are emptied to 

avoid overfilling;

■ The blade is kept flush against the surface 

whenever possible; and 

■ The tool is operated against the direction 

of blade rotation, whenever practical. 
20 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

When using handheld grinders for mortar 

removal indoors or in enclosed areas (areas 

where airborne dust can buildup, such as 

a structure with a roof and three walls), 

employers must provide additional exhaust 

if needed to minimize the accumulation 

of visible airborne dust. See the section 

on Indoors or Enclosed Areas for more 

information on how to determine when those 

work situations apply. 

Respiratory protection with a minimum APF 

of 10 is required for work with handheld 

grinders for mortar removal lasting four 

hours or less in a shift. Respiratory protection 

with a minimum APF of 25 is required for 

work lasting more than four hours per shift.

Worker grinding mortar from between bricks with a handheld grinder 

equipped with a shroud and dust collection system. In addition, worker is 

using respiratory protection.

Photo courtesy of OSHA, International Masonry Institute.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 21

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xii) Handheld grinders for 

uses other than mortar 

removal

For tasks performed outdoors only:

Use grinder equipped with integrated 

water delivery system that continuously 

feeds water to the grinding surface. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

OR 

Use grinder equipped with commercially 

available shroud and dust collection system. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

Dust collector must provide 25 cubic feet 

per minute (cfm) or greater of airflow per 

inch of wheel diameter and have a filter 

with 99% or greater efficiency and a 

cyclonic pre-separator or filter-cleaning 

mechanism.

• When used outdoors.

• When used indoors or in an 

enclosed area. 

None

None

None

None

None

APF 10

Handheld grinders may also be used for tasks 

other than mortar removal, such as to remove 

thin layers of concrete and surface coatings. 

Two control options may be used: (1) A 

grinder equipped with an integrated water 

delivery system (supplied by the equipment 

manufacturer and developed specifically 

for the tool in use) that continuously feeds 

water to the grinding surface operated for 

outdoor work only; and (2) a dust collector 

equipped with a commercially available 

shroud and dust collection system with the 

same features as the dust collection system 

used for mortar removal for outdoor and 

indoor work. The dust collector must be rated 

to provide 25 cfm or greater air flow per inch 

of wheel diameter, have a filter with a 99 

percent or greater efficiency, and a cyclonic 

pre-separator or filter-cleaning mechanism. 

Cyclonic pre-separators and filter-cleaning 
22 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

mechanisms improve the suction of dust 

collection systems by preventing debris from 

building up on the filter. The grinder and both 

controls must be operated and maintained in 

accordance with manufacturer’s instructions 

to minimize dust emissions. 

The integrated water delivery system can 

be a free-flowing water system designed 

for blade cooling as well as manufacturers’ 

systems designed for dust suppression alone. 

This option applies only when grinders are 

used outdoors. 

Full and proper implementation of water 

controls on grinders requires the employer 

to ensure that: 

■ An adequate supply of water for dust 

suppression is used; 

■ The spray nozzles are working properly 

and produce a pattern that applies water 

at the point of dust generation;

■ The spray nozzles are not clogged or 

damaged; and 

■ All hoses and connections are intact.

Handheld grinders equipped with dust 

collection systems may be used outdoors or 

indoors. Full and proper implementation of 

dust collection systems on handheld grinders 

requires the employer to ensure that:

■ The shroud is intact and installed in 

accordance with the manufacturer’s 

instructions; 

■ The hose connecting the tool to the 

vacuum is intact and without kinks or 

tight bends; 

■ The filter(s) on the vacuum are cleaned 

or changed in accordance with the 

manufacturer’s instructions; and 

■ The dust collection bags are emptied to 

avoid overfilling.

Respiratory protection is not required when 

water-based dust suppression systems are 

used regardless of task duration. When dust 

collection systems are used, respiratory 

protection with a minimum APF of 10 is 

required only when engaged in a task indoors 

or in an enclosed location for more than four 

hours per shift.

When using handheld grinders indoors or in 

enclosed areas (areas where airborne dust 

can buildup, such as a structure with a roof 

and three walls), employers must provide 

additional exhaust as needed to minimize the 

accumulation of visible airborne dust. See 

the section on Indoors or Enclosed Areas for 

more information. 

Worker grinding concrete floor with grinder attached to dust 

collector (background).

Photo courtesy of the University of Washington.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 23

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xiii) Walk-behind milling 

machines and floor 

grinders

Use machine equipped with integrated 

water delivery system that continuously 

feeds water to the cutting surface. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

OR 

Use machine equipped with dust collection 

system recommended by the manufacturer. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to 

minimize dust emissions. 

Dust collector must provide the air flow 

recommended by the manufacturer, or 

greater, and have a filter with 99% or 

greater efficiency and a filter-cleaning 

mechanism. 

When used indoors or in an enclosed area, 

use a HEPA-filtered vacuum to remove 

loose dust in between passes.

None

None

None

None

Two control options may be used when 

using walk-behind milling machines and 

floor grinders. Regardless of control option 

used, the tool must also be operated 

and maintained in accordance with 

manufacturer’s instructions for minimizing 

dust emissions. 

Option one is to use an integrated water 

delivery system (supplied by the equipment 

manufacturer and developed specifically 

for the tool in use) that continuously feeds 

water to the cutting surface. Table 1 does not 

specify a minimum flow rate; however, water 

must be applied at flow rates specified by the 

manufacturer. 

Full and proper implementation of water 

controls on walk-behind milling machines 

and floor grinders requires the employer to 

ensure that: 

■ An adequate supply of water for dust 

suppression is used; 
24 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

■ The spray nozzles are working properly 

and produce a pattern that applies water 

at the point of dust generation;

■ The spray nozzles are not clogged or 

damaged; and

■ All hoses and connections are intact. 

Option two is to use a dust collection system 

recommended by the manufacturer of 

the milling machine or floor grinder and a 

filter with 99 percent or greater efficiency 

and a filter-cleaning mechanism. The dust 

collection system used must be capable of 

maintaining the air flow recommended by the 

manufacturer.

Full and proper implementation of dust 

collection systems on walk-behind milling 

machines and floor grinders requires the 

employer to ensure that:

■ The hose connecting the tool to the 

vacuum is intact and without kinks or 

tight bends; 

■ The filter(s) on the vacuum are cleaned 

or changed in accordance with the 

manufacturer’s instructions to prevent 

clogging; and 

■ The dust collection bags are emptied to 

avoid overfilling.

When using a dust collector system indoors 

or in enclosed areas (areas where airborne 

dust can buildup, such as a structure with 

a roof and three walls), loose dust must 

be cleaned with a HEPA-filtered vacuum in 

between passes of the milling machine or 

floor grinder to prevent the loose dust from 

being re-suspended. Removing loose dust 

with a HEPA vacuum also maximizes vacuum 

suction by improving the seal between the 

machine and floor. For indoor and enclosed 

spaces, employers must provide additional 

ventilation as needed to minimize the 

accumulation of visible airborne dust. See 

the section on Indoors or Enclosed Areas for 

more information. 

Respiratory protection is not required for 

work with walk-behind milling machines and 

floor grinders regardless of task duration.

Worker milling granite floor indoors with milling machine and dust collection 

system (background).

Photo courtesy of OSHA.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 25

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xiv) Small drivable 

milling machines (less 

than half-lane)

Use a machine equipped with supplemental 

water sprays designed to suppress dust. 

Water must be combined with a surfactant. 

Operate and maintain machine to minimize 

dust emissions.

None None

Small drivable milling machines must 

be used with supplemental water sprays 

designed to suppress dust and must be 

operated and maintained to minimize 

dust emissions. The water used must be 

combined with a surfactant. 

Full and proper implementation of water 

controls on small drivable milling machines 

requires the employer to ensure that: 

■ An adequate supply of water for dust 

suppression is used; 

■ The spray nozzles are working properly 

and produce a pattern that applies water 

at the point of dust generation;

■ The spray nozzles are not clogged or 

damaged; and

■ All hoses and connections are intact. 

When using small drivable milling machines 

indoors or in enclosed areas (areas where 

airborne dust can buildup, such as a 

structure with a roof and three walls), the 

employer must provide additional exhaust 

as needed to prevent the accumulation 

of visible airborne dust. See the section 

on Indoors or Enclosed Areas for more 

information on how to determine when 

those work situations apply. 

Respiratory protection is not required for work 

with small drivable milling machines (less than 

half-lane) regardless of task duration. 

Milling machine milling asphalt road and loading debris into haul truck.

U.S. Air Force photo, Beth Holliker. The equipment shown in this picture 

is for illustrative purposes only and is not intended as an endorsement by 

OSHA of this company, its products or services.
26 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xv) Large drivable 

milling machines (half-lane 

and larger)

For cuts of any depth on asphalt only:

Use machine equipped with exhaust ventilation 

on drum enclosure and supplemental water 

sprays designed to suppress dust. 

Operate and maintain machine to minimize 

dust emissions. 

For cuts of four inches in depth or less on 

any substrate:

Use machine equipped with exhaust ventilation 

on drum enclosure and supplemental water 

sprays designed to suppress dust. 

Operate and maintain machine to minimize 

dust emissions. 

OR

Use a machine equipped with supplemental 

water spray designed to suppress dust. 

Water must be combined with a surfactant.

Operate and maintain machine to minimize 

dust emissions. 

None

None

None

None

None

None

Employers whose employees operate large 

(one-half lane or wider) milling machines have 

two control options for cuts of four inches in 

depth or less on any substrate and one control 

option for cuts of greater than four inches 

in depth on asphalt. When using any of the 

control options, the machine must be operated 

and maintained to minimize dust emissions. 

When making cuts of greater than four inches 

on roadway material containing asphalt only, 

the only control option is to use a machine 

equipped with exhaust ventilation on the 

drum enclosure and supplemental water 

sprays designed to suppress dust.

When making cuts of four inches or less 

on any combination of roadway material 

(including asphalt and/or concrete), 

employers have two control options: (1) use 

a machine equipped with exhaust ventilation 

on the drum enclosure and supplemental 

water sprays designed to suppress dust; 

or (2) use a machine equipped with a 

supplemental water spray, combined with a 

surfactant, designed to suppress dust. 

When using the controls specified in Table 1, 

respiratory protection is not required for work 

with large drivable milling machines (half-lane 

or larger) regardless of task duration.

NOTE: Employers making cuts of greater than four inches 

on roadway material that is not asphalt only must follow the 

alternative exposure control methods approach.

Milling machine milling asphalt road and loading debris into a haul truck.

Photo courtesy of NIOSH. The equipment shown in this picture is for 

illustrative purposes only and is not intended as an endorsement by OSHA of 

this company, its products or services.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 27

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xvi) Crushing machines Use equipment designed to deliver water 

spray or mist for dust suppression at crusher 

and other points where dust is generated 

(e.g., hoppers, conveyers, sieves/sizing or 

vibrating components, and discharge points). 

Operate and maintain machine in 

accordance with manufacturer’s 

instructions to minimize dust emissions.

Use a ventilated booth that provides fresh, 

climate-controlled air to the operator, or a 

remote control station.

None None

When using crushing machines, employers 

must provide workers with a remote control 

station or ventilated booth that provides 

fresh, climate-controlled air to the operator. 

Water sprays or mists must be used for 

dust suppression at the crusher and other 

points where dust is generated (e.g., at 

hoppers, conveyors, sieves/sizing or vibrating 

components, and discharge points). See 

the section on Enclosed Cabs for more 

information on how to make sure enclosures 

meet the requirements of the rule. Table 1 also 

requires that the machine be operated and 

maintained according to the manufactures 

instructions to minimize dust emissions. 

The water spray systems can be installed 

so that they can be activated by remote 

control. To prevent airborne dust from being 

generated, full and proper implementation of 

controls requires that:

■ Nozzles are located upstream of dust 

generation points and positioned to 

thoroughly wet the material; 

■ The volume and size of droplets is adequate 

to sufficiently wet the material (optimal 

droplet size is between 10 and 150 μm); and

■ Spray nozzles are located far enough from 

the target area to provide complete water 

coverage but not so far that the water is 

carried away by wind. 

Respiratory protection is not required for 

crusher operators regardless of task duration.

Crushing machine being loaded with construction debris by an excavator 

Photo courtesy of Screen Machine Industries. The equipment shown 

in this picture is for illustrative purposes only and is not intended as an 

endorsement by OSHA of this company, its products or services.

Heavy equipment and utility vehicles include 

a variety of wheeled or tracked vehicles, 

ranging in size from large heavy construction 

equipment, such as bulldozers, scrapers, 

loaders, cranes and road graders, to smaller 

and medium-sized utility vehicles, such as 

tractors, bobcats and backhoes with attached 

tools. Table 1 has two entries for heavy 

equipment and utility vehicles based on the 

types of tasks performed with that equipment.
28 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xvii) Heavy equipment 

and utility vehicles used to 

abrade or fracture silicacontaining materials 

(e.g., hoe-ramming, rock 

ripping) or used during 

demolition activities 

involving silica-containing 

materials

Operate equipment from within an 

enclosed cab.

When employees outside of the cab are 

engaged in the task, apply water and/

or dust suppressants as necessary to 

minimize dust emissions. 

None

None

None

None

The next Table 1 entry is heavy equipment 

and utility vehicles used to abrade or fracture 

silica-containing materials (e.g., hoe-ramming, 

rock ripping) or used during demolition 

activities involving silica-containing materials.

These include activities such as fracturing or 

abrading rock and soil; demolishing concrete or 

masonry structures; and loading, dumping, and 

removing demolition debris. 

The operator must be in an enclosed cab. 

Modern heavy equipment already comes 

equipped with enclosed, filtered cabs that meet 

the requirements of Table 1. See the section on 

Enclosed Cabs for more information on how to 

make sure that the cab meets the requirements 

of the rule. When other employees are engaged 

in the task, water, dust suppressants, or both 

must also be applied as necessary to minimize 

dust emissions. 

Respiratory protection is not required for 

heavy equipment operators and laborers 

who assist heavy equipment operators 

during demolition activities involving silicacontaining materials or activities where silicacontaining materials are abraded or fractured, 

regardless of the duration of the task. 

NOTE: When the operator exits the enclosed 

cab and is no longer actively preforming 

the task, the operator is considered to have 

stopped the task. However, if other abrading, 

fracturing, or demolition work is performed 

by other heavy equipment and utility vehicles 

in the area while an operator is outside the 

cab, that operator is considered to be an 

employee “engaged in the task” and must be 

protected by the application of water and/or 

dust suppressants. 

Excavator equipped with an enclosed cab and hoe-ram demolishing a 

concrete wall. 

Photo courtesy of CPWR.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 29

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xviii) Heavy equipment 

and utility vehicles for 

tasks such as grading 

and excavating but not 

including demolishing, 

abrading, or fracturing 

silica-containing materials

Apply water and/or dust suppressants as 

necessary to minimize dust emissions. 

OR

When the equipment operator is the only 

employee engaged in the task, operate 

equipment from within an enclosed cab.

None

None

None

None

Heavy equipment and utility vehicles used 

for tasks such as grading and excavating do 

not involve demolition or the fracturing or 

abrading of silica. Tasks include earthmoving, 

grading, and excavating; other activities such 

as moving, loading, and dumping soil and 

rock; and dumping and grading of ballast 

in the railroad industry, which is generally 

subject to OSHA’s Construction standards. 

Employers have two control options when the 

operator is the only employee engaged in the 

task and one option when employees other 

than the operator are engaged in the task. The 

first option requires the equipment operator 

to operate the equipment within an enclosed 

cab when the operator is the only employee 

in the area. Most heavy equipment already 

comes equipped with enclosed, filtered 

cabs that meet the requirements of Table 1. 

See the section on Enclosed Cabs for more 

information on how to make sure that the cab 

meets the requirements of the rule.

The second option requires the application of 

water and/or dust suppressants as necessary 

to minimize dust emissions. Water must be 

applied at rates sufficient to minimize release 

of visible dust. The following scenarios are 

examples of when the employer must use 

water and/or dust suppressants as necessary 

to minimize dust emissions: (1) equipment for 

grading and excavating is not equipped with 

enclosed, pressurized cabs or (2) employees 

other than the operator are engaged in 

the task. If water or dust suppressants are 

applied as necessary to minimize visible dust, 

the employer need not provide an enclosed, 

filtered cab for the operator.

Respiratory protection is not required for 

work with heavy equipment when it is 

operated from within an enclosed cab, or 

when water or other dust suppressants are 

used, regardless of task duration. 

Earthmoving using a dozer equipped with enclosed operator cab.

Photo courtesy of NIOSH.
30 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Water Delivery Systems 

Integrated water delivery systems are 

required for several types of equipment in 

Table 1. Integrated water systems must be 

be supplied by the equipment manufacture 

and developed specifically for the tool in use 

so they will apply water at the appropriate 

dust emission points based on tool 

configuration and do not interfere with other 

tool components or safety devices. Water 

systems designed for blade cooling also 

suppress dust and meet the requirements for 

Table 1. 

The water must be applied at flow rates 

sufficient to minimize release of visible 

dust. Effective control of the dust depends 

on factors such as dust particle size, dust 

particle velocity, spray nozzle size and 

location, use of surfactants or other binders, 

and environmental factors (water hardness, 

humidity, weather, etc.), all of which must be 

considered when using wet methods. The 

appropriate water flow rates for controlling 

silica dust emissions can vary; therefore, 

it is necessary to follow manufacturers’ 

instructions when determining the required 

flow rate for dust suppression systems on a 

given worksite. 

Any slurry generated when using water to 

suppress dust should be cleaned up to limit 

secondary exposure to silica dust when the 

slurry dries following procedures described in 

the employer’s Written Exposure Control Plan. 

When working in cold temperatures, where 

there is a risk of water freezing, additional 

work practices such as insulating drums, 

wrapping drums with gutter heat tape or 

adding environmentally-friendly antifreeze 

additives to water may be needed.

Dust Collection Systems

Commercially available dust collection 

systems (i.e., LEV) are required for several 

types of equipment in Table 1. This 

requirement ensures that employers use 

equipment that is designed to effectively 

capture dust generated by the tool being 

used and does not introduce new hazards 

such as obstructing or interfering with safety 

mechanisms. 

The “commercially available” limitation 

is meant only to eliminate on-site 

improvisations of equipment by the 

employer. Employers can use products that 

are made by aftermarket manufacturers 

(someone other than the original tool 

manufacturer) that are intended to fit the 

make and model of the tool. This includes 

custom-designed products made to meet 

the particular needs and specifications of 

the employer purchasing the product. These 

systems are designed to work effectively 

with the equipment and not introduce new 

hazards such as obstructing or interfering 

with safety mechanisms. When employers 

use methods other than commercially 

available systems for dust suppression, they 

must conduct exposure assessments and 

comply with the PEL.

Some Table 1 entries for dust collection 

systems specify use of cyclonic preseparators and filter cleaning mechanisms to 

prevent buildup of debris on filters that result 

in less dust capture. A cyclonic pre-separator 

collects large debris before the air reaches 

the filters. A filter cleaning mechanism 

prevents the need for manually cleaning 

filters to prevent buildup of debris (caking). 

Some vacuums are equipped with a gauge 

indicating filter pressure or an equivalent 

device (e.g., timer to periodically pulse the 

filter) to help employees in determining when 

it is time to run a filter cleaning cycle. 

Indoors or Enclosed Areas

Several Table 1 entries refer to tasks 

performed “outdoors” or “indoors or in an 

enclosed area.” Indoors or in an enclosed 

areas mean areas where airborne dust can 

build up unless additional exhaust is used. 

For example, a work area with only a roof 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 31

that does not affect the dispersal of dust 

would not be considered enclosed; however, 

an open-top structure with three walls and 

limited air movement or a roof that does limit 

dispersal would be considered enclosed.

Sufficient air circulation in enclosed or indoor 

environments is important to ensure the 

effectiveness of the control strategies and to 

prevent the accumulation of airborne dust. 

Employers following Table 1 are required 

to provide a means of exhaust as needed 

to minimize the accumulation of visible 

airborne dust for tasks performed indoors 

or in enclosed areas. The means of exhaust 

necessary could include: the use of portable 

fans (box fans, floor fans, axial fans), portable 

ventilation systems, or other systems that 

increase air movement and assist in the 

removal and dispersion of airborne dust. To 

be effective, the ventilation must be set up so 

that movements of employees during work, 

or the opening of doors and windows, will 

not negatively affect the airflow. 

Enclosed Cabs

Enclosed cabs or booths are specified for 

rock drilling, crushers, and heavy equipment. 

Employers must ensure that the enclosed cab 

or booth is: 

■ Maintained as free as practicable from 

settled dust; 

■ Has door seals and closing mechanisms 

that work properly; 

■ Has gaskets and seals that are in good 

condition and work properly; 

■ Is under positive pressure maintained 

through continuous delivery of filtered air; 

■ Has intake air that is filtered through a prefilter that is 95% efficient in the 0.3-10.0 

μm range (e.g., MERV-16 or better); an

■ Has heating and cooling capabilities.

The controls for enclosed cabs lower the 

potential for dust to be re-suspended inside 

the cab or enter the enclosed cab or booth. 

They also ensure that the filtered air provided 

to the employee does not contain silica 

particles and that the working conditions in 

the cab are comfortable so that employees are 

less likely to open windows and be exposed.

The procedures for maintaining and cleaning 

the cab or booth, and for frequent and regular 

inspections of the cabs and booths, must be 

addressed through the employer’s Written 

Exposure Control Plan and Competent Person

requirements described below.

Determining Task Duration and 

Requirements for Respirator Use 

Respirator requirements in Table 1 are 

divided by task duration: 

■ “Less than or equal to four hours/shift” and, 

■ “Greater than four hours/shift”.

Each of the following scenarios is considered 

a “shift” for purposes of determining the 

maximum amount of time that an employee 

may spend on Table 1 tasks without 

respiratory protection: 

■ A standard 8-hour work period;

■ A day with a break between work periods 

(e.g., four hours on, two hours off, four 

hours on);

■ Work periods longer than eight hours; 

■ Double shifts within a single day; 

■ A work period spanning two calendar days 

(e.g., 8 p.m. until 4 a.m.). 

Task duration time starts when the 

operator begins using the tool, and 

continues to be counted until he or she 

completes the task. This time includes 

intermittent breaks in tool usage and cleanup. However, tasks that are performed 

multiple times per day, during distinct time 

periods, should be counted as separate 

tasks, and times should be combined.

The requirement to provide respirators is 

based on the anticipated duration of the task. 
32 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Employers must make a good-faith judgment 

of the task’s anticipated duration over the work 

shift, whether performed continuously or 

intermittently, based on previous experience 

and all other available information. 

If an employer estimates that an employee 

will perform a single task for four hours or 

less during a single shift, then the employer 

must ensure that the employee uses 

whichever respirator, if any, is specified in 

the “≤ 4 hr/shift” column in Table 1. If an 

employer estimates that the task will take 

more than four hours, then the employer 

must ensure that the employee uses any 

respiratory protection specified in the “> 4 hr/

shift” column in Table 1, during the entire 

task, not just during the time beyond the first 

four hours that the task is performed. 

If an employer anticipates that a task will take 

four hours or less, but unforeseen difficulties 

will extend the task duration beyond four 

hours, the employer is required to provide the 

listed respiratory protection as soon as it 

becomes evident that the duration of the task 

may exceed the 4-hour limit, measured from 

the beginning of the task. 

Where an employee performs more than one 

task in Table 1 during the course of a shift, 

and the total duration of all tasks combined 

is less than four hours, the required 

respiratory protection for each task is the 

respiratory protection specified in the less 

than four hours per shift column. If the total 

duration of all Table 1 tasks combined is 

more than four hours per shift, the required 

respiratory protection for each task is the 

respiratory protection specified in the more 

than four hours per shift column. As was 

discussed for single tasks, if multiple tasks 

are estimated to last less than 4 hours, but 

it becomes evident that the tasks will take 

more than four hours total, the employer 

must reexamine respiratory protection 

requirements and immediately provide a 

respirator, when required.

Examples of Determining Task Durations 

1. Tasks with intermittent breaks. An 

employee cuts and places bricks, one at a 

time, for four hours consecutively and then 

spends 30 minutes cleaning up the saw and 

emptying slurry or dust collectors. All four 

hours spent cutting and laying bricks along 

with the 30 minutes for clean-up count for a 

total task duration of four and a half hours.

2. Tasks with distinct time periods. An 

employee cuts multiple bricks for 15 minutes, 

lays bricks for two hours before returning to 

cut more bricks for another 30 minutes. The 

total task duration is 45 minutes

Examples of Respiratory Protection 

Requirements for Single Tasks in Table 1

1. An employer anticipates that it will take 

an employee 3 hours to cut concrete walls 

using a handheld power saw (outdoors). No 

respiratory protection is required. 

2. An employer anticipates that it will take an 

employee 5 hours to demolish an asphalt 

road using a jackhammer (outdoors). The 

employer must provide a respirator with 

an APF of 10 and ensure that the employee 

wears it for the entire duration of the task.

3. An employer anticipates that it will take an 

employee 3 hours to grind a concrete floor 

(indoors) and, therefore, determines that 

respiratory protection is not required under 

Table 1. However, at two hours, the employer 

determines that it will take more than 4 hours 

to complete the task. The employer must 

provide a respirator with an APF of 10 at that 

time and ensure that the employee wears it 

for the remaining duration of the task.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 33

Examples of Respiratory Protection Requirements for Employees who do more than 

one Table 1 Task

1. An employer anticipates that an employee will use a handheld grinder on a concrete wall outdoors for 

3 hours and then use a chipping hammer outdoors for 2 hours (total Table 1 task duration of 5 hours per 

shift). The employer looks in the “> 4 hour/shift” column for each task to determine that no respiratory 

protection is required during use of the handheld grinder outdoors, but a respirator with an APF of 10 is 

required during use of the chipping hammer outdoors.

2. An employer anticipates that an employee will use a stationary masonry saw to cut bricks for 1 hour 

and use a handheld power saw to cut concrete indoors for 1 hour over the course of a shift (total Table 

1 task duration of two hours per shift). The employer looks in the “≤ 4 hour/shift” column for each task 

to determine that no respiratory protection is required during use of the stationary masonry saw, but a 

respirator with an APF of 10 is required during use of the handheld power saw indoors. 

3. An employer anticipates that an employee will drive a half-lane milling machine for 4 hours and then 

operate a walk-behind milling machine equipped with an integrated water delivery system for 4 hours 

(total Table 1 task duration of 8 hours). The employer looks in the “> 4 hour/shift” column for each task 

to determine that no respiratory protection is required for either task. 
34 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

ALTERNATIVE EXPOSURE CONTROL METHODS – 

PARAGRAPH (D) OF THE STANDARD

Employers that conduct tasks not listed in 

Table 1 or do not fully and properly implement 

the engineering controls, work practices, and 

respiratory protection described in Table 1 

of the specified exposure control methods 

approach must follow the alternative exposure 

control methods approach. The alternative 

exposure control methods approach involves 

assessing employee exposure to respirable 

crystalline silica, and limiting exposure to 

the PEL using feasible engineering and work 

practice control methods, and respiratory 

protection when necessary. Each of the three 

components of alternative exposure control 

methods – the PEL, exposure assessment, and 

methods of compliance – is explained below. 

Permissible Exposure Limit (PEL)

Employers complying with the alternative 

exposure control methods must ensure that 

their employees’ exposures to respirable 

crystalline silica do not exceed the PEL, which 

is 50 μg/m as an 8-hour TWA. This means 

that over the course of any 8-hour work shift, 

exposures can fluctuate, but the average 

exposure to respirable crystalline silica cannot 

exceed 50 μg/m3. The PEL applies to the three 

forms of respirable crystalline silica that are 

covered by the standard: quartz, cristobalite, 

and trydimite. Quartz is by far the most 

common form of crystalline silica found at 

construction workplaces, and in most cases, 

quartz will be the only form of respirable 

crystalline silica analyzed in air samples used 

to measure employee exposures. 

Exposure Assessment

Construction employers following alternative 

exposure control methods must assess the 

8-hour TWA exposure for each employee 

who is or may reasonably be expected to be 

exposed to respirable crystalline silica at or 

above the action level of 25 μg/m as an 

8-hour TWA. The purposes of assessing 

employee exposures include: identifying 

where exposures are occurring; helping the 

employer select control methods and make 

sure those methods are effective; preventing 

employees from being exposed above the 

PEL; providing employees with information 

about their exposure levels; and allowing the 

employer to give the PLHCP performing 

medical examinations information about 

employee exposures. 

Calculation of TWA Exposures

Both the PEL and the action level are expressed 

as TWA exposures. TWA measurements 

account for variable exposure levels over the 

course of a work shift by averaging periods of 

higher and lower exposures. The TWA exposure 

for an 8-hour work shift is calculated using a 

simple formula:

TWA = (Ca Ta + Cb Tb . . . Cn Tn) ÷ 8

Where: 

TWA is the time-weighted average exposure 

for the work shift

C is the concentration during any period of time (T) 

where the concentration remains constant; and 

T is the duration in hours of the exposure at the 

concentration (C)

For example, assume that an employee is 

exposed to respirable crystalline silica in an 

8-hour workday as follows: 

Two hours exposure at 100 μg/m3

Two hours exposure at 50 μg/m3

Four hours exposure at 10 μg/m3

Entering this information in the formula, we get: 

(2 x 100 + 2 x 50 + 4 x 10) ÷ 8 = 42.5 μg/m3

Because 42.5 μg/m3 is higher than 25 μg/m3, 

this employee’s TWA exposure would be above 

the action level, but below the PEL of 50 μg/m3

. 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 35

Employers can choose between two options 

for assessing exposures: 

■ The performance option; or

■ The scheduled monitoring option.

Performance Option. The performance option 

gives employers flexibility to determine the 

8-hour TWA exposure for each employee 

based on any combination of air monitoring 

data or objective data that can accurately 

characterize employee exposures to 

respirable crystalline silica. 

Air monitoring data are any results of air 

monitoring (analyzed according to the 

procedures and requirements in Appendix 

A) that the employer has done to meet the 

requirements of the standard. 

Objective data is information that 

demonstrates employee exposure to 

respirable crystalline silica associated with a 

particular product or material or a specific 

process, task, or activity. The data must 

reflect workplace conditions that closely 

resemble or could result in higher exposures 

than the processes, types of material, 

control methods, work practices, and 

environmental conditions in the employer’s 

current operations. 

Examples of objective data are information 

such as:

■ Air monitoring data from industry-wide 

surveys;

■ Calculations based on the composition of 

a substance;

■ Area sampling results and exposure 

mapping profile approaches; and 

■ Historical air monitoring data collected by 

the employer.

Employers choosing the performance 

option must:

■ Conduct the exposure assessment before 

work begins;

■ Reassess exposures whenever a change 

in production, process, control equipment, 

personnel, or work practices may 

reasonably be expected to result in new 

or higher exposures at or above the action 

level, or when the employer has any reason 

to believe that new or additional exposures 

at or above the action level have occurred;

■ Be able to demonstrate that employee 

exposures have been accurately 

characterized; and

■ Make sure that the exposure assessment 

reflects the exposures of employees on 

each shift, for each job classification, in 

each work area.

Examples of Using Objective Data to Conduct Exposure Assessments under the 

Performance Option

1. Industry-wide surveys of typical tasks or operations, which include well-documented procedures for 

measuring exposures and methods for controlling dust, could be used by employers to characterize 

employee exposures where employees perform tasks consistent with those described in the survey.

2. Employers can use direct-reading instruments to measure real-time levels of respirable dust in the 

air. If the employer has information on the percentage of respirable crystalline silica in that dust (for 

example, from the analysis of a bulk sample or information from a safety data sheet), he or she can 

then calculate the level of respirable crystalline silica in air.

3. Historical air monitoring data collected by the employer could be used to assess employee 

exposures if the employer can show that the data were collected during work operations and 

conditions that are consistent with the processes, types of material, control methods, work 

practices, and environmental conditions in the employer’s current operations.
36 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

The performance option may be especially 

useful when measuring employee exposures 

is challenging, such as when tasks are 

conducted for short durations of time or 

performed under different weather conditions. 

The performance option gives employers 

flexibility for characterizing the exposures 

of all employees. For example, instead 

of conducting air monitoring on two 

employees who perform the same job 

on different shifts, the employer could 

determine that there are no differences in 

exposure between those two employees, 

and characterize the exposure of the second 

employee based on the air monitoring 

results of the first employee.

Under the performance option, employers 

can characterize employee exposure within 

a range to account for exposure variability. 

Employers can also use that option to 

show that exposures exceed the PEL by a 

certain level, such as less than 10 times the 

PEL, after using all feasible controls. The 

employer would then know that he or she 

must provide respiratory protection with 

an APF of at least 10, as well as medical 

surveillance for employees required to wear 

a respirator under the silica standard for 

30 or more days per year.

Scheduled Monitoring Option. The scheduled 

monitoring option lets employers know when 

and how often they must perform exposure 

monitoring to measure employee exposures. 

When following the scheduled monitoring 

option, employers must make sure that: 

■ Results represent the employee’s TWA 

exposure to respirable crystalline silica 

over an eight-hour workday; 

■ Samples are collected from the 

employee’s breathing zone; and 

■ Samples are collected outside respirators so 

that they represent the exposure that would 

occur without the use of the respirator.

OSHA intends for employers using the 

scheduled monitoring option to conduct 

initial monitoring as soon as work begins so 

that they are aware of exposure levels and 

where control measures are needed.

Under the scheduled monitoring option, just 

as under the performance option, employers 

must correctly characterize each employee’s 

exposure to respirable crystalline silica. 

Exposure monitoring must include, at a 

minimum, one full-shift sample taken for each 

job function in each job classification, in each 

work area, and on each shift. Characterizing 

each employee’s exposure may involve 

monitoring all exposed employees or a smaller 

number of employees whose exposures can 

then represent those of other employees.

Representative sampling involves monitoring 

the employee or employees reasonably 

expected to have the highest exposure to 

respirable crystalline silica (for example, the 

employee closest to an exposure source). 

This exposure is then assigned to the other 

employees in the group who perform the 

same tasks on the same shift and in the same 

work area.

Representative monitoring is allowed when 

several employees perform the same job on 

the same shift and under the same conditions. 

How Often Employers Must Monitor under 

the Scheduled Monitoring Option. Under the 

scheduled monitoring option, how often 

monitoring must be done depends on the 

results of initial monitoring and, thereafter, 

any required further monitoring, as follows:

■ If the initial monitoring indicates that 

employee exposures are below the action 

level, no further monitoring is required. 

■ If the most recent exposure monitoring 

reveals employee exposures at or above 

the action level but at or below the PEL, the 

employer must repeat monitoring within 

six months of the most recent monitoring. 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 37

■ If the most recent exposure monitoring 

reveals employee exposures above the PEL, 

the employer must repeat monitoring within 

three months of the most recent monitoring. 

■ When two non-initial monitoring results 

taken consecutively, at least 7 days 

apart but within 6 months of each other, 

are below the action level, employers 

may stop monitoring for employees 

represented by those results, as long as 

no changes occur that could reasonably 

be expected to result in new or additional 

exposures at or above the action level.

Reassessment of Exposures. The employer 

must reassess exposures whenever a change 

in production, process, control equipment, 

personnel, or work practices may reasonably 

be expected to result in new or additional 

exposures to respirable crystalline silica 

at or above the action level, or when the 

employer has any reason to believe that 

new or additional exposures at or above the 

action level have occurred. For example, 

reassessment would be required when a 

task performed in an open, outdoor location 

is moved to an enclosed or confined space, 

because the change in conditions could 

reasonably be expected to result in higher 

exposures to respirable crystalline silica. 

Employers do not have to conduct additional 

monitoring simply because a change has 

occurred, so long as the change is not 

reasonably expected to result in new or 

additional exposures to respirable crystalline 

silica at or above the action level. For 

example, reassessment is not required when 

a task is moved from an indoor to an outdoor 

location, or when a product is replaced with 

another product that has lower crystalline 

silica content in the same process. 

Methods of Sample Analysis (Appendix A 

of the Standard). Appendix A of the silica 

standard lists laboratory procedures for 

measuring respirable crystalline silica in air 

samples. Employers must make sure that all 

air samples taken to meet the requirements 

of the silica standard are analyzed by a 

laboratory that follows the procedures in 

Appendix A. If employers hire an outside 

laboratory to do the analyses for respirable 

crystalline silica, they can rely on a statement 

from that laboratory that it follows Appendix 

A. For example, the laboratory could indicate 

that it analyzes samples according to 

Appendix A of the standard in the laboratory 

report or on its website. 

Employee Notification. Employers must notify 

each affected employee of the results of 

the exposure assessment within 5 working 

days of completing it. “Affected” means all 

employees whose exposures were assessed, 

including employees whose exposures were 

represented by other employees’ exposure 

measurements, and those whose exposure 

assessments were based on objective data. 

The 5-day period for notification starts when:

■ An employer following the performance 

option finishes the exposure assessment; or 

■ An employer following the scheduled 

monitoring approach receives the 

laboratory results. 

Employers must either notify each employee in 

writing or post the results in a location that all 

affected employees can access. In cases where 

an employee might have moved onto another 

job or jobsite, the assessment results could be 

included with the employees’ final paycheck.

Exposures can be characterized and reported 

as a range (for example, between the action 

level and the PEL), but must reflect exposures 

that would occur if the employee were not 

using a respirator.

When an exposure assessment reveals 

exposures above the PEL, the written 

notification must also describe the corrective 

action the employer is taking to reduce 

employee exposures to or below the PEL. 

Corrective actions include engineering 

controls. However, if engineering controls 

are not feasible or the employer needs more 

than 5 days to identify the right engineering 
38 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

controls, respiratory protection is the 

corrective action that would be described in 

the written notification. 

Observation of Monitoring. The employer 

must let affected employees or their 

designated representatives observe any 

air monitoring of employee exposure 

to respirable crystalline silica. When 

observation of monitoring requires entry into 

an area where use of protective clothing or 

equipment, such as a respirator, is required, 

the employer must provide the observer 

with that protective clothing or equipment. 

The employer must provide the protective 

clothing and equipment at no cost, and 

make sure that the observer uses such 

clothing or equipment.

However, if the observer does not need to 

enter an area requiring the use of protective 

clothing or equipment in order to effectively 

observe monitoring (for example, if 

monitoring can be viewed from outside the 

hazardous areas), no protective clothing or 

equipment would be needed. 

Methods of Compliance

Employers following alternative exposure 

control methods must comply with the 

methods of compliance requirements of 

the standard. The methods of compliance 

section of the standard requires employers 

to protect employees following the hierarchy 

of controls, which relies on engineering 

and work practice controls for reducing 

exposures and allows for respirator use, 

in addition to those controls, only when 

feasible engineering controls cannot 

reduce exposures to acceptable levels. The 

methods of compliance section also crossreferences other OSHA standards that apply 

to abrasive blasting.

Engineering and Work Practice Controls.

Employers must use engineering and 

work practice controls to reduce and keep 

employee exposure to respirable crystalline 

silica to or below the PEL of 50 μg/m3,

unless the employer can demonstrate that 

such controls are not feasible. If feasible 

engineering and work practice controls are 

not able to reduce employee exposures to 

or below the PEL, employers must still use 

feasible controls to reduce exposures to the 

lowest possible level and then use respiratory 

protection along with those controls. 

The main types of engineering controls for 

silica are wet methods and local exhaust 

ventilation. Wet methods involve applying 

water or foam at the point of dust generation 

to keep dust from getting into the air. An 

example is an integrated water delivery 

system on a stationary masonry saw. 

Local exhaust ventilation removes dust by 

capturing it at or near the point where it is 

created. An example is a dust collector for a 

handheld grinder. 

Another engineering control is isolation. 

Isolation separates employees from the dust 

source by containing the dust or isolating 

employees. An example is a properly 

ventilated cab on heavy equipment.

Work practice controls involve performing a 

task in a way that reduces the likelihood or 

levels of exposure. Work practice controls 

are often used with engineering controls 

to protect employees. Employees must 

know the appropriate work practices for 

maximizing the effectiveness of controls and 

minimizing exposures. Examples of work 

practice controls include: 

■ Inspecting and maintaining controls to 

prevent or fix malfunctions that would 

result in increased exposures;

■ Making sure that nozzles spray water 

at the point of dust generation for wet 

method controls;
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 39

■ Making sure that hoses are not kinked on a 

tool used with a dust collector; 

■ Wetting down silica dust before sweeping 

it up; and

■ Scheduling work so that tasks that involve 

high exposures are performed when no 

other employees are in the area.

Reducing exposures through the primary use 

of engineering and work practice controls is 

known as the hierarchy of controls, and it is 

a long-standing OSHA policy. Advantages of 

engineering controls are that they:

■ Control crystalline silica-containing 

dust particles at the source, thus 

minimizing exposures to all persons in the 

surrounding work area; 

■ Are reliable, predictable, and provide 

consistent levels of protection to a large 

number of employees; 

■ Can be monitored; and

■ Are less prone to human error than the 

use of personal protective equipment. 

Under the hierarchy of controls, respirators 

can be another effective way to protect 

employees. However, respirators may be 

less practical or effective than engineering 

controls for the following reasons: 

■ They must be selected for each worker, 

fitted, occasionally refitted, and regularly 

maintained (including replacing filters and 

other parts as necessary). 

■ Employees have to consistently and 

correctly use properly fitted respirators 

but may resist wearing them because 

respirators can be uncomfortable, 

especially in hot weather. 

■ Respirators may put a physical strain 

on employees’ bodies, as a result of the 

respirator’s weight and because they 

increase breathing resistance. Employees 

with some health conditions cannot wear 

respirators because the physical strain of 

wearing the respirator increases their risk 

of illness, injury, and even death. 

■ Respirators can create safety concerns 

because they interfere with workers’ 

ability to hear, see, smell, and 

communicate. 

■ Respirators only protect the employees 

wearing them. 

Even when engineering and work practice 

controls cannot reduce exposure levels 

to or below the PEL, those controls must 

be used to reduce exposures as low as 

possible. This reduction in exposure levels 

benefits employees by reducing the required 

protection factor of the respirator, and thus 

increasing the choices of respirators that can 

be used. For example, if feasible engineering 

controls reduce exposures from 50 times to 

less than 10 times the PEL, employers could 

provide approved half-mask respirators with 

an APF of 10 that may be lighter and easier to 

use compared to full-facepiece respirators.

Abrasive Blasting. In addition to complying 

with requirements to use engineering controls 

and work practices according to the hierarchy 

of controls, construction employers that 

conduct abrasive blasting operations using 

crystalline silica-containing blasting agents or 

conduct abrasive blasting on structures that 

contain crystalline silica must also comply 

with other relevant standards, such as the 

ventilation standard for construction (29 CFR 

1926.57), which contains requirements for 

ventilation and personal protective equipment, 

including respirators. This is simply a crossreference to other standards that construction 

employers must comply with when 

conducting abrasive blasting.
40 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

RESPIRATORY PROTECTION – PARAGRAPH (E) 

OF THE STANDARD

Employers must provide employees with 

appropriate respirators where required by the 

silica standard. The respirators must comply 

with requirements of the silica standard and 

with OSHA’s Respiratory Protection standard 

(29 CFR 1910.134). 

Employers who follow the specified exposure 

control methods listed in Table 1 must 

provide respiratory protection where required 

by Table 1. Employers who follow alternative 

exposure control methods must provide 

respiratory protection:

■ Where exposures exceed the PEL during 

periods necessary to install or implement 

feasible engineering and work practice 

controls;

■ Where exposures exceed the PEL during 

tasks, such as some maintenance and 

repair tasks, for which engineering and 

work practice controls are not feasible;

■ During tasks in which the employer has 

implemented all feasible engineering 

and work practice controls but exposures 

remain above the PEL. 

Where respirator use is required, employers 

must implement a respiratory protection 

program in accordance with the respiratory 

protection standard. The respiratory protection 

program ensures that respirators are properly 

used in the workplace and are effective 

in protecting employees. See the Small 

Entity Compliance Guide for the Respiratory 

Protection Standard for information on the 

requirements of that standard.

If an employer following the specified 

exposure control methods fully and properly 

implements the engineering controls, work 

practices, and respiratory protection required 

in Table 1, the employer will be considered to 

be in compliance with the requirements of the 

silica standard and the respiratory protection 

standard for identifying and evaluating 

respiratory hazards and providing each 

employee with an appropriate respirator. 

Employers following Table 1 must comply 

with all other requirements of the Respiratory 

Protection standard.

Voluntary Use of Respirators

Employers may provide respirators at the 

request of employees or let employees use 

their own respirators when respirators 

are not required under the silica standard. 

See the Small Entity Compliance Guide for 

the Respiratory Protection Standard for 

information about employer responsibilities 

when employees voluntarily wear respirators. 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 41

HOUSEKEEPING – PARAGRAPH (F) OF THE STANDARD

The respirable crystalline silica standard 

requires all construction employers covered 

by the standard, including those who 

fully and properly implement the control 

methods specified in Table 1, to avoid certain 

housekeeping practices. When cleaning 

up dust that could contribute to employee 

exposure to respirable crystalline silica, 

employers must: 

■ Not allow dry brushing or dry sweeping, 

unless methods such as wet sweeping and 

HEPA-filtered vacuuming are not feasible; 

■ Not allow cleaning of surfaces or 

clothing with compressed air, unless the 

compressed air is used together with 

a ventilation system that effectively 

captures the dust cloud or no other 

cleaning method is feasible.

Cleaning methods such as dry sweeping, 

dry brushing, and use of compressed air can 

cause respirable crystalline silica dust to get 

into the air and be inhaled by employees. 

Therefore, the silica standard limits the 

use of these cleaning methods to prevent 

unnecessary exposures to employees. 

Employers are required to use other cleaning 

methods such as wet sweeping and HEPAfiltered vacuums, whenever feasible, because 

such methods reduce employee exposures 

by preventing silica-containing dust from 

getting into the air. 

Feasibility of Cleaning Methods

In a very limited number of cases, cleaning 

methods such as wet sweeping or HEPAfiltered vacuums may not be safe or effective. 

When wet methods or HEPA-filtered 

vacuuming would not be effective, would 

cause damage, or would create a hazard in 

the workplace, the employer is not required to 

use these cleaning methods. However, even 

in cases where one of those cleaning methods 

may not be safe or effective, employers could 

often use another acceptable method for 

cleaning. For example, if it is not feasible to 

wet sweep a wood floor because water would 

damage the wood or cause mold growth, 

a HEPA-filtered vacuum could be used for 

cleaning. Therefore, situations in which no 

acceptable cleaning methods can be used are 

expected to be very rare. 

In those rare cases where the employer 

needs to use cleaning methods such as dry 

sweeping, dry brushing, or compressed air, 

the employer must be able to show why 

cleaning methods that decrease employee 

exposures are not feasible.

When Employers Must Follow 

Housekeeping Practices

The housekeeping requirements in the 

silica standard apply only where cleaning 

“could contribute to employee exposure 

to respirable crystalline silica”. This phrase 

clarifies that employers have to follow the 

housekeeping requirements of the silica 

standard only where employees could 

be exposed to the very small (respirable) 

crystalline silica particles created by highenergy tasks such as drilling, cutting, 

grinding, or crushing crystalline-silicacontaining materials. Employers are not 

required to follow these housekeeping 

requirements when cleaning ordinary soil, 

large debris, and non-silica-containing 

materials, such as sawdust.
42 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

WRITTEN EXPOSURE CONTROL PLAN – PARAGRAPH (G) 

OF THE STANDARD

All employers covered by the standard, 

including employers who fully and properly 

implement the specified exposure controls 

in Table 1, must develop and implement 

a written exposure control plan. Written 

exposure control plans describe workplace 

exposures and ways to reduce those 

exposures, such as engineering controls, 

work practices, housekeeping methods, 

and restricting access to areas where 

high exposures occur. The plans improve 

employee protections by making sure that 

employers identify all exposures and controls 

to prevent overexposures. Such plans are 

also useful for letting employees know what 

kind of protections they should expect to see 

on the job. 

What Must be Included in a Written 

Exposure Control Plan

Below is a list of what the employer must 

include in each section of the written 

exposure control plan, with general examples 

of the types of information that could be 

included and sample entries for the use of a 

stationary masonry saws for cutting bricks. 

The plan must include a description of 

workplace tasks involving exposures to 

respirable crystalline silica. Employers must 

list all tasks that employees perform that 

could expose them to respirable crystalline 

silica dust. This section could also describe 

the equipment used and factors that affect 

exposures, such as types of silica-containing 

materials handled in those tasks (concrete or 

tile), weather conditions (wind or humidity), 

soil types (clay versus rock), and if tasks 

are done outdoors versus indoors or in 

enclosed locations.

Example: Cutting bricks using a stationary 

masonry saw outdoors.

The plan must include a description of 

engineering controls, work practices, and 

respiratory protection used to limit employee 

exposure to respirable crystalline silica for 

each task. For each task that employees 

perform, employers must describe types 

of controls used, like a dust collector with 

manufacturer’s recommended air flow and 

a filter with 99 percent efficiency, effective 

work practices, as in checking that water 

nozzles are not plugged, and if required, 

appropriate respiratory protection, like a 

respirator with an APF of 10. Employers could 

also describe signs that controls are not 

working effectively, such as an increase in 

visible dust or no water being delivered to the 

saw blade. 

This section of the written exposure control 

plan is especially important for construction 

employers who use controls in Table 1, 

because they are not required to measure 

exposures to make sure that controls are 

working. Therefore, including information 

such as manufacturer’s instructions for 

operating and maintaining tools to decrease 

dust, when possible, demonstrates that the 

employer has a complete understanding 

of those instructions and is using them to 

control dust. Describing those instructions in 

the written exposure control plans also lets 

employees know what the employer needs to 

do to protect them.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 4 3

Example: When cutting bricks using a 

stationary masonry saw, Table 1 will be fully 

and properly implemented, including using a 

saw with an integrated water delivery system 

that delivers a steady stream of water to the 

cutting blade. The saw operator will make 

sure that enough water for the saw is available 

before starting to cut, and that a steady 

stream of water can be seen while cutting. The 

operator will change water, when needed, to 

maintain flow of water to the blade. 

Use the stationary masonry saw in accordance 

with manufacturer’s instructions to minimize 

the release of visible dust. Inspect dust 

controls daily to make sure they are functioning 

properly. Stop work and adjust controls if you 

see an increase in visible dust.

Respiratory protection is not required. 

The plan must include a description of 

the housekeeping methods used to limit 

employee exposure to respirable crystalline 

silica. While employees are cleaning, dust 

can become airborne and expose them to 

silica. In this part of the written exposure 

control plan, employers must list acceptable 

cleaning methods that will be used to 

prevent employees from being exposed and 

any protections that are needed if certain 

cleaning methods have to be used. 

The Housekeeping section of the standard 

requires that when cleaning up dust that 

can contribute to employee exposures to 

respirable crystalline silica, employers must: 

■ Not allow cleaning by dry brushing and 

sweeping, unless methods such as wet 

sweeping and HEPA-filtered vacuuming 

are not feasible; 

■ Not allow cleaning of surfaces or 

clothing with compressed air, unless the 

compressed air is used together with 

a ventilation system that effectively 

captures the dust cloud or no other 

cleaning method is feasible.

This section of the written plan would include 

cleaning methods that are acceptable (e.g., 

wet sweeping), cleaning methods that are 

unacceptable because acceptable cleaning 

methods are feasible (e.g., dry sweeping), 

and special instructions (e.g., use local 

exhaust ventilation if compressed air must 

be used). Hygiene-related subjects, such as 

not using compressed air to clean clothing, 

could also be addressed in this section of the 

written exposure control plan.

Example: Slurry generated by the saw will be 

cleaned up before it dries using a wet vacuum. 

When emptying the vacuum, the slurry will be 

transferred into a plastic bag and placed inside 

a container for disposal. The container will be 

sealed to prevent the release of dust back into 

the work space.

Never sweep or use compressed air on dried 

slurry. If slurry dries, immediately wet it down 

and clean it up with the wet vacuum.

The plan must include a description of the 

procedures used to restrict access to work 

areas, when necessary, to limit the number of 

employees exposed to respirable crystalline 

silica and the levels to which they are 

exposed, including exposures generated by 

other employers or self-employed workers. 

This section of the plan must describe how 

the employer restricts access to prevent 

exposures, such as: 

■ Scheduling certain tasks when others are 

not around, 

■ Telling employees to stay out of areas 

where dust is generated, 

■ Moving employees to an area where they 

are not exposed to dust, or 

■ Posting warning signs. 

Employers following the alternative exposure 

control methods approach must restrict 

access where an exposure assessment shows 

that exposures are above the PEL. When 

following Table 1, employers must restrict 
4 4 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

access when employees are engaged in tasks 

that require respirator use under Table 1. For 

example, if an employer following Table 1 

has an employee who is jackhammering for 

more than four hours and is therefore wearing 

a respirator, the employer or the competent 

person must make sure that an employee 

directing traffic (not engaged in the task), 

is positioned away and upwind from the 

employee who is jackhammering. 

The employer or competent person must also 

restrict access, when needed, for exposures 

generated by another employer or selfemployed person. Such a situation might 

occur if the other employer of self-employed 

person is conducting a task that generates 

clearly visible dust. 

Example: When the controls on a stationary 

masonry saw are fully and properly 

implemented, access does not need to be 

restricted to decrease other employees’ 

exposure to respirable crystalline silica. 

The competent person can use traffic cones 

or barrier tape to restrict access if needed for 

other reasons such as safety concerns.

Yearly Review of Written Exposure 

Control Plans

The respirable crystalline silica standard 

requires employers to review and evaluate 

the effectiveness of the written exposure 

control plan at least once a year and update 

it as necessary. A yearly review is needed 

to make sure that all information in the plan 

is up-to-date. For example, the employer 

might have bought a new type of equipment 

or asked employees to conduct a new task 

involving exposure, and that information 

needs to be described in the written plan. 

Availability of the Written Exposure 

Control Plan

Employers must allow the written exposure 

control plan to be viewed or copied by 

each employee covered by the standard, 

their designated representative, and 

representatives from OSHA or NIOSH, 

upon request. Making the written exposure 

control plan available to employees and 

their designated representatives empowers 

and protects employees by letting them 

and their representatives know the silica 

hazards the employer identified and controls 

for those hazards. This allows employees 

and representatives to question employers 

if controls are not fully and properly 

implemented or maintained. Likewise, 

making written exposure control plans 

readily available to OSHA or NIOSH allows 

them to verify that employee protections 

are effective. If OSHA inspects a workplace, 

the OSHA Compliance Safety and Health 

Officer will ask to see the employer’s written 

exposure control plan.

Sample Written Exposure 

Control Plans

To help employers develop written exposure 

control plans, a sample plan is included below. 

This sample shows an easy-to-use format that 

can be changed to address the specific tasks 

performed by each employee. The sample 

plan meets the requirements of the standard 

and contains the level of detail that OSHA 

considers useful for employers in helping 

them protect their employees. As the sample 

shows, the plan can contain useful information 

without being long or complicated. 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 45

The Center for Construction Research and 

Training (CPWR) has a tool to help employers 

develop written exposure control plans that 

is available at www.silica-safe.org. Unions, 

trade associations or professional groups may 

offer sample written exposure control plans or 

other assistance to employers, which might be 

helpful, especially if written exposure control 

plans are tailored to a particular type of 

construction work performed. Although such 

general guidance may be helpful, employers 

must make sure that any plan they use is 

tailored to address all the information required 

by the standard and all tasks, tools, and 

controls used by the employer. 

Some sample plans might call for more 

information than is required by the silica 

standard (for example, information about 

exposure assessments, medical surveillance, 

and training). Employers can include this 

information in the plan if it is useful to them, 

but they are not required to do so under the 

silica standard.

Employers can also develop a comprehensive 

plan that includes all equipment, materials, 

tasks, and conditions for the jobs they 

perform. Doing so will greatly reduce the 

need to update the written plan for each 

new job or jobsite for the many construction 

employers who use the same equipment to 

perform the same tasks at many locations. 
46 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Sample Written Exposure Control Plan

Company: Person Completing the Plan, Title:

John Doe Renovators John Doe, Owner

Description of Task:

Demolishing concrete and tile floors inside homes or public buildings using a jackhammer.

Control Description

Controls: 

• Use jackhammer equipped with the appropriate, commercially available shroud and a vacuum 

dust collection system with the flow rate recommended by the jackhammer manufacturer, a filter 

that is at least 99 percent efficient, and a filter cleaning mechanism.

• Use a portable fan to exhaust air and prevent the buildup of dust.

Work practices: 

• Check shrouds and hoses to make sure they are not damaged before starting work. 

• Make sure the hoses do not become kinked or bent while working. 

• Use switch on vacuum to activate filter cleaning at the frequency recommended by the manufacturer.

• Replace vacuum bags as needed to prevent overfilling.

• Use the jackhammer and vacuum controls according to manufacturer’s instructions for reducing 

the release of visible dust.

• If visible dust increases, check controls and adjust as needed.

Respiratory protection:

• Use respirator with APF of 10 the entire time the task is being performed.

• See the written respiratory protection program for information on selection, training and fit 

testing requirements, in addition to proper use instructions for respirators (for example, being 

clean shaven when using a respirator that seals against the face).

Housekeeping:

• Dust containing silica on work surfaces and equipment must be cleaned up using wet methods or 

a HEPA-filtered vacuum. 

• Do not use compressed air or dry sweeping for removing dust and debris containing silica from 

work surfaces. 

• Dispose of used vacuum bags in a container and keep the container sealed.

Procedures Used to Restrict Access to Work Areas:

Schedule the work so that only employees who are engaged in the task (the jackhammer operator 

and employees helping the operator) are in the area.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 47

Competent Person Requirements

The employer must designate a competent 

person to frequently and regularly inspect 

job sites, materials, and equipment to 

implement the written exposure control plan. 

A competent person is someone who:

■ Can identify existing and foreseeable 

respirable crystalline silica hazards; 

■ Is authorized to promptly eliminate or 

minimize silica hazards; and 

■ Has the knowledge and ability to implement 

the written exposure control plan. 

The employer can designate any of his or her 

employees to be a competent person if the 

employee is qualified, including the employee 

who does the work on a jobsite. For example, 

employees who go to jobsites alone can be 

designated a competent person if they know 

how to properly implement controls on the 

tools they use, can recognize if the controls 

are not working, and can correct the nonworking control.

The standard does not require specific training 

for a competent person. The employer is 

responsible for determining what training 

is necessary to provide the knowledge and 

ability for his or her competent person to 

implement the written exposure control plan. 

The training will depend on the types of 

work done, and in some cases, successfully 

completing training required under the silica 

standard and OSHA’s Hazard Communication 

standard will be enough. In other cases, 

additional training may be needed. For 

example, a competent person at a small 

residential construction company might only 

need training on controls for power tools that 

they do not typically use to do their own tasks, 

so that they could help other employees with 

questions about or problems with dust controls 

on those tools. In contrast, a competent 

person for heavy equipment tasks may require 

more specialized training in heavy equipment 

inspection or in recognizing different soil types 

to determine if exposures might be a concern.
4 8 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

MEDICAL SURVEILLANCE – PARAGRAPH (H) 

OF THE STANDARD

Medical surveillance is intended to: 

(1) identify respirable crystalline silica-related 

diseases so that employees with those 

diseases can take actions to protect their 

health; (2) determine if an employee has any 

condition, such as a lung disease, that might 

make him or her more sensitive to respirable 

crystalline silica exposure; and (3) determine 

the employee’s fitness to use respirators. 

The standard specifies which employees 

must be offered medical surveillance, when 

and how often the examinations must 

offered, and the tests that make up medical 

examinations. The standard also specifies 

the information that the employer must give 

to the physician or other licensed health 

care professional (PLHCP) who conducts 

the examinations and the information that 

the employer must ensure that the PLHCP 

provides to the employee and employer.

All medical examinations and procedures 

required by the standard must be performed 

by a PLHCP. Medical surveillance must 

be provided at no cost to employees, and 

at a reasonable time and place. If getting 

the medical examination requires the 

employee to travel away from the worksite, 

the employer is required to cover the cost 

of travel. The employer must also pay 

employees for time spent traveling and taking 

medical examinations.

Which Employees Must be Offered 

Medical Surveillance

Employers must make an initial or periodic 

medical examination available to employees 

who will be required by the silica standard to 

wear a respirator for 30 or more days per year 

in the upcoming year (the next 365 days). If 

the employee is required to wear a respirator 

at any time during a day, that counts as one 

day of respirator use.

An employer will be able to estimate how often 

respirator use will be required by the standard 

in the upcoming year based on the types of 

tasks that the employee will perform, as well 

as how long and how often those tasks are 

performed. Respirator use with past employers 

does not count toward the 30-day threshold.

When unexpected circumstances result in 

employees being required to wear respirators 

more frequently than first expected, 

employers must make medical surveillance 

available as soon as it becomes apparent that 

the employee will be required by the silica 

standard to wear a respirator for 30 or more 

days in the upcoming year.

Frequency of Medical Examinations

Employers must offer medical examinations:

■ Within 30 days of initial assignment (the 

day the employee starts working in a job/

task in which he or she will be required 

by the silica standard to wear a respirator 

for 30 or more days per year), unless 

the employee has had an examination 

that meets the requirements of the silica 

standard within the last three years. 

■ Every three years from the employee’s last 

examination that met the requirements 

of the silica standard, or more frequently 

if recommended by the PLHCP, if the 

employee will continue to perform tasks 

that require respirator use under the silica 

standard for 30 or more days per year. 

A PLHCP might recommend more frequent 

medical examinations based on factors such 

as high exposure levels or a medical finding 

such as an X-ray suggesting silicosis. 

Employers must make sure that employees 

receive a dated copy of the PLHCP’s written 

medical opinion for the employer, and the 

employee can present that opinion to a 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 4 9

new employer as proof of a current medical 

examination. Employers can determine when 

they must offer an employee the next periodic 

medical examination based on the examination 

date on the written medical opinion. 

Medical Evaluation Requirements under 

the Respiratory Protection Standard

Employees who are required to wear 

respirators must receive medical evaluations 

required by the respiratory protection standard 

before they are fit tested for a respirator 

or wear a respirator in the workplace. 

The medical evaluation for the respiratory 

protection standard can be combined with the 

medical examination for silica, and employers 

could have the PLHCP conduct both the 

evaluation for respirator use and examination 

for silica at the same time. They could also 

have employees evaluated for respirator use 

before they wear a respirator and then offer 

the silica examination later, according to the 

required time limits of the silica standard. 

Also note that under the respiratory protection 

standard, employers are required to provide 

another medical evaluation if employees report 

medical signs or symptoms related to the 

ability to wear a respirator. 

(see 29 CFR 1910.134, Respiratory Protection, 

and OSHA’s Small Entity Compliance Guide 

for the Respiratory Protection Standard, 

Publication #3384). 

Tests that Must be Included 

in the Examination

An initial medical examination provided 

under the silica standard must consist of: 

■ A medical and work history that focuses 

on: past, present, and anticipated 

exposure to respirable crystalline 

silica, dust, and other agents affecting 

the respiratory system; any history of 

respiratory system dysfunction, including 

signs and symptoms of respiratory 

disease (for example, shortness of breath, 

cough, wheezing); history of tuberculosis; 

and smoking status and history; 

■ A physical examination that focuses on 

the respiratory system;

■ A digital or film chest X-ray interpreted 

according to the International Labour 

Office (ILO) International Classification 

of Radiographs of Pneumoconioses by a 

National Institute for Occupational Safety 

and Health (NIOSH)-certified B Reader 

(this involves a certified physician reading 

the X-ray according to certain procedures 

to determine if it shows signs of diseases 

such as silicosis);

■ A lung function (spirometry) test that 

includes forced vital capacity (the total 

amount of air that is forcefully blown out 

after taking a full breath), forced expiratory 

volume in one second (the amount of air 

forcefully blown out in the first second), 

and FEV1

/FVC ratio (the speed of air that 

is forcefully blown out), administered by 

a spirometry technician with a current 

certificate from a NIOSH-approved 

spirometry course; 

■ Testing for latent tuberculosis infection; 

■ Any other tests deemed appropriate 

(medically necessary and related to 

respirable crystalline silica exposure) by 

the PLHCP.

Periodic examinations include all these 

tests, with the exception of testing for latent 

tuberculosis, which is required only for the 

initial examination.

Employees who must be offered medical 

surveillance are at risk of developing 

respirable crystalline silica-related diseases, 

and the required tests are the minimum tests 

needed to look for those diseases. More tests 

may also be needed to address an employee’s 

medical complaint or a finding related to 

respirable crystalline silica exposure, such as 
50 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

abnormal lung function. The standard gives 

the PLHCP the flexibility to order additional 

tests he or she deems appropriate. Employers 

must make those tests ordered by the PLHCP 

available to the employee. 

Information the Employer Must Provide to 

the PLHCP

The employer must ensure that the 

examining PLHCP has a copy of the standard 

and must provide the PLHCP with: 

■ A description of the employee’s past, 

current, and future duties as they relate to 

respirable crystalline silica exposure; 

■ The employee’s past, current, and future 

levels of exposure to respirable crystalline 

silica (if the employer does not have 

information on the employee’s past or 

current exposure level because they are 

following Table 1 and are not required to 

measure exposures, the employer can 

indicate if the employee is likely exposed 

at or above the PEL, based on required 

respirator use under Table 1);

■ A description of any personal protective 

equipment used, or to be used, by the 

employee, including when and for how 

long the employee has used or will use 

that equipment; and 

■ Information from records of employmentrelated medical examinations previously 

provided to the employee and currently 

within the control of the employer. 

The PLHCP needs this information to evaluate 

the employee’s health in relation to assigned 

duties and fitness to use personal protective 

equipment, such as respirators. The 

information provided to the PLHCP includes 

only that within the control of the employer; 

the employer is not required to obtain 

information from past employers. 

The PLHCP’s Written Medical 

Report for the Employee

The employer must ensure that the 

PLHCP explains the results of the medical 

examination to the employee and gives 

the employee a written medical report 

within 30 days of each medical examination 

performed. Only the employee receives the 

written medical report, and the employer 

does not receive a copy of this report. The 

report must contain: 

■ A description of the medical examination 

results, including any medical condition(s) 

that would place the employee at 

increased risk of material impairment 

of health from exposure to respirable 

crystalline silica (any health condition 

that might make the employee more 

sensitive to exposure). The report must 

also describe any medical conditions that 

require further evaluation or treatment;

■ Any recommended limitations on the 

employee’s use of respirators;

■ Any recommended limitations on 

respirable crystalline silica exposure; and

■ A statement that the employee should be 

examined by a specialist if the B-reader 

classifies the chest X-ray provided 

under the silica standard as 1/0 or higher 

(X-ray evidence of silicosis in employees 

exposed to respirable crystalline silica), 

or if the PLHCP otherwise recommends 

referral to a specialist. 

The PLHCP’s Written Medical 

Opinion for the Employer

The employer must get a written medical 

opinion from the PLHCP within 30 days of the 

medical examination. The written opinion 

must contain only the following information: 

■ The date of the examination; 

■ A statement that the examination has 

met the requirements of the silica 

standard; and 

■ Any recommended limitations on the 

employee’s use of respirators. 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 51

If the employee gives written authorization, 

the written medical opinion to the employer 

must also contain one or both of the following: 

■ Any recommended limitations on the 

employee’s exposure to respirable 

crystalline silica;

■ A statement that the employee should 

be examined by a specialist if the B 

reader classifies the chest X-ray provided 

under the silica standard as 1/0 or higher 

(X-ray evidence of silicosis in employees 

exposed to respirable crystalline silica), 

or if the PLHCP otherwise recommends 

referral to a specialist.

The purpose of the employee written 

authorization requirement is to enhance 

employee privacy and encourage employees 

to participate in medical surveillance 

by minimizing fears about retaliation or 

discrimination based on medical findings.

Employers must make sure that each 

employee receives a copy of the written 

medical opinion within 30 days of each 

medical examination. The PLHCP can give a 

copy of the opinion directly to the employee, 

so long as the time deadline is met. As 

indicated above, employees can show this 

opinion to future employers as proof that 

medical surveillance requirements under the 

silica standard are current. 

Sample Medical Forms in 

Appendix B of the Standard

Appendix B contains guidelines for PLHCPs 

and blank sample forms for the medical 

report for the employee, the medical opinion 

for the employer, and an authorization form 

to allow limitations on respirable crystalline 

silica exposure or recommendations for 

a specialist examination to be reported to 

the employer. Employers must make sure 

that PLHCPs who will conduct medical 

examinations required by the silica standard 

have a copy of the standard, including 

Appendix B. The purpose of Appendix B 

is to give PLHCPs medical information and 

guidance to help them conduct medical 

examinations that meet the requirements of 

the silica standard. 

Examples of completed forms are included 

in this guide. Sample Form 1 is a sample 

of the written medical report that the 

PLHCP provides to the employee. The 

employer does not receive a copy of the 

written medical report. Sample Form 2 is a 

sample of the written medical opinion that 

the PLHCP provides to the employer. The 

PLHCP indicates the type of examination 

and recommendations on use of a 

respirator. If the employee signs the written 

authorization (Sample Form 3) allowing 

the PLHCP to release further information 

to the employer, the PLHCP must include 

any recommend limitations on exposure to 

respirable crystalline silica and/or any referral 

to a specialist.
52 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Sample Form 1: Written Medical Report for Employee

Small Entity Compliance Guide– Construction 

Draft – Do not Quote or Cite 9/7/2016 

75 

SAMPLE FORM 1: WRITTEN MEDICAL REPORT FOR EMPLOYEE

EMPLOYEE NAME: Joe Smith DATE OF EXAMINATION: June 1, 2017

TYPE OF EXAMINATION: 

[x] Initial examination [ ] Periodic examination [ ] Specialist examination 

[ ] Other: _______________________________________________________________________________________ 

RESULTS OF MEDICAL EXAMINATION:

Physical Examination – [x] Normal [ ] Abnormal (see below) [ ] Not performed 

Chest X-Ray – [x] Normal [ ] Abnormal (see below) [ ] Not performed 

Breathing Test (Spirometry) – [ ] Normal [x] Abnormal (see below) [ ] Not performed 

Test for Tuberculosis – [x] Normal [ ] Abnormal (see below) [ ] Not performed 

Other:___________________ [ ] Normal [ ] Abnormal (see below) [ ] Not performed 

Results reported as abnormal: Breathing test (Spirometry) shows an obstructive pattern. 

__________________________________________________________________________________________________ 

[x] Your health may be at increased risk from exposure to respirable crystalline silica due to the following: 

Continued unprotected exposure to respirable crystalline silica may further damage your lungs. 

RECOMMENDATIONS: 

[ ] No limitations on respirator use 

[x] Recommended limitations on use of respirator: A powered air purifying respirator (PAPR) is the only type of 

respirator you can safely wear. A PAPR will give you higher protection from silica exposure and will decrease strain on 

your heart and lungs. 

[x] Recommended limitations on exposure to respirable crystalline silica: Ideally, you may want to consider a position 

that doesn’t involve exposure to substances hazardous to your lungs, such as respirable crystalline silica. If that is not 

possible, be sure to always wear a respirator when needed to protect your lungs. 

Dates for recommended limitations, if applicable: Indefinitely unless otherwise indicated by a specialist. 

[x] I recommend that you be examined by a Board Certified Specialist in Pulmonary Disease or Occupational Medicine 

[x] Other recommendations*: See your personal physician about the mole on your neck 

__________________________________________________________________________________________________ 

Your next periodic examination for silica exposure should be in: [ ] 3 years [x] Other: 1 year, June 1, 2018

 

Examining Provider: Dr. Jones Date: June 1, 2017

 (signature) 

Provider Name: Dr. Jones Health Clinic 

Office Address: _1111 Main Street, Washington, DC Office Phone: _123-456-7890__________________ 

*These findings may not be related to respirable crystalline silica exposure or may not be work-related, and therefore 

may not be covered by the employer. These findings may necessitate follow-up and treatment by your personal 

physician.

Respirable Crystalline Silica standard (§ 1910.1053 or 1926.1153)
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 53

Sample Form 2: Written Medical Opinion for Employer

Small Entity Compliance Guide– Construction 

Draft – Do not Quote or Cite 9/7/2016 

76 

SAMPLE FORM 2: WRITTEN MEDICAL OPINION FOR EMPLOYER

EMPLOYER: _John Doe Renovations___________________________________________ 

EMPLOYEE NAME: __Joe Smith_________________ DATE OF EXAMINATION: June 1, 2017________ 

TYPE OF EXAMINATION:

[x] Initial examination [ ] Periodic examination [ ] Specialist examination 

[ ] Other: _______________________________________________________________________________________ 

USE OF RESPIRATOR: 

[ ] No limitations on respirator use 

[x] Recommended limitations on use of respirator: A powered air purifying respirator (PAPR) is the only type of 

respirator Mr. Smith can safely wear. 

Dates for recommended limitations, if applicable: Indefinitely, unless otherwise recommended by specialist 

 

The employee has provided written authorization for disclosure of the following to the employer (if applicable): 

[x] This employee should be examined by an American Board Certified Specialist in Pulmonary Disease or Occupational 

Medicine 

[ ] Recommended limitations on exposure to respirable crystalline silica:_______________________________________

__________________________________________________________________________________________________ 

Dates for exposure limitations noted above: _______________ to _______________

 MM/DD/YYYY MM/DD/YYYY

NEXT PERIODIC EVALUATION: [ ] 3 years [x] Other: _1 year, June 1, 2018 

 

Examining Provider: __Dr. Jones____________________________ Date: June 1, 2017

 (signature) 

Provider Name: _Dr. Jones Health Clinic Provider’s specialty: None, general practitioner 

Office Address: _1111 Main Street, Washington, DC________ Office Phone: _123-456-7890_____________

[x] I attest that the results have been explained to the employee. 

The following is required to be checked by the Physician or other Licensed Health Care Professional (PLHCP): 

[x] I attest that this medical examination has met the requirements of the medical surveillance section of the OSHA 

Respirable Crystalline Silica standard (§ 1910.1053(h) or 1926.1153(h)). 
5 4 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Sample Form 3: Authorization for Crystalline Silica Opinion to Employer

Small Entity Compliance Guide– Construction 

Draft – Do not Quote or Cite 9/7/2016 

77 

SAMPLE FORM 3: AUTHORIZATION FOR CRYSTALLINE SILICA OPINION TO EMPLOYER

This medical examination for exposure to crystalline silica could reveal a medical condition that results in 

recommendations for (1) limitations on respirator use, (2) limitations on exposure to crystalline silica, or (3) 

examination by a specialist in pulmonary disease or occupational medicine. Recommended limitations on 

respirator use will be included in the written opinion to the employer. If you want your employer to know about 

limitations on crystalline silica exposure or recommendations for a specialist examination, you will need to give 

authorization for the written opinion to the employer to include one or both of those recommendations. 

I hereby authorize the opinion to the employer to contain the following information, if relevant 

(please check all that apply): 

 Recommendations for limitations on crystalline silica exposure 

 Recommendation for a specialist examination 

OR

 I do not authorize the opinion to the employer to contain anything other than recommended limitations on 

respirator use. 

Please read and initial: 

 X I understand that if I do not authorize my employer to receive the recommendation for specialist 

examination, the employer will not be responsible for arranging and covering costs of a specialist 

examination under the OSHA standard for respirable crystalline silica. 

 Joe Smith 

Name (printed) 

__Joe Smith______________________________ June 1, 2017______________________ 

Signature Date 

X
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 55

Additional Examinations 

by a Specialist

The employer must make the specialist 

examination available within 30 days of 

receiving the written medical opinion that 

includes the PLHCP’s recommendation for 

a specialist examination. The specialists 

must be either an American Board Certified 

Specialist in Pulmonary Disease or an 

American Board Certified Specialist in 

Occupational Medicine.

The employer must ensure the specialist: 

■ Receives the same information that the 

employer is required to provide the PLHCP 

(see above);

■ Explains the results of the medical 

examination to the employee and 

provides each employee with a written 

medical report within 30 days of the 

examination; and 

■ Provides the employer a written medical 

opinion within 30 days of the examination.

The specialist’s written medical report to 

the employee must contain the following 

information: 

■ A description of the medical examination 

results, including any medical condition(s) 

that may make an employee more 

sensitive to respirable crystalline silica 

exposure and any medical conditions that 

require further evaluation or treatment;

■ Any recommended limitations on the 

employee’s use of respirators; and 

■ Any recommended limitations on 

respirable crystalline silica exposure.

The specialist’s written medical opinion for 

the employer must include only the following: 

■ The date of the examination; and 

■ Any recommended limitations on the 

employee’s use of respirators. 

If the employee gives written authorization, 

the written opinion to the employer must 

also contain any recommended limitations 

on the employee’s exposure to respirable 

crystalline silica.
56 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

COMMUNICATION OF HAZARDS – PARAGRAPH (I) 

OF THE STANDARD

Employers must train and inform 

employees covered by the silica standard 

about respirable crystalline silica hazards 

and the methods the employer uses to 

limit their exposures to those hazards. 

Employers must cover the cost of training 

and must pay employees for the time spent 

in training.

OSHA’s Hazard Communication Standard

Employers must also comply with OSHA’s Hazard Communication standard (HCS) (29 CFR 1910.1200). 

HCS requires employers to inform employees about hazardous chemicals in the workplace, such 

as respirable crystalline silica, through their written hazard communication programs. Written 

hazard communication programs must describe how requirements for container labels, safety data 

sheets (SDSs), and employee training will be met. As part of their hazard communication program 

for respirable crystalline silica, employers must address at least these health hazards: cancer, lung 

effects, immune system effects, and kidney effects. 

Under the HCS, employers must:

• Inform employees about the general requirements of HCS, as well as where and how they can view the 

written hazard communication program, lists of hazardous chemicals, and SDSs.

• Train employees on how the presence or release of hazardous chemicals in the work area is 

detected; in the case of respirable crystalline silica, this could include methods the employer uses 

to measure exposures, such as air sampling or objective data. If employers are using Table 1, they 

can train employees to recognize that an increase in visible dust is a sign that a control may not be 

working properly.

• Train employees on the details of the workplace-specific hazard communication program developed 

by the employer, such as container labels, the workplace labeling system, SDSs (including the order in 

which the information is presented), and how employees can get and use hazard information.

See OSHA’s HAZARD COMMUNICATION: Small Entity Compliance Guide for Employers that Use 

Hazardous Chemicals [OSHA Publication #3695] for more information on preparing a written hazard 

communication program and employer requirements for labeling, SDSs, and training.

Training Topics

The employer must ensure that employees 

trained under the silica standard can 

demonstrate knowledge and understanding 

of at least: 

1. Health hazards associated with respirable 

crystalline silica exposure. For respirable 

crystalline silica, the health hazards 

include: cancer, lung effects, immune 

system effects, and kidney effects. 

2. Specific workplace tasks that could 

expose employees to respirable 

crystalline silica. Examples include 

those listed in Table 1, such as using a 

stationary masonry saw to cut crystalline 

silica-containing materials. 

3. Specific measures the employer is 

implementing to protect employees from 

respirable crystalline silica exposure, 

including engineering controls, work 

practices, and respirators to be used. 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 57

This training must be specific for the 

task that each employee performs. For 

example, employees who operate tools 

with built-in controls, such as saws with 

integrated water delivery systems, would 

need to demonstrate knowledge and 

understanding of:

■ The full and proper use of the controls 

on those tools; and 

■ Signs that controls may not be 

functioning properly.

Laborers who do not operate equipment 

but are engaged in a task by helping 

the tool operator would only need 

to demonstrate knowledge and 

understanding of:

■ The general types of controls used 

in the workplace, such as water or 

vacuum controls and how to recognize 

if those controls are not working 

properly; and

■ Work practices they perform as part 

of helping the tool operator, such as 

appropriate clean-up of respirable 

crystalline silica dust accumulations. 

4. The contents of the respirable 

crystalline silica standard. This would 

involve a description of the standard’s 

requirements.

5. The identity of the competent person 

designated by the employer. This could 

be as simple as announcing who the 

competent person is at the beginning of 

a work shift. 

6. The purpose and a description of the 

medical surveillance program required 

under the standard. Topics that employers 

could communicate to their employees as 

part of this training include: 

■ That employers must offer medical 

examinations to employees who are 

required to wear a respirator under 

the silica standard for 30 or more 

days a year;

■ That employers must offer medical 

examinations at no cost to the 

employee, including additional silicarelated tests or specialist examinations 

recommended by the physician or 

other licensed health care professional; 

■ The types of tests included in the 

medical examinations; 

■ Symptoms associated with respirable 

crystalline silica-related diseases;

■ Information that must be included 

in the written medical report to the 

employee versus the written medical 

opinion for the employer;

■ Information that must not be included 

in written medical opinion to the 

employer without written authorization 

from the employee (recommendations 

for limitations on exposures to silica 

and for specialist referrals);

■ The importance of keeping a copy of 

the written medical opinion to the 

employer as proof of a current medical 

examination to avoid unnecessary 

testing; and 

■ That employers cannot retaliate or 

discriminate against employees for 

participating in medical surveillance.

The employer is not required to provide 

all required training if an employee is 

already able to demonstrate knowledge 

and understanding of training topics such 

as health hazards, the contents of the 

silica standard, or medical surveillance 

requirements. However, some site-specific 

or employer-specific training is always 

necessary, such as training on specific 

tasks that could result in exposures in that 

workplace, specific controls or work practices 

that the employer is using, and the identity of 

the competent person. 

When Employees Must be Trained

Employees must be trained at the time they 

are assigned to a position involving exposure 

to respirable crystalline silica. 
58 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Additional training must be provided as often 

as necessary to ensure that employees know 

and understand respirable crystalline silica 

hazards and the protections available in their 

workplace. Examples of when additional 

training would be required include:

■ When the employer asks an employee to 

perform a task that is new to that employee; 

■ When the employer introduces new 

protections (for example, an employer 

who was having employees use a 

handheld grinder with wet method 

controls decides to have employees use 

a handheld grinder with a dust collection 

system); or 

■ When an employee is working in a manner 

that suggests he or she has forgotten what 

was learned in training.

Training Methods

The silica standard does not require the 

employer to use any particular method 

for training employees. Employers could 

use hands-on training, videotapes, slide 

presentations, classroom instruction, 

informal discussions during safety meetings, 

written materials, or any combination of 

these methods to train employees. 

In order for employees to demonstrate 

knowledge and understanding of the training 

subjects, training must be done in a manner 

and language that employees understand. 

This may mean, for example, providing 

materials, instruction, or assistance in 

Spanish rather than English for Spanishspeaking employees who do not understand 

English, and using methods other than 

printed reading materials if the employee is 

not able to read. 

To ensure that employees understand the 

material presented during training, it is 

critical that trainees have the opportunity 

to ask questions and receive answers if 

they do not fully understand the material 

that is presented to them. When videotape 

presentations or computer-based programs 

are used, this requirement may be met by 

having a qualified trainer available to address 

questions after the presentation, or providing 

a telephone hotline so that trainees will have 

direct access to a qualified trainer.

Employers can determine if employees know 

and understand the training topics through 

discussion of the required training subjects, 

written tests, or oral quizzes. 

Making a Copy of the Standard 

Available

Employers must make a copy of the 

respirable crystalline silica standard available 

at no cost to each employee covered by the 

standard. This could simply involve allowing 

employees to view a printed or electronic 

copy in a reasonable location. 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 59

RECORDKEEPING – PARAGRAPH (J) OF THE STANDARD

Records can demonstrate employer 

compliance with the standard, and can assist 

in diagnosing and identifying workplacerelated illnesses. Therefore, employers 

are required to make and keep accurate 

records of air monitoring data and objective 

data used to assess employee exposures 

to respirable crystalline silica under the 

standard, as well as records of medical 

surveillance provided under the standard.

Air Monitoring Data

Employers must make and keep an 

accurate record of all air monitoring 

performed to comply with the standard. 

The record must indicate:

■ The date of the measurement for each 

sample taken;

■ The task monitored;

■ Sampling and analytical methods used;

■ The number, duration, and results of 

samples taken;

■ The identity of the laboratory that 

performed the analysis;

■ The type of personal protective equipment 

used (e.g., type of respirators worn); and

■ The name, social security number, and job 

classification of all employees represented 

by the monitoring, indicating which 

employees were actually monitored.

Objective Data

When an employer relies on objective data to 

comply with the silica standard, the employer 

must make and keep an accurate record of 

the objective data. The record must include 

at least:

■ The crystalline silica-containing material 

in question;

■ The source of the objective data;

■ The testing protocol and results of testing;

■ A description of the process, task, or 

activity on which the objective data were 

based; and

■ Any other data relevant to the process, 

task, activity, material, or exposures on 

which the objective data are based.

Medical Surveillance

The employer must make and keep an 

accurate record for each employee provided 

medical surveillance under the standard. 

The record must include the following 

information about the employee:

■ Name and social security number;

■ A copy of the PLHCPs’ and specialists’ 

written opinions; and

■ A copy of the information that the 

employer is required to provide to the 

PLHCPs and specialists (i.e., a description 

of the employee’s former, current, and 

anticipated duties as they relate to 

crystalline silica exposure; a description 

of the employee’s former, current, and 

anticipated respirable crystalline silica 

exposure levels; a description of the 

personal protective equipment used 

by the employee; and information from 

previous employment-related medical 

examinations that is currently within the 

control of the employer).

Keeping and Making Medical 

Records Available

Exposure and medical records must be kept 

and made available to employees, their 

representatives, and OSHA in accordance 

with OSHA’s access to employee exposure 

and medical records regulation.
60 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

OSHA’s Access to Employee Exposure and Medical Records Regulation

A separate OSHA regulation (29 CFR 1910.1020, Access to Employee Exposure and Medical Records) 

addresses requirements for maintaining exposure and medical records. In general, exposure records 

(including air monitoring and objective data) must be kept for at least 30 years, and medical records must 

be kept for at least the duration of employment plus 30 years. It is necessary to keep these records for 

extended periods because silica-related diseases such as cancer often cannot be detected until several 

decades after exposure. However, if an employee works for an employer for less than one year, the 

employer does not have to keep the medical records after employment ends, as long as the employer 

gives those records to the employee.

DATES – PARAGRAPH (K) OF THE STANDARD

Construction employers must comply 

with all requirements of the standard 

by September 23, 2017 (delayed from 

June 23, 2017), except the requirement to 

use laboratories that analyze respirable 

crystalline silica samples according to 

the procedures in Appendix A, which will 

be enforced beginning on June 23, 2018.

That means that as of September 23, 

2017, employers must either fully and 

properly implement Table 1 requirements 

or implement alternative exposure control 

measures, and comply with requirements 

for respiratory protection, housekeeping, 

medical surveillance, hazard communication 

and training, and recordkeeping. Prior to 

September 23, 2017, the previous PEL (a 

formula that is approximately equivalent to 

250 μg/m of respirable crystalline silica as 

an 8-hour TWA) remains in effect.

Take steps now to ensure the requirements 

can be met by the compliance dates.

1. Implement specified exposure control 

methods in Table 1.

2. Complete exposure assessments needed to 

select appropriate engineering controls and 

respiratory protection for tasks not in Table 1.

3. Set up respiratory protection programs 

where required.

4. Get appropriate equipment, controls, 

and respirators.

5. Arrange for medical surveillance. 

6. Take actions such as the following to meet 

all other requirements: 

a. Determine appropriate housekeeping 

methods.

b. Prepare a written exposure control plan.

c. Set up a training program.

d. Set up a recordkeeping system.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 61

APPENDIX I: OSHA RESPIRABLE CRYSTALLINE SILICA 

STANDARD FOR CONSTRUCTION

§1926.1153 Respirable crystalline silica.

(a) Scope and application. This section applies 

to all occupational exposures to respirable 

crystalline silica in construction work, except 

where employee exposure will remain below 

25 micrograms per cubic meter of air (25 μg/

m3) as an 8-hour time-weighted average 

(TWA) under any foreseeable conditions.

(b) Definitions. For the purposes of this 

section the following definitions apply:

Action level means a concentration of 

airborne respirable crystalline silica of 25 μg/

m3, calculated as an 8-hour TWA.

Assistant Secretary means the Assistant 

Secretary of Labor for Occupational Safety and 

Health, U.S. Department of Labor, or designee.

Director means the Director of the National 

Institute for Occupational Safety and Health 

(NIOSH), U.S. Department of Health and 

Human Services, or designee.

Competent person means an individual who is 

capable of identifying existing and foreseeable 

respirable crystalline silica hazards in the 

workplace and who has authorization to take 

prompt corrective measures to eliminate or 

minimize them. The competent person must 

have the knowledge and ability necessary to 

fulfill the responsibilities set forth in paragraph 

(g) of this section.

Employee exposure means the exposure 

to airborne respirable crystalline silica that 

would occur if the employee were not using 

a respirator.

High-efficiency particulate air [HEPA] filter

means a filter that is at least 99.97 percent 

efficient in removing mono-dispersed 

particles of 0.3 micrometers in diameter.

Objective data means information, such 

as air monitoring data from industrywide surveys or calculations based on the 

composition of a substance, demonstrating 

employee exposure to respirable crystalline 

silica associated with a particular product 

or material or a specific process, task, or 

activity. The data must reflect workplace 

conditions closely resembling or with a 

higher exposure potential than the processes, 

types of material, control methods, work 

practices, and environmental conditions in 

the employer’s current operations.

Physician or other licensed health care 

professional [PLHCP] means an individual 

whose legally permitted scope of practice (i.e., 

license, registration, or certification) allows 

him or her to independently provide or be 

delegated the responsibility to provide some 

or all of the particular health care services 

required by paragraph (h) of this section.

Respirable crystalline silica means quartz, 

cristobalite, and/or tridymite contained 

in airborne particles that are determined 

to be respirable by a sampling device 

designed to meet the characteristics for 

respirable-particle-size-selective samplers 

specified in the International Organization 

for Standardization (ISO) 7708:1995: Air 

Quality – Particle Size Fraction Definitions 

for Health-Related Sampling.

Specialist means an American Board 

Certified Specialist in Pulmonary Disease 

or an American Board Certified Specialist in 

Occupational Medicine.

This section means this respirable crystalline 

silica standard, 29 CFR 1926.1153.

(c) Specified exposure control methods. (1) 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 the task in Table 1, unless the 

employer assesses and limits the exposure of 

the employee to respirable crystalline silica in 

accordance with paragraph (d) of this section.
62 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(i) Stationary 

masonry saws 

Use saw equipped with integrated water delivery 

system that continuously feeds water to the blade. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize 

dust emissions.

None None

(ii) Handheld power 

saws (any blade 

diameter)

Use saw equipped with integrated water delivery 

system that continuously feeds water to the blade. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

APF 10

APF 10

(iii) Handheld power 

saws for cutting 

fiber-cement board 

(with blade diameter 

of 8 inches or less)

For tasks performed outdoors only:

Use saw equipped with commercially available 

dust collection system. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

Dust collector must provide the air flow 

recommended by the tool manufacturer, 

or greater, and have a filter with 99% or 

greater efficiency.

None None

(iv) Walk-behind saws Use saw equipped with integrated water delivery 

system that continuously feeds water to the blade. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

None

APF 10
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 6 3

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(v) Drivable saws For tasks performed outdoors only:

Use saw equipped with integrated water delivery 

system that continuously feeds water to the blade. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize 

dust emissions.

None None

(vi) Rig-mounted core 

saws or drills

Use tool equipped with integrated water delivery 

system that supplies water to cutting surface. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

None None

(vii) Handheld and 

stand-mounted 

drills (including 

impact and rotary 

hammer drills)

Use drill equipped with commercially available 

shroud or cowling with dust collection system. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize 

dust emissions. 

Dust collector must provide the air flow 

recommended by the tool manufacturer, or 

greater, and have a filter with 99% or greater 

efficiency and a filter-cleaning mechanism. 

Use a HEPA-filtered vacuum when cleaning holes.

None None

(viii) Dowel drilling 

rigs for concrete

For tasks performed outdoors only:

Use shroud around drill bit with a dust 

collection system. Dust collector must have a 

filter with 99% or greater efficiency and a filtercleaning mechanism. 

Use a HEPA-filtered vacuum when cleaning holes.

APF 10 APF 10
6 4 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(ix) Vehicle-mounted 

drilling rigs for rock 

and concrete

Use dust collection system with close capture 

hood or shroud around drill bit with a low-flow 

water spray to wet the dust at the discharge point 

from the dust collector. 

OR 

Operate from within an enclosed cab and use 

water for dust suppression on drill bit.

None

None

None

None

(x) Jackhammers and 

handheld powered 

chipping tools

Use tool with water delivery system that supplies 

a continuous stream or spray of water at the point 

of impact.

• When used outdoors.

• When used indoors or in an enclosed area.

OR 

Use tool equipped with commercially available 

shroud and dust collection system.

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

Dust collector must provide the air flow 

recommended by the tool manufacturer, or 

greater, and have a filter with 99% or greater 

efficiency and a filter-cleaning mechanism. 

• When used outdoors.

• When used indoors or in an enclosed area.

None

APF 10

None

APF 10

APF 10

APF 10

APF 10

APF 10
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 65

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xi) Handheld 

grinders for mortar 

removal (i.e., 

tuckpointing)

Use grinder equipped with commercially available 

shroud and dust collection system. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

Dust collector must provide 25 cubic feet per 

minute (cfm) or greater of airflow per inch of 

wheel diameter and have a filter with 99% or 

greater efficiency and a cyclonic pre-separator 

or filter-cleaning mechanism.

APF 10 APF 25

(xii) Handheld 

grinders for uses 

other than mortar 

removal

For tasks performed outdoors only:

Use grinder equipped with integrated water 

delivery system that continuously feeds water 

to the grinding surface. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

OR

Use grinder equipped with commercially available 

shroud and dust collection system. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

Dust collector must provide 25 cubic feet per 

minute (cfm) or greater of airflow per inch of 

wheel diameter and have a filter with 99% or 

greater efficiency and a cyclonic pre-separator or 

filter-cleaning mechanism.

• When used outdoors.

• When used indoors or in an enclosed area. 

None

None

None

None

None

APF 10
6 6 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xiii) Walk-behind 

milling machines and 

floor grinders

Use machine equipped with integrated water 

delivery system that continuously feeds water to 

the cutting surface. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize 

dust emissions. 

OR 

Use machine equipped with dust collection 

system recommended by the manufacturer. 

Operate and maintain tool in accordance 

with manufacturer’s instructions to minimize dust 

emissions. 

Dust collector must provide the air flow 

recommended by the manufacturer, or greater, 

and have a filter with 99% or greater efficiency 

and a filter-cleaning mechanism. 

When used indoors or in an enclosed area, use 

a HEPA-filtered vacuum to remove loose dust in 

between passes.

None

None

None

None

(xiv) Small drivable 

milling machines 

(less than half-lane)

Use a machine equipped with supplemental water 

sprays designed to suppress dust. Water must be 

combined with a surfactant. 

Operate and maintain machine to minimize 

dust emissions.

None None
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 67

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xv) Large drivable 

milling machines 

(half-lane and larger)

For cuts of any depth on asphalt only:

Use machine equipped with exhaust ventilation 

on drum enclosure and supplemental water 

sprays designed to suppress dust. 

Operate and maintain machine to minimize 

dust emissions. 

For cuts of four inches in depth or less on 

any substrate:

Use machine equipped with exhaust ventilation 

on drum enclosure and supplemental water 

sprays designed to suppress dust. 

Operate and maintain machine to minimize 

dust emissions. 

OR

Use a machine equipped with supplemental water 

spray designed to suppress dust. Water must be 

combined with a surfactant.

Operate and maintain machine to minimize dust 

emissions. 

None

None

None

None

None

None

(xvi) Crushing 

machines 

Use equipment designed to deliver water spray 

or mist for dust suppression at crusher and other 

points where dust is generated (e.g., hoppers, 

conveyers, sieves/sizing or vibrating components, 

and discharge points). 

Operate and maintain machine in accordance 

with manufacturer’s instructions to minimize dust 

emissions.

Use a ventilated booth that provides fresh, 

climate-controlled air to the operator, or a remote 

control station.

None None
68 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

TABLE 1: Specified Exposure Control Methods When 

Working with Materials Containing Crystalline Silica

Equipment/Task

Engineering and Work Practice 

Control Methods

Required Respiratory Protection 

and Minimum Assigned 

Protection Factor (APF) 

≤ 4 hours/shift > 4 hours/shift

(xvii) Heavy 

equipment and 

utility vehicles 

used to abrade 

or fracture silicacontaining materials 

(e.g., hoe-ramming, 

rock ripping) or used 

during demolition 

activities involving 

silica-containing 

materials

Operate equipment from within an enclosed cab.

When employees outside of the cab are engaged 

in the task, apply water and/or dust suppressants 

as necessary to minimize dust emissions. 

None

None

None

None

(xviii) Heavy 

equipment and utility 

vehicles for tasks 

such as grading 

and excavating 

but not including: 

demolishing, 

abrading, or 

fracturing silicacontaining materials

Apply water and/or dust suppressants as 

necessary to minimize dust emissions. 

OR

When the equipment operator is the only 

employee engaged in the task, operate equipment 

from within an enclosed cab. 

None

None

None

None
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 69

(2) When implementing the control measures 

specified in Table 1, each employer shall:

(i) For tasks performed indoors or in enclosed 

areas, provide a means of exhaust as needed 

to minimize the accumulation of visible 

airborne dust;

(ii) For tasks performed using wet methods, 

apply water at flow rates sufficient to 

minimize release of visible dust; 

(iii) For measures implemented that include 

an enclosed cab or booth, ensure that the 

enclosed cab or booth: 

(A) Is maintained as free as practicable from 

settled dust; 

(B) Has door seals and closing mechanisms 

that work properly;

(C) Has gaskets and seals that are in good 

condition and working properly; 

(D) Is under positive pressure maintained 

through continuous delivery of fresh air; 

(E) Has intake air that is filtered through a 

filter that is 95% efficient in the 0.3-10.0 μm 

range (e.g., MERV-16 or better); and

(F) Has heating and cooling capabilities.

(3) Where an employee performs more 

than one task on Table 1 during the course 

of a shift, and the total duration of all tasks 

combined is more than four hours, the 

required respiratory protection for each task 

is the respiratory protection specified for 

more than four hours per shift. If the total 

duration of all tasks on Table 1 combined is 

less than four hours, the required respiratory 

protection for each task is the respiratory 

protection specified for less than four hours 

per shift.

(d) Alternative exposure control methods.

For tasks not listed in Table 1, or where 

the employer does not fully and properly 

implement the engineering controls, work 

practices, and respiratory protection 

described in Table 1:

(1) Permissible exposure limit (PEL). The 

employer shall ensure that no employee 

is exposed to an airborne concentration of 

respirable crystalline silica in excess of 50 μg/

m3, calculated as an 8-hour TWA.

(2) Exposure assessment—(i) General. 

The employer shall assess the exposure of 

each employee who is or may reasonably 

be expected to be exposed to respirable 

crystalline silica at or above the action level 

in accordance with either the performance 

option in paragraph (d)(2)(ii) or the scheduled 

monitoring option in paragraph (d)(2)(iii) of 

this section.

(ii) Performance option. The employer shall 

assess the 8-hour TWA exposure for each 

employee on the basis of any combination 

of air monitoring data or objective data 

sufficient to accurately characterize employee 

exposures to respirable crystalline silica.

(iii) Scheduled monitoring option. (A) The 

employer shall perform initial monitoring 

to assess the 8-hour TWA exposure for 

each employee on the basis of one or more 

personal breathing zone air samples that 

reflect the exposures of employees on each 

shift, for each job classification, in each work 

area. Where several employees perform 

the same tasks on the same shift and in the 

same work area, the employer may sample 

a representative fraction of these employees 

in order to meet this requirement. In 

representative sampling, the employer shall 

sample the employee(s) who are expected 

to have the highest exposure to respirable 

crystalline silica. 
70 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(B) If initial monitoring indicates that employee 

exposures are below the action level, the 

employer may discontinue monitoring for 

those employees whose exposures are 

represented by such monitoring. 

(C) Where the most recent exposure 

monitoring indicates that employee 

exposures are at or above the action level 

but at or below the PEL, the employer shall 

repeat such monitoring within six months of 

the most recent monitoring.

(D) Where the most recent exposure 

monitoring indicates that employee 

exposures are above the PEL, the employer 

shall repeat such monitoring within three 

months of the most recent monitoring.

(E) Where the most recent (non-initial) 

exposure monitoring indicates that employee 

exposures are below the action level, the 

employer shall repeat such monitoring within 

six months of the most recent monitoring 

until two consecutive measurements, taken 

seven or more days apart, are below the 

action level, at which time the employer may 

discontinue monitoring for those employees 

whose exposures are represented by such 

monitoring, except as otherwise provided in 

paragraph (d)(2)(iv) of this section. 

(iv) Reassessment of exposures. The 

employer shall reassess exposures whenever 

a change in the production, process, control 

equipment, personnel, or work practices may 

reasonably be expected to result in new or 

additional exposures at or above the action 

level, or when the employer has any reason 

to believe that new or additional exposures at 

or above the action level have occurred.

(v) Methods of sample analysis. The employer 

shall ensure that all samples taken to satisfy 

the monitoring requirements of paragraph (d)

(2) of this section are evaluated by a laboratory 

that analyzes air samples for respirable 

crystalline silica in accordance with the 

procedures in Appendix A to this section.

(vi) Employee notification of assessment 

results. (A) Within five working days after 

completing an exposure assessment in 

accordance with paragraph (d)(2) of this 

section, the employer shall individually notify 

each affected employee in writing of the 

results of that assessment or post the results 

in an appropriate location accessible to all 

affected employees.

(B) Whenever an exposure assessment 

indicates that employee exposure is above 

the PEL, the employer shall describe in the 

written notification the corrective action 

being taken to reduce employee exposure to 

or below the PEL.

(vii) Observation of monitoring. (A) Where air 

monitoring is performed to comply with the 

requirements of this section, the employer 

shall provide affected employees or their 

designated representatives an opportunity 

to observe any monitoring of employee 

exposure to respirable crystalline silica.

(B) When observation of monitoring requires 

entry into an area where the use of protective 

clothing or equipment is required for any 

workplace hazard, the employer shall provide 

the observer with protective clothing and 

equipment at no cost and shall ensure 

that the observer uses such clothing and 

equipment.

(3) Methods of compliance—(i) Engineering 

and work practice controls. The employer 

shall use engineering and work practice 

controls to reduce and maintain employee 

exposure to respirable crystalline silica to 

or below the PEL, unless the employer can 

demonstrate that such controls are not 

feasible. Wherever such feasible engineering 

and work practice controls are not sufficient 

to reduce employee exposure to or below 

the PEL, the employer shall nonetheless use 

them to reduce employee exposure to the 

lowest feasible level and shall supplement 

them with the use of respiratory protection 

that complies with the requirements of 

paragraph (e) of this section.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 71

(ii) Abrasive blasting. In addition to the 

requirements of paragraph (d)(3)(i) of this 

section, the employer shall comply with other 

OSHA standards, when applicable, such as 

29 CFR 1926.57 (Ventilation), where abrasive 

blasting is conducted using crystalline silicacontaining blasting agents, or where abrasive 

blasting is conducted on substrates that 

contain crystalline silica.

(e) Respiratory protection—(1) General. 

Where respiratory protection is required 

by this section, the employer must provide 

each employee an appropriate respirator 

that complies with the requirements of this 

paragraph and 29 CFR 1910.134. Respiratory 

protection is required: 

(i) Where specified by Table 1 of paragraph (c) 

of this section; or

(ii) For tasks not listed in Table 1, or where 

the employer does not fully and properly 

implement the engineering controls, work 

practices, and respiratory protection 

described in Table 1:

(A) Where exposures exceed the PEL during 

periods necessary to install or implement 

feasible engineering and work practice 

controls; 

(B) Where exposures exceed the PEL during 

tasks, such as certain maintenance and 

repair tasks, for which engineering and work 

practice controls are not feasible; and

(C) During tasks for which an employer has 

implemented all feasible engineering and 

work practice controls and such controls 

are not sufficient to reduce exposures to or 

below the PEL.

(2) Respiratory protection program. Where 

respirator use is required by this section, 

the employer shall institute a respiratory 

protection program in accordance with 29 

CFR 1910.134. 

(3) Specified exposure control methods. 

For the tasks listed in Table 1 in paragraph 

(c) of this section, if the employer fully 

and properly implements the engineering 

controls, work practices, and respiratory 

protection described in Table 1, the employer 

shall be considered to be in compliance 

with paragraph (e)(1) of this section and the 

requirements for selection of respirators in 29 

CFR 1910.134(d)(1)(iii) and (d)(3) with regard to 

exposure to respirable crystalline silica.

(f) Housekeeping. (1) The employer shall not 

allow dry sweeping or dry brushing where 

such activity could contribute to employee 

exposure to respirable crystalline silica unless 

wet sweeping, HEPA-filtered vacuuming or 

other methods that minimize the likelihood of 

exposure are not feasible.

(2) The employer shall not allow compressed 

air to be used to clean clothing or surfaces 

where such activity could contribute to 

employee exposure to respirable crystalline 

silica unless:

(i) The compressed air is used in conjunction 

with a ventilation system that effectively 

captures the dust cloud created by the 

compressed air; or

(ii) No alternative method is feasible.

(g) Written exposure control plan. (1) The 

employer shall establish and implement a 

written exposure control plan that contains at 

least the following elements:

(i) A description of the tasks in the workplace 

that involve exposure to respirable crystalline 

silica;

(ii) A description of the engineering controls, 

work practices, and respiratory protection 

used to limit employee exposure to respirable 

crystalline silica for each task;
72 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(iii) A description of the housekeeping 

measures used to limit employee exposure to 

respirable crystalline silica; and

(iv) A description of the procedures used 

to restrict access to work areas, when 

necessary, to minimize the number of 

employees exposed to respirable crystalline 

silica and their level of exposure, including 

exposures generated by other employers or 

sole proprietors.

(2) The employer shall review and evaluate 

the effectiveness of the written exposure 

control plan at least annually and update it as 

necessary.

(3) The employer shall make the written 

exposure control plan readily available for 

examination and copying, upon request, to 

each employee covered by this section, their 

designated representatives, the Assistant 

Secretary and the Director.

(4) The employer shall designate a 

competent person to make frequent and 

regular inspections of job sites, materials, 

and equipment to implement the written 

exposure control plan.

(h) Medical surveillance—(1) General. (i) The 

employer shall make medical surveillance 

available at no cost to the employee, and 

at a reasonable time and place, for each 

employee who will be required under this 

section to use a respirator for 30 or more 

days per year. 

(ii) The employer shall ensure that all medical 

examinations and procedures required by 

this section are performed by a PLHCP as 

defined in paragraph (b) of this section. 

(2) Initial examination. The employer shall 

make available an initial (baseline) medical 

examination within 30 days after initial 

assignment, unless the employee has 

received a medical examination that meets 

the requirements of this section within the last 

three years. The examination shall consist of:

(i) A medical and work history, with emphasis 

on: past, present, and anticipated exposure 

to respirable crystalline silica, dust, and other 

agents affecting the respiratory system; any 

history of respiratory system dysfunction, 

including signs and symptoms of respiratory 

disease (e.g., shortness of breath, cough, 

wheezing); history of tuberculosis; and 

smoking status and history; 

(ii) A physical examination with special 

emphasis on the respiratory system;

(iii) A chest X-ray (a single posteroanterior 

radiographic projection or radiograph of the 

chest at full inspiration recorded on either 

film (no less than 14 x 17 inches and no more 

than 16 x 17 inches) or digital radiography 

systems), interpreted and classified according 

to the International Labour Office (ILO) 

International Classification of Radiographs 

of Pneumoconioses by a NIOSH-certified B 

Reader; 

(iv) A pulmonary function test to include 

forced vital capacity (FVC) and forced 

expiratory volume in one second (FEV1

) and 

FEV1

/FVC ratio, administered by a spirometry 

technician with a current certificate from a 

NIOSH-approved spirometry course;

(v) Testing for latent tuberculosis infection; and 

(vi) Any other tests deemed appropriate by 

the PLHCP.

(3) Periodic examinations. The employer shall 

make available medical examinations that 

include the procedures described in paragraph 

(h)(2) of this section (except paragraph (h)(2)(v)) 

at least every three years, or more frequently if 

recommended by the PLHCP.

(4) Information provided to the PLHCP. The 

employer shall ensure that the examining 

PLHCP has a copy of this standard, and 

shall provide the PLHCP with the following 

information:
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 73

(i) A description of the employee’s former, 

current, and anticipated duties as they relate 

to the employee’s occupational exposure to 

respirable crystalline silica;

(ii) The employee’s former, current, and 

anticipated levels of occupational exposure to 

respirable crystalline silica;

(iii) A description of any personal protective 

equipment used or to be used by the employee, 

including when and for how long the employee 

has used or will use that equipment; and

(iv) Information from records of employmentrelated medical examinations previously 

provided to the employee and currently 

within the control of the employer.

(5) PLHCP’s written medical report for the 

employee. The employer shall ensure that the 

PLHCP explains to the employee the results 

of the medical examination and provides 

each employee with a written medical report 

within 30 days of each medical examination 

performed. The written report shall contain:

(i) A statement indicating the results of the 

medical examination, including any medical 

condition(s) that would place the employee 

at increased risk of material impairment to 

health from exposure to respirable crystalline 

silica and any medical conditions that require 

further evaluation or treatment;

(ii) Any recommended limitations on the 

employee’s use of respirators;

(iii) Any recommended limitations on the 

employee’s exposure to respirable crystalline 

silica; and

(iv) A statement that the employee should 

be examined by a specialist (pursuant 

to paragraph (h)(7) of this section) if the 

chest X-ray provided in accordance with 

this section is classified as 1/0 or higher by 

the B Reader, or if referral to a specialist is 

otherwise deemed appropriate by the PLHCP.

(6) PLHCP’s written medical opinion for the 

employer. (i) The employer shall obtain a 

written medical opinion from the PLHCP 

within 30 days of the medical examination. 

The written opinion shall contain only 

the following:

(A) The date of the examination;

(B) A statement that the examination has met 

the requirements of this section; and

(C) Any recommended limitations on the 

employee’s use of respirators.

(ii) If the employee provides written 

authorization, the written opinion shall also 

contain either or both of the following:

(A) Any recommended limitations on 

the employee’s exposure to respirable 

crystalline silica;

(B) A statement that the employee should 

be examined by a specialist (pursuant 

to paragraph (h)(7) of this section) if the 

chest X-ray provided in accordance with 

this section is classified as 1/0 or higher by 

the B Reader, or if referral to a specialist is 

otherwise deemed appropriate by the PLHCP.

(iii) The employer shall ensure that each 

employee receives a copy of the written 

medical opinion described in paragraph (h)

(6)(i) and (ii) of this section within 30 days of 

each medical examination performed.

(7) Additional examinations. (i) If the PLHCP’s 

written medical opinion indicates that an 

employee should be examined by a specialist, 

the employer shall make available a medical 

examination by a specialist within 30 days 

after receiving the PLHCP’s written opinion.

(ii) The employer shall ensure that the 

examining specialist is provided with all of 

the information that the employer is obligated 

to provide to the PLHCP in accordance with 

paragraph (h)(4) of this section.
74 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(iii) The employer shall ensure that the 

specialist explains to the employee the results 

of the medical examination and provides 

each employee with a written medical report 

within 30 days of the examination. The 

written report shall meet the requirements of 

paragraph (h)(5) (except paragraph (h)(5)(iv)) 

of this section.

(iv) The employer shall obtain a written 

opinion from the specialist within 30 days of 

the medical examination. The written opinion 

shall meet the requirements of paragraph (h)

(6) (except paragraph (h)(6)(i)(B) and (ii)(B)) of 

this section.

(i) Communication of respirable crystalline 

silica hazards to employees—(1) Hazard 

communication. The employer shall include 

respirable crystalline silica in the program 

established to comply with the hazard 

communication standard (HCS) (29 CFR 

1910.1200). The employer shall ensure that 

each employee has access to labels on 

containers of crystalline silica and safety data 

sheets, and is trained in accordance with the 

provisions of HCS and paragraph (i)(2) of this 

section. The employer shall ensure that at 

least the following hazards are addressed: 

Cancer, lung effects, immune system effects, 

and kidney effects.

(2) Employee information and training.

(i) The employer shall ensure that each 

employee covered by this section can 

demonstrate knowledge and understanding 

of at least the following:

(A) The health hazards associated with 

exposure to respirable crystalline silica;

(B) Specific tasks in the workplace that 

could result in exposure to respirable 

crystalline silica;

(C) Specific measures the employer has 

implemented to protect employees from 

exposure to respirable crystalline silica, 

including engineering controls, work 

practices, and respirators to be used; 

(D) The contents of this section;

(E) The identity of the competent person 

designated by the employer in accordance 

with paragraph (g)(4) of this section; and

(F) The purpose and a description of the 

medical surveillance program required by 

paragraph (h) of this section.

(ii) The employer shall make a copy of this 

section readily available without cost to each 

employee covered by this section.

(j) Recordkeeping—(1) Air monitoring 

data. (i) The employer shall make and 

maintain an accurate record of all exposure 

measurements taken to assess employee 

exposure to respirable crystalline silica, as 

prescribed in paragraph (d)(2) of this section.

(ii) This record shall include at least the 

following information:

(A) The date of measurement for each 

sample taken; 

(B) The task monitored;

(C) Sampling and analytical methods used;

(D) Number, duration, and results of 

samples taken;

(E) Identity of the laboratory that performed 

the analysis;

(F) Type of personal protective equipment, 

such as respirators, worn by the employees 

monitored; and

(G) Name, social security number, and job 

classification of all employees represented by 

the monitoring, indicating which employees 

were actually monitored.

(iii) The employer shall ensure that exposure 

records are maintained and made available in 

accordance with 29 CFR 1910.1020.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 75

(2) Objective data. (i) The employer shall 

make and maintain an accurate record of all 

objective data relied upon to comply with the 

requirements of this section.

(ii) This record shall include at least the 

following information:

(A) The crystalline silica-containing material 

in question;

(B) The source of the objective data;

(C) The testing protocol and results of testing;

(D) A description of the process, task, or 

activity on which the objective data were 

based; and

(E) Other data relevant to the process, task, 

activity, material, or exposures on which the 

objective data were based.

(iii) The employer shall ensure that objective 

data are maintained and made available in 

accordance with 29 CFR 1910.1020.

(3) Medical surveillance. (i) The employer shall 

make and maintain an accurate record for each 

employee covered by medical surveillance 

under paragraph (h) of this section.

(ii) The record shall include the following 

information about the employee:

(A) Name and social security number;

(B) A copy of the PLHCPs’ and specialists’ 

written medical opinions; and

(C) A copy of the information provided to the 

PLHCPs and specialists.

(iii) The employer shall ensure that medical 

records are maintained and made available in 

accordance with 29 CFR 1910.1020.

(k) Dates. (1) This section shall become 

effective June 23, 2016. 

(2) All obligations of this section, except 

requirements for methods of sample analysis 

in paragraph (d)(2)(v), shall commence 

June 23, 2017.

(3) Requirements for methods of sample 

analysis in paragraph (d)(2)(v) of this section 

commence June 23, 2018.

Appendix A to § 1926.1153 – Methods of 

Sample Analysis.

This appendix specifies the procedures 

for analyzing air samples for respirable 

crystalline silica, as well as the quality control 

procedures that employers must ensure 

that laboratories use when performing an 

analysis required under 29 CFR 1926.1153 (d)

(2)(v). Employers must ensure that such a 

laboratory:

1. Evaluates all samples using the procedures 

specified in one of the following analytical 

methods: OSHA ID-142; NMAM 7500; NMAM 

7602; NMAM 7603; MSHA P-2; or MSHA P-7;

2. Is accredited to ANS/ISO/IEC Standard 

17025:2005 with respect to crystalline silica 

analyses by a body that is compliant with ISO/

IEC Standard 17011:2004 for implementation of 

quality assessment programs;

3. Uses the most current National Institute 

of Standards and Technology (NIST) or NIST 

traceable standards for instrument calibration 

or instrument calibration verification;

4. Implements an internal quality control (QC) 

program that evaluates analytical uncertainty 

and provides employers with estimates of 

sampling and analytical error;

5. Characterizes the sample material by 

identifying polymorphs of respirable 

crystalline silica present, identifies the 

presence of any interfering compounds that 

might affect the analysis, and makes any 

corrections necessary in order to obtain 

accurate sample analysis; and
76 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

6. Analyzes quantitatively for crystalline 

silica only after confirming that the sample 

matrix is free of uncorrectable analytical 

interferences, corrects for analytical 

interferences, and uses a method that meets 

the following performance specifications:

6.1 Each day that samples are analyzed, 

performs instrument calibration checks 

with standards that bracket the sample 

concentrations;

6.2 Uses five or more calibration standard 

levels to prepare calibration curves and 

ensures that standards are distributed 

through the calibration range in a manner 

that accurately reflects the underlying 

calibration curve; and

6.3 Optimizes methods and instruments to 

obtain a quantitative limit of detection that 

represents a value no higher than 25 percent 

of the PEL based on sample air volume.

Appendix B to § 1926.1153 – Medical 

Surveillance Guidelines. 

Introduction

The purpose of this Appendix is to provide 

medical information and recommendations 

to aid physicians and other licensed health 

care professionals (PLHCPs) regarding 

compliance with the medical surveillance 

provisions of the respirable crystalline silica 

standard (29 CFR 1926.1153). Appendix B is 

for informational and guidance purposes 

only and none of the statements in Appendix 

B should be construed as imposing a 

mandatory requirement on employers that is 

not otherwise imposed by the standard. 

Medical screening and surveillance allow for 

early identification of exposure-related health 

effects in individual employee and groups 

of employees, so that actions can be taken 

to both avoid further exposure and prevent 

or address adverse health outcomes. Silicarelated diseases can be fatal, encompass a 

variety of target organs, and may have public 

health consequences when considering the 

increased risk of a latent tuberculosis (TB) 

infection becoming active. Thus, medical 

surveillance of silica-exposed employees 

requires that PLHCPs have a thorough 

knowledge of silica-related health effects. 

This Appendix is divided into seven 

sections. Section 1 reviews silica-related 

diseases, medical responses, and public 

health responses. Section 2 outlines the 

components of the medical surveillance 

program for employees exposed to 

silica. Section 3 describes the roles and 

responsibilities of the PLHCP implementing 

the program and of other medical specialists 

and public health professionals. Section 4 

provides a discussion of considerations, 

including confidentiality. Section 5 provides 

a list of additional resources and Section 6 

lists references. Section 7 provides sample 

forms for the written medical report for the 

employee, the written medical opinion for the 

employer and the written authorization.

1. Recognition of Silica-related Diseases.

1.1. Overview. The term “silica” refers 

specifically to the compound silicon dioxide 

(SiO2

). Silica is a major component of sand, 

rock, and mineral ores. Exposure to fine 

(respirable size) particles of crystalline forms 

of silica is associated with adverse health 

effects, such as silicosis, lung cancer, chronic 

obstructive pulmonary disease (COPD), and 

activation of latent TB infections. Exposure 

to respirable crystalline silica can occur in 

industry settings such as foundries, abrasive 

blasting operations, paint manufacturing, 

glass and concrete product manufacturing, 

brick making, china and pottery 

manufacturing, manufacturing of plumbing 

fixtures, and many construction activities 

including highway repair, masonry, concrete 

work, rock drilling, and tuck-pointing. New 

uses of silica continue to emerge. These 

include countertop manufacturing, finishing, 

and installation (Kramer et al. 2012; OSHA 

2015) and hydraulic fracturing in the oil and 

gas industry (OSHA 2012). 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 77

Silicosis is an irreversible, often disabling, 

and sometimes fatal fibrotic lung disease. 

Progression of silicosis can occur despite 

removal from further exposure. Diagnosis of 

silicosis requires a history of exposure to silica 

and radiologic findings characteristic of silica 

exposure. Three different presentations of 

silicosis (chronic, accelerated, and acute) have 

been defined. Accelerated and acute silicosis 

are much less common than chronic silicosis. 

However, it is critical to recognize all cases of 

accelerated and acute silicosis because these 

are life-threatening illnesses and because 

they are caused by substantial overexposures 

to respirable crystalline silica. Although any 

case of silicosis indicates a breakdown in 

prevention, a case of acute or accelerated 

silicosis implies current high exposure and a 

very marked breakdown in prevention.

In addition to silicosis, employees exposed to 

respirable crystalline silica, especially those 

with accelerated or acute silicosis, are at 

increased risks of contracting active TB and 

other infections (ATS 1997; Rees and Murray 

2007). Exposure to respirable crystalline 

silica also increases an employee’s risk of 

developing lung cancer, and the higher the 

cumulative exposure, the higher the risk 

(Steenland et al. 2001; Steenland and Ward 

2014). Symptoms for these diseases and 

other respirable crystalline silica-related 

diseases are discussed below.

1.2. Chronic Silicosis. Chronic silicosis is 

the most common presentation of silicosis 

and usually occurs after at least 10 years of 

exposure to respirable crystalline silica. The 

clinical presentation of chronic silicosis is:

1.2.1. Symptoms - shortness of breath 

and cough, although employees may not 

notice any symptoms early in the disease. 

Constitutional symptoms, such as fever, loss 

of appetite and fatigue, may indicate other 

diseases associated with silica exposure, such 

as TB infection or lung cancer. Employees with 

these symptoms should immediately receive 

further evaluation and treatment.

1.2.2. Physical Examination - may be 

normal or disclose dry rales or rhonchi 

on lung auscultation.

1.2.3. Spirometry - may be normal or may show 

only a mild restrictive or obstructive pattern. 

1.2.4. Chest X-ray - classic findings are small, 

rounded opacities in the upper lung fields 

bilaterally. However, small irregular opacities 

and opacities in other lung areas can also 

occur. Rarely, “eggshell calcifications” in the 

hilar and mediastinal lymph nodes are seen.

1.2.5. Clinical Course - chronic silicosis in most 

cases is a slowly progressive disease. Under 

the respirable crystalline silica standard, the 

PLHCP is to recommend that employees 

with a 1/0 category X-ray be referred to 

an American Board Certified Specialist in 

Pulmonary Disease or Occupational Medicine. 

The PLHCP and/or Specialist should counsel 

employees regarding work practices and 

personal habits that could affect employees’ 

respiratory health.

1.3. Accelerated Silicosis. Accelerated silicosis 

generally occurs within 5-10 years of exposure 

and results from high levels of exposure 

to respirable crystalline silica. The clinical 

presentation of accelerated silicosis is: 

1.3.1. Symptoms - shortness of breath, cough, 

and sometimes sputum production. Employees 

with exposure to respirable crystalline silica, 

and especially those with accelerated silicosis, 

are at high risk for activation of TB infections, 

atypical mycobacterial infections, and fungal 

superinfections. Constitutional symptoms, such 

as fever, weight loss, hemoptysis (coughing 

up blood), and fatigue may herald one of these 

infections or the onset of lung cancer. 

1.3.2. Physical Examination - rales, rhonchi, 

or other abnormal lung findings in relation to 

illnesses present. Clubbing of the digits, signs 

of heart failure, and cor pulmonale may be 

present in severe lung disease.
78 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

1.3.3. Spirometry - restrictive or mixed 

restrictive/obstructive pattern.

1.3.4. Chest X-ray - small rounded and/

or irregular opacities bilaterally. Large 

opacities and lung abscesses may indicate 

infections, lung cancer, or progression 

to complicated silicosis, also termed 

progressive massive fibrosis.

1.3.5. Clinical Course - accelerated silicosis 

has a rapid, severe course. Under the 

respirable crystalline silica standard, the 

PLHCP can recommend referral to a Board 

Certified Specialist in either Pulmonary 

Disease or Occupational Medicine, as 

deemed appropriate, and referral to a 

Specialist is recommended whenever the 

diagnosis of accelerated silicosis is being 

considered. 

1.4. Acute Silicosis. Acute silicosis is a rare 

disease caused by inhalation of extremely 

high levels of respirable crystalline silica 

particles. The pathology is similar to alveolar 

proteinosis with lipoproteinaceous material 

accumulating in the alveoli. Acute silicosis 

develops rapidly, often, within a few months 

to less than 2 years of exposure, and is 

almost always fatal. The clinical presentation 

of acute silicosis is as follows: 

1.4.1. Symptoms - sudden, progressive, and 

severe shortness of breath. Constitutional 

symptoms are frequently present and 

include fever, weight loss, fatigue, productive 

cough, hemoptysis (coughing up blood), and 

pleuritic chest pain. 

1.4.2. Physical Examination - dyspnea at rest, 

cyanosis, decreased breath sounds, inspiratory 

rales, clubbing of the digits, and fever. 

1.4.3. Spirometry - restrictive or mixed 

restrictive/obstructive pattern. 

1.4.4. Chest X-ray - diffuse haziness of the 

lungs bilaterally early in the disease. As 

the disease progresses, the “ground glass” 

appearance of interstitial fibrosis will appear. 

1.4.5. Clinical Course - employees with acute 

silicosis are at especially high risk of TB 

activation, nontuberculous mycobacterial 

infections, and fungal superinfections. Acute 

silicosis is immediately life-threatening. The 

employee should be urgently referred to 

a Board Certified Specialist in Pulmonary 

Disease or Occupational Medicine for 

evaluation and treatment. Although any 

case of silicosis indicates a breakdown in 

prevention, a case of acute or accelerated 

silicosis implies a profoundly high level 

of silica exposure and may mean that 

other employees are currently exposed to 

dangerous levels of silica. 

1.5. COPD. COPD, including chronic bronchitis 

and emphysema, has been documented in 

silica-exposed employees, including those who 

do not develop silicosis. Periodic spirometry 

tests are performed to evaluate each employee 

for progressive changes consistent with 

the development of COPD. In addition to 

evaluating spirometry results of individual 

employees over time, PLHCPs may want to 

be aware of general trends in spirometry 

results for groups of employees from the same 

workplace to identify possible problems that 

might exist at that workplace. (See Section 

2 of this Appendix on Medical Surveillance 

for further discussion.) Heart disease may 

develop secondary to lung diseases such as 

COPD. A recent study by Liu et al. 2014 noted a 

significant exposure-response trend between 

cumulative silica exposure and heart disease 

deaths, primarily due to pulmonary heart 

disease, such as cor pulmonale.

1.6. Renal and Immune System. Silica 

exposure has been associated with 

several types of kidney disease, including 

glomerulonephritis, nephrotic syndrome, and 

end stage renal disease requiring dialysis. 

Silica exposure has also been associated 

with other autoimmune conditions, including 

progressive systemic sclerosis, systemic 

lupus erythematosus, and rheumatoid 

arthritis. Studies note an association between 

employees with silicosis and serologic 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 79

markers for autoimmune diseases, including 

antinuclear antibodies, rheumatoid factor, 

and immune complexes (Jalloul and Banks 

2007; Shtraichman et al. 2015).

1.7. TB and Other Infections. Silica-exposed 

employees with latent TB are 3 to 30 times 

more likely to develop active pulmonary 

TB infection (ATS 1997; Rees and Murray 

2007). Although respirable crystalline silica 

exposure does not cause TB infection, 

individuals with latent TB infection are 

at increased risk for activation of disease 

if they have higher levels of respirable 

crystalline silica exposure, greater profusion 

of radiographic abnormalities, or a diagnosis 

of silicosis. Demographic characteristics, 

such as immigration from some countries, 

are associated with increased rates of latent 

TB infection. PLHCPs can review the latest 

Centers for Disease Control and Prevention 

(CDC) information on TB incidence rates and 

high risk populations online (See Section 

5 of this Appendix). Additionally, silicaexposed employees are at increased risk for 

contracting nontuberculous mycobacterial 

infections, including Mycobacterium aviumintracellulare and Mycobacterium kansaii.

1.8. Lung Cancer. The National Toxicology 

Program has listed respirable crystalline silica 

as a known human carcinogen since 2000 (NTP 

2014). The International Agency for Research 

on Cancer (2012) has also classified silica as 

Group 1 (carcinogenic to humans). Several 

studies have indicated that the risk of lung 

cancer from exposure to respirable crystalline 

silica and smoking is greater than additive 

(Brown 2009; Liu et al. 2013). Employees 

should be counseled on smoking cessation.

2. Medical Surveillance.

PLHCPs who manage silica medical 

surveillance programs should have a 

thorough understanding of the many silicarelated diseases and health effects outlined 

in Section 1 of this Appendix. At each clinical 

encounter, the PLHCP should consider silicarelated health outcomes, with particular 

vigilance for acute and accelerated silicosis. 

In this Section, the required components of 

medical surveillance under the respirable 

crystalline silica standard are reviewed, 

along with additional guidance and 

recommendations for PLHCPs performing 

medical surveillance examinations for silicaexposed employees.

2.1. History.

2.1.1. The respirable crystalline silica standard 

requires the following: A medical and work 

history, with emphasis on: past, present, and 

anticipated exposure to respirable crystalline 

silica, dust, and other agents affecting the 

respiratory system; any history of respiratory 

system dysfunction, including signs and 

symptoms of respiratory disease (e.g., 

shortness of breath, cough, wheezing); history 

of TB; and smoking status and history.

2.1.2. Further, the employer must provide the 

PLHCP with the following information: 

2.1.2.1. A description of the employee’s 

former, current, and anticipated duties as 

they relate to the employee’s occupational 

exposure to respirable crystalline silica;

2.1.2.2. The employee’s former, current, and 

anticipated levels of occupational exposure to 

respirable crystalline silica;

2.1.2.3. A description of any personal 

protective equipment used or to be used by 

the employee, including when and for how 

long the employee has used or will use that 

equipment; and

2.1.2.4. Information from records of 

employment-related medical examinations 

previously provided to the employee and 

currently within the control of the employer.

2.1.3. Additional guidance and 

recommendations: A history is particularly 

important both in the initial evaluation 

and in periodic examinations. Information 

on past and current medical conditions 
80 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

(particularly a history of kidney disease, 

cardiac disease, connective tissue disease, 

and other immune diseases), medications, 

hospitalizations and surgeries may uncover 

health risks, such as immune suppression, 

that could put an employee at increased 

health risk from exposure to silica. This 

information is important when counseling 

the employee on risks and safe work 

practices related to silica exposure.

2.2. Physical Examination. 

2.2.1. The respirable crystalline silica 

standard requires the following: A physical 

examination, with special emphasis on the 

respiratory system. The physical examination 

must be performed at the initial examination 

and every three years thereafter. 

2.2.2. Additional guidance and 

recommendations: Elements of the 

physical examination that can assist the 

PHLCP include: an examination of the 

cardiac system, an extremity examination 

(for clubbing, cyanosis, edema, or joint 

abnormalities), and an examination of other 

pertinent organ systems identified during the 

history.

2.3. TB Testing. 

2.3.1. The respirable crystalline silica standard 

requires the following: Baseline testing for TB 

on initial examination.

2.3.2. Additional guidance and 

recommendations:

2.3.2.1. Current CDC guidelines (See Section 

5 of this Appendix) should be followed for the 

application and interpretation of Tuberculin 

skin tests (TST). The interpretation and 

documentation of TST reactions should 

be performed within 48 to 72 hours of 

administration by trained PLHCPs. 

2.3.2.2. PLHCPs may use alternative TB tests, 

such as interferon-release assays (IGRAs), 

if sensitivity and specificity are comparable 

to TST (Mazurek et al. 2010; Slater et al. 

2013). PLHCPs can consult the current CDC 

guidelines for acceptable tests for latent TB 

infection. 

2.3.2.3. The silica standard allows the PLHCP 

to order additional tests or test at a greater 

frequency than required by the standard, 

if deemed appropriate. Therefore, PLHCPs 

might perform periodic (e.g., annual) TB 

testing as appropriate, based on employees’ 

risk factors. For example, according to 

the American Thoracic Society (ATS), the 

diagnosis of silicosis or exposure to silica for 

25 years or more are indications for annual 

TB testing (ATS 1997). PLHCPs should consult 

the current CDC guidance on risk factors for 

TB (See Section 5 of this Appendix).

2.3.2.4. Employees with positive TB tests and 

those with indeterminate test results should 

be referred to the appropriate agency or 

specialist, depending on the test results and 

clinical picture. Agencies, such as local public 

health departments, or specialists, such as a 

pulmonary or infectious disease specialist, 

may be the appropriate referral. Active TB is a 

nationally notifiable disease. PLHCPs should 

be aware of the reporting requirements 

for their region. All States have TB Control 

Offices that can be contacted for further 

information. (See Section 5 of this Appendix 

for links to CDC’s TB resources and State TB 

Control Offices.)

2.3.2.5. The following public health principles 

are key to TB control in the U.S. (ATS-CDCIDSA 2005):

(1) Prompt detection and reporting of persons 

who have contracted active TB;

(2) Prevention of TB spread to close contacts 

of active TB cases;

(3) Prevention of active TB in people with 

latent TB through targeted testing and 

treatment; and
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 81

(4) Identification of settings at high risk for TB 

transmission so that appropriate infectioncontrol measures can be implemented.

2.4. Pulmonary Function Testing. 

2.4.1. The respirable crystalline silica 

standard requires the following: Pulmonary 

function testing must be performed on the 

initial examination and every three years 

thereafter. The required pulmonary function 

test is spirometry and must include forced 

vital capacity (FVC), forced expiratory 

volume in one second (FEV1

), and FEV1/

FVC ratio. Testing must be administered 

by a spirometry technician with a current 

certificate from a National Institute for 

Occupational Health and Safety (NIOSH)-

approved spirometry course.

2.4.2. Additional guidance and 

recommendations: Spirometry provides 

information about individual respiratory 

status and can be used to track an 

employee’s respiratory status over time or 

as a surveillance tool to follow individual 

and group respiratory function. For quality 

results, the ATS and the American College of 

Occupational and Environmental Medicine 

(ACOEM) recommend use of the third National 

Health and Nutrition Examination Survey 

(NHANES III) values, and ATS publishes 

recommendations for spirometry equipment 

(Miller et al. 2005; Townsend 2011; Redlich 

et al. 2014). OSHA’s publication, Spirometry 

Testing in Occupational Health Programs: 

Best Practices for Healthcare Professionals, 

provides helpful guidance (See Section 5 of 

this Appendix). Abnormal spirometry results 

may warrant further clinical evaluation and 

possible recommendations for limitations 

on the employee’s exposure to respirable 

crystalline silica.

2.5. Chest X-ray. 

2.5.1. The respirable crystalline silica 

standard requires the following: A single 

posteroanterior (PA) radiographic projection 

or radiograph of the chest at full inspiration 

recorded on either film (no less than 14 x 17 

inches and no more than 16 x 17 inches) or 

digital radiography systems. A chest X-ray 

must be performed on the initial examination 

and every three years thereafter. The chest 

X-ray must be interpreted and classified 

according to the International Labour 

Office (ILO) International Classification 

of Radiographs of Pneumoconioses by a 

NIOSH-certified B Reader.

Chest radiography is necessary to diagnose 

silicosis, monitor the progression of silicosis, 

and identify associated conditions such as 

TB. If the B reading indicates small opacities 

in a profusion of 1/0 or higher, the employee 

is to receive a recommendation for referral 

to a Board Certified Specialist in Pulmonary 

Disease or Occupational Medicine. 

2.5.2. Additional guidance and 

recommendations: Medical imaging has 

largely transitioned from conventional filmbased radiography to digital radiography 

systems. The ILO Guidelines for the 

Classification of Pneumoconioses has 

historically provided film-based chest 

radiography as a referent standard for 

comparison to individual exams. However, 

in 2011, the ILO revised the guidelines to 

include a digital set of referent standards 

that were derived from the prior filmbased standards. To assist in assuring that 

digitally-acquired radiographs are at least 

as safe and effective as film radiographs, 

NIOSH has prepared guidelines, based 

upon accepted contemporary professional 

recommendations (See Section 5 of this 

Appendix). Current research from Laney et al. 

2011 and Halldin et al. 2014 validate the use of 

the ILO digital referent images. Both studies 

conclude that the results of pneumoconiosis 

classification using digital references are 

comparable to film-based ILO classifications. 

Current ILO guidance on radiography for 

pneumoconioses and B-reading should 

be reviewed by the PLHCP periodically, as 

needed, on the ILO or NIOSH websites (See 

Section 5 of this Appendix).
82 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

2.6. Other Testing. Under the respirable 

crystalline silica standards, the PLHCP has 

the option of ordering additional testing he 

or she deems appropriate. Additional tests 

can be ordered on a case-by-case basis 

depending on individual signs or symptoms 

and clinical judgment. For example, if an 

employee reports a history of abnormal 

kidney function tests, the PLHCP may want 

to order a baseline renal function tests 

(e.g., serum creatinine and urinalysis). As 

indicated above, the PLHCP may order annual 

TB testing for silica-exposed employees 

who are at high risk of developing active 

TB infections. Additional tests that PLHCPs 

may order based on findings of medical 

examinations include, but is not limited to, 

chest computerized tomography (CT) scan for 

lung cancer or COPD, testing for immunologic 

diseases, and cardiac testing for pulmonaryrelated heart disease, such as cor pulmonale.

3. Roles and Responsibilities.

3.1. PLHCP. The PLHCP designation refers 

to “an individual whose legally permitted 

scope of practice (i.e., license, registration, 

or certification) allows him or her to 

independently provide or be delegated the 

responsibility to provide some or all of the 

particular health care services required” by 

the respirable crystalline silica standard. The 

legally permitted scope of practice for the 

PLHCP is determined by each State. PLHCPs 

who perform clinical services for a silica 

medical surveillance program should have a 

thorough knowledge of respirable crystalline 

silica-related diseases and symptoms. 

Suspected cases of silicosis, advanced COPD, 

or other respiratory conditions causing 

impairment should be promptly referred to 

a Board Certified Specialist in Pulmonary 

Disease or Occupational Medicine. 

Once the medical surveillance examination 

is completed, the employer must ensure 

that the PLHCP explains to the employee 

the results of the medical examination and 

provides the employee with a written medical 

report within 30 days of the examination. 

The written medical report must contain 

a statement indicating the results of the 

medical examination, including any medical 

condition(s) that would place the employee 

at increased risk of material impairment to 

health from exposure to respirable crystalline 

silica and any medical conditions that 

require further evaluation or treatment. In 

addition, the PLHCP’s written medical report 

must include any recommended limitations 

on the employee’s use of respirators, any 

recommended limitations on the employee’s 

exposure to respirable crystalline silica, and 

a statement that the employee should be 

examined by a Board Certified Specialist in 

Pulmonary Disease or Occupational medicine 

if the chest X-ray is classified as 1/0 or higher 

by the B Reader, or if referral to a Specialist is 

otherwise deemed appropriate by the PLHCP.

The PLHCP should discuss all findings and 

test results and any recommendations 

regarding the employee’s health, worksite 

safety and health practices, and medical 

referrals for further evaluation, if indicated. 

In addition, it is suggested that the PLHCP 

offer to provide the employee with a 

complete copy of their examination and 

test results, as some employees may want 

this information for their own records or to 

provide to their personal physician or a future 

PLHCP. Employees are entitled to access their 

medical records. 

Under the respirable crystalline silica 

standard, the employer must ensure that 

the PLHCP provides the employer with a 

written medical opinion within 30 days of 

the employee examination, and that the 

employee also gets a copy of the written 

medical opinion for the employer within 30 

days. The PLHCP may choose to directly 

provide the employee a copy of the written 

medical opinion. This can be particularly 

helpful to employees, such as construction 

employees, who may change employers 

frequently. The written medical opinion can 

be used by the employee as proof of upto-date medical surveillance. The following 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 8 3

lists the elements of the written medical 

report for the employee and written medical 

opinion for the employer. (Sample forms for 

the written medical report for the employee, 

the written medical opinion for the employer, 

and the written authorization are provided in 

Section 7 of this Appendix.)

3.1.1. The written medical report for the 

employee must include the following 

information:

3.1.1.1. A statement indicating the results 

of the medical examination, including any 

medical condition(s) that would place the 

employee at increased risk of material 

impairment to health from exposure to 

respirable crystalline silica and any medical 

conditions that require further evaluation or 

treatment; 

3.1.1.2. Any recommended limitations upon 

the employee’s use of a respirator;

3.1.1.3. Any recommended limitations on the 

employee’s exposure to respirable crystalline 

silica; and

3.1.1.4. A statement that the employee should 

be examined by a Board Certified Specialist in 

Pulmonary Disease or Occupational Medicine, 

where the standard requires or where the 

PLHCP has determined such a referral is 

necessary. The standard requires referral 

to a Board Certified Specialist in Pulmonary 

Disease or Occupational Medicine for a chest 

X-ray B reading indicating small opacities in 

a profusion of 1/0 or higher, or if the PHLCP 

determines that referral to a Specialist is 

necessary for other silica-related findings.

3.1.2. The PLHCP’s written medical opinion 

for the employer must include only the 

following information:

3.1.2.1. The date of the examination;

3.1.2.2. A statement that the examination has 

met the requirements of this section; and

3.1.2.3. Any recommended limitations on the 

employee’s use of respirators.

3.1.2.4. If the employee provides the PLHCP 

with written authorization, the written 

opinion for the employer shall also contain 

either or both of the following:

(1) Any recommended limitations on the 

employee’s exposure to respirable crystalline 

silica; and

(2) A statement that the employee should be 

examined by a Board Certified Specialist in 

Pulmonary Disease or Occupational Medicine 

if the chest X-ray provided in accordance with 

this section is classified as 1/0 or higher by 

the B Reader, or if referral to a Specialist is 

otherwise deemed appropriate.

3.1.2.5. In addition to the above referral for 

abnormal chest X-ray, the PLHCP may refer 

an employee to a Board Certified Specialist in 

Pulmonary Disease or Occupational Medicine 

for other findings of concern during the medical 

surveillance examination if these findings are 

potentially related to silica exposure.

3.1.2.6. Although the respirable crystalline 

silica standard requires the employer to 

ensure that the PLHCP explains the results of 

the medical examination to the employee, the 

standard does not mandate how this should 

be done. The written medical opinion for 

the employer could contain a statement that 

the PLHCP has explained the results of the 

medical examination to the employee. 

3.2. Medical Specialists. The silica standard 

requires that all employees with chest X-ray B 

readings of 1/0 or higher be referred to a Board 

Certified Specialist in Pulmonary Disease or 

Occupational Medicine. If the employee has 

given written authorization for the employer 

to be informed, then the employer shall 

make available a medical examination by a 

Specialist within 30 days after receiving the 

PLHCP’s written medical opinion.
8 4 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

3.2.1. The employer must provide the 

following information to the Board Certified 

Specialist in Pulmonary Disease or 

Occupational Medicine: 

3.2.1.1. A description of the employee’s 

former, current, and anticipated duties as 

they relate to the employee’s occupational 

exposure to respirable crystalline silica;

3.2.1.2. The employee’s former, current, and 

anticipated levels of occupational exposure to 

respirable crystalline silica;

3.2.1.3. A description of any personal 

protective equipment used or to be used by 

the employee, including when and for how 

long the employee has used or will use that 

equipment; and

3.2.1.4. Information from records of 

employment-related medical examinations 

previously provided to the employee and 

currently within the control of the employer.

3.2.2. The PLHCP should make certain that, 

with written authorization from the employee, 

the Board Certified Specialist in Pulmonary 

Disease or Occupational Medicine has any 

other pertinent medical and occupational 

information necessary for the specialist’s 

evaluation of the employee’s condition. 

3.2.3. Once the Board Certified Specialist in 

Pulmonary Disease or Occupational Medicine 

has evaluated the employee, the employer 

must ensure that the Specialist explains 

to the employee the results of the medical 

examination and provides the employee with 

a written medical report within 30 days of the 

examination. The employer must also ensure 

that the Specialist provides the employer with 

a written medical opinion within 30 days of 

the employee examination. (Sample forms for 

the written medical report for the employee, 

the written medical opinion for the employer 

and the written authorization are provided in 

Section 7 of this Appendix.)

3.2.4. The Specialist’s written medical report

for the employee must include the following 

information:

3.2.4.1. A statement indicating the results 

of the medical examination, including any 

medical condition(s) that would place the 

employee at increased risk of material 

impairment to health from exposure to 

respirable crystalline silica and any medical 

conditions that require further evaluation 

or treatment; 

3.2.4.2. Any recommended limitations upon 

the employee’s use of a respirator; and

3.2.4.3. Any recommended limitations 

on the employee’s exposure to respirable 

crystalline silica.

3.2.5. The Specialist’s written medical 

opinion for the employer must include the 

following information:

3.2.5.1. The date of the examination; and

3.2.5.2. Any recommended limitations on the 

employee’s use of respirators.

3.2.5.3. If the employee provides the Board 

Certified Specialist in Pulmonary Disease 

or Occupational Medicine with written 

authorization, the written medical opinion 

for the employer shall also contain any 

recommended limitations on the employee’s 

exposure to respirable crystalline silica.

3.2.5.4. Although the respirable crystalline 

silica standard requires the employer to 

ensure that the Board Certified Specialist 

in Pulmonary Disease or Occupational 

Medicine explains the results of the medical 

examination to the employee, the standard 

does not mandate how this should be done. 

The written medical opinion for the employer 

could contain a statement that the Specialist 

has explained the results of the medical 

examination to the employee. 

3.2.6. After evaluating the employee, the 

Board Certified Specialist in Pulmonary 

Disease or Occupational Medicine 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 85

should provide feedback to the PLHCP as 

appropriate, depending on the reason for 

the referral. OSHA believes that because 

the PLHCP has the primary relationship with 

the employer and employee, the Specialist 

may want to communicate his or her 

findings to the PLHCP and have the PLHCP 

simply update the original medical report 

for the employee and medical opinion for 

the employer. This is permitted under the 

standard, so long as all requirements and 

time deadlines are met.

3.3. Public Health Professionals. PLHCPs 

might refer employees or consult with 

public health professionals as a result of 

silica medical surveillance. For instance, if 

individual cases of active TB are identified, 

public health professionals from state or local 

health departments may assist in diagnosis 

and treatment of individual cases and may 

evaluate other potentially affected persons, 

including coworkers. Because silica-exposed 

employees are at increased risk of progression 

from latent to active TB, treatment of latent 

infection is recommended. The diagnosis of 

active TB, acute or accelerated silicosis, or 

other silica-related diseases and infections 

should serve as sentinel events suggesting 

high levels of exposure to silica and may 

require consultation with the appropriate 

public health agencies to investigate 

potentially similarly exposed coworkers to 

assess for disease clusters. These agencies 

include local or state health departments 

or OSHA. In addition, NIOSH can provide 

assistance upon request through their Health 

Hazard Evaluation program. (See Section 5 of 

this Appendix)

4. Confidentiality and Other Considerations.

The information that is provided from the 

PLHCP to the employee and employer 

under the medical surveillance section of 

OSHA’s respirable crystalline silica standard 

differs from that of medical surveillance 

requirements in previous OSHA standards. 

The standard requires two separate written 

communications, a written medical report 

for the employee and a written medical 

opinion for the employer. The confidentiality 

requirements for the written medical opinion 

are more stringent than in past standards. For 

example, the information the PLHCP can (and 

must) include in his or her written medical 

opinion for the employer is limited to: the 

date of the examination, a statement that the 

examination has met the requirements of this 

section, and any recommended limitations 

on the employee’s use of respirators. If the 

employee provides written authorization 

for the disclosure of any limitations on the 

employee’s exposure to respirable crystalline 

silica, then the PLHCP can (and must) include 

that information in the written medical 

opinion for the employer as well. Likewise, 

with the employee’s written authorization, the 

PLHCP can (and must) disclose the PLHCP’s 

referral recommendation (if any) as part of 

the written medical opinion for the employer. 

However, the opinion to the employer 

must not include information regarding 

recommended limitations on the employee’s 

exposure to respirable crystalline silica or 

any referral recommendations without the 

employee’s written authorization. 

The standard also places limitations on the 

information that the Board Certified Specialist 

in Pulmonary Disease or Occupational 

Medicine can provide to the employer 

without the employee’s written authorization. 

The Specialist’s written medical opinion 

for the employer, like the PLHCP’s opinion, 

is limited to (and must contain): the date 

of the examination and any recommended 

limitations on the employee’s use of 

respirators. If the employee provides written 

authorization, the written medical opinion 

can (and must) also contain any limitations 

on the employee’s exposure to respirable 

crystalline silica. 

The PLHCP should discuss the implication of 

signing or not signing the authorization with 

the employee (in a manner and language that 

he or she understands) so that the employee 

can make an informed decision regarding the 
86 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

written authorization and its consequences. 

The discussion should include the risk of 

ongoing silica exposure, personal risk factors, 

risk of disease progression, and possible 

health and economic consequences. For 

instance, written authorization is required 

for a PLHCP to advise an employer that an 

employee should be referred to a Board 

Certified Specialist in Pulmonary Disease 

or Occupational Medicine for evaluation of 

an abnormal chest X-ray (B-reading 1/0 or 

greater). If an employee does not sign an 

authorization, then the employer will not 

know and cannot facilitate the referral to a 

Specialist and is not required to pay for the 

Specialist’s examination. In the rare case 

where an employee is diagnosed with acute 

or accelerated silicosis, co-workers are likely 

to be at significant risk of developing those 

diseases as a result of inadequate controls in 

the workplace. In this case, the PLHCP and/or 

Specialist should explain this concern to the 

affected employee and make a determined 

effort to obtain written authorization from the 

employee so that the PLHCP and/or Specialist 

can contact the employer. 

Finally, without written authorization from 

the employee, the PLHCP and/or Board 

Certified Specialist in Pulmonary Disease 

or Occupational Medicine cannot provide 

feedback to an employer regarding control of 

workplace silica exposure, at least in relation 

to an individual employee. However, the 

regulation does not prohibit a PLHCP and/

or Specialist from providing an employer 

with general recommendations regarding 

exposure controls and prevention programs 

in relation to silica exposure and silicarelated illnesses, based on the information 

that the PLHCP receives from the employer 

such as employees’ duties and exposure 

levels. Recommendations may include 

increased frequency of medical surveillance 

examinations, additional medical surveillance 

components, engineering and work practice 

controls, exposure monitoring and personal 

protective equipment. For instance, more 

frequent medical surveillance examinations 

may be a recommendation to employers 

for employees who do abrasive blasting 

with silica because of the high exposures 

associated with that operation. 

ACOEM’s Code of Ethics and discussion is a 

good resource to guide PLHCPs regarding the 

issues discussed in this section (See Section 

5 of this Appendix).

5. Resources.

5.1. American College of Occupational and 

Environmental Medicine (ACOEM): 

ACOEM Code of Ethics. Accessed at: http://

www.acoem.org/codeofconduct.aspx

Raymond, L.W. and Wintermeyer, S. (2006) 

ACOEM evidenced-based statement on 

medical surveillance of silica-exposed 

workers: medical surveillance of workers 

exposed to crystalline silica. J Occup Environ 

Med, 48, 95-101.

5.2. Center for Disease Control and 

Prevention (CDC) 

Tuberculosis webpage: http://www.cdc.gov/

tb/default.htm

State TB Control Offices web page: http://

www.cdc.gov/tb/links/tboffices.htm

Tuberculosis Laws and Policies webpage: 

http://www.cdc.gov/tb/programs/laws/

default.htm

CDC. (2013). Latent Tuberculosis Infection: 

A Guide for Primary Health Care Providers. 

Accessed at: http://www.cdc.gov/tb/

publications/ltbi/pdf/targetedltbi.pdf

5.3. International Labour Organization

International Labour Office (ILO). 

(2011) Guidelines for the use of the ILO 

International Classification of Radiographs 

of Pneumoconioses, Revised edition 2011. 

Occupational Safety and Health Series No. 22: 

http://www.ilo.org/safework/info/publications/

WCMS_168260/lang--en/index.htm

5.4. National Institute of Occupational Safety 

and Health (NIOSH)
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 87

NIOSH B Reader Program webpage. 

(Information on interpretation of X-rays for 

silicosis and a list of certified B-readers). 

Accessed at: http://www.cdc.gov/niosh/

topics/chestradiography/breader-info.html

NIOSH Guideline (2011). Application of 

Digital Radiography for the Detection and 

Classification of Pneumoconiosis. NIOSH 

publication number 2011-198. Accessed at: 

http://www.cdc.gov/niosh/docs/2011-198/

NIOSH Hazard Review (2002), Health Effects 

of Occupational Exposure to Respirable 

Crystalline Silica. NIOSH publication number 

2002-129: Accessed at http://www.cdc.gov/

niosh/docs/2002-129

NIOSH Health Hazard Evaluations Programs. 

(Information on the NIOSH Health Hazard 

Evaluation (HHE) program, how to request 

an HHE and how to look up an HHE report). 

Accessed at: http://www.cdc.gov/niosh/hhe

5.5. National Industrial Sand Association:

Occupational Health Program for Exposure 

to Crystalline Silica in the Industrial 

Sand Industry. National Industrial Sand 

Association, 2nd ed. 2010. Can be ordered 

at: http://www.sand.org/silica-occupationalhealth-program

5.6. Occupational Safety and Health 

Administration (OSHA)

Contacting OSHA: http://www.osha.gov/html/

Feed_Back.html

OSHA’s Clinicians webpage. (OSHA 

resources, regulations and links to help 

clinicians navigate OSHA’s web site and aid 

clinicians in caring for workers.) Accessed at: 

http://www.osha.gov/dts/oom/clinicians

OSHA’s Safety and Health Topics webpage 

on Silica. Accessed at: http://www.osha.gov/

dsg/topics/silicacrystalline

OSHA (2013). Spirometry Testing in 

Occupational Health Programs: Best Practices 

for Healthcare Professionals. (OSHA 3637-

03 2013). Accessed at: http://www.osha.gov/

Publications/OSHA3637.pdf

OSHA/NIOSH (2011). Spirometry: OSHA/

NIOSH Spirometry InfoSheet (OSHA 3415-

1-11). (Provides guidance to employers). 

Accessed at http://www.osha.gov/

Publications/osha3415.pdf

OSHA/NIOSH (2011) Spirometry: OSHA/

NIOSH Spirometry Worker Info. (OSHA 

3418-3-11). Accessed at http://www.osha.gov/

Publications/osha3418.pdf

5.7. Other 

Steenland, K. and Ward E. (2014). Silica: A 

lung carcinogen. CA Cancer J Clin, 64, 63-69. 

(This article reviews not only silica and lung 

cancer but also all the known silica-related 

health effects. Further, the authors provide 

guidance to clinicians on medical surveillance 

of silica-exposed workers and worker 

counselling on safety practices to minimize 

silica exposure.)

6. References.

American Thoracic Society (ATS). Medical 

Section of the American Lung Association 

(1997). Adverse effects of crystalline silica 

exposure. Am J Respir Crit Care Med, 155, 

761-765.

American Thoracic Society (ATS), Centers for 

Disease Control (CDC), Infectious Diseases 

Society of America (IDSA) (2005). Controlling 

Tuberculosis in the United States. Morbidity 

and Mortality Weekly Report (MMWR), 

54(RR12), 1-81. Accessed at: http://www.cdc.

gov/mmwr/preview/mmwrhtml/rr5412a1.htm

Brown, T. (2009). Silica exposure, smoking, 

silicosis and lung cancer – complex 

interactions. Occupational Medicine, 59, 89-95.
8 8 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Halldin, C. N., Petsonk, E. L., and Laney, 

A. S. (2014). Validation of the International 

Labour Office digitized standard images for 

recognition and classification of radiographs 

of pneumoconiosis. Acad Radiol, 21,305-311. 

International Agency for Research on 

Cancer. (2012). Monographs on the 

evaluation of carcinogenic risks to humans: 

Arsenic, Metals, Fibers, and Dusts Silica 

Dust, Crystalline, in the Form of Quartz 

or Cristobalite. A Review of Human 

Carcinogens. Volume 100 C. Geneva, 

Switzerland: World Health Organization.

Jalloul, A. S. and Banks D. E. (2007). Chapter 

23. The health effects of silica exposure. 

In: Rom, W. N. and Markowitz, S. B. (Eds). 

Environmental and Occupational Medicine, 

4th edition. Lippincott, Williams and Wilkins, 

Philadelphia, 365-387.

Kramer, M. R., Blanc, P. D., Fireman, E., 

Amital, A., Guber, A., Rahman, N. A., and 

Shitrit, D. (2012). Artifical stone silicosis: 

disease resurgence among artificial stone 

workers. Chest, 142, 419-424.

Laney, A. S., Petsonk, E. L., and Attfield, M. 

D. (2011). Intramodality and intermodality 

comparisons of storage phosphor computed 

radiography and conventional film-screen 

radiography in the recognition of small 

pneumonconiotic opacities. Chest, 140, 

1574-1580. 

Liu, Y., Steenland, K., Rong, Y., Hnizdo, E., 

Huang, X., Zhang, H., Shi, T., Sun, Y., Wu, 

T., and Chen, W. (2013). Exposure-response 

analysis and risk assessment for lung cancer 

in relationship to silica exposure: a 44-year 

cohort study of 34,018 workers. Am J Epi, 

178,1424-1433.

Liu, Y., Rong, Y., Steenland, K., Christiani, D. 

C., Huang, X., Wu, T., and Chen, W. (2014). 

Long-term exposure to crystalline silica and 

risk of heart disease mortality. Epidemiology, 

25, 689-696.

Mazurek, G. H., Jereb, J., Vernon, A., LoBue, 

P., Goldberg, S., Castro, K. (2010). Updated 

guidelines for using interferon gamma 

release assays to detect Mycobacterium

tuberculosis infection – United States. 

Morbidity and Mortality Weekly Report 

(MMWR), 59(RR05), 1-25.

Miller, M. R., Hankinson, J., Brusasco, V., 

Burgos, F., Casaburi, R., Coates, A., Crapo, R., 

Enright, P., van der Grinten, C. P., Gustafsson, 

P., Jensen, R., Johnson, D. C., MacIntyre, 

N., McKay, R., Navajas, D., Pedersen, O. F., 

Pellegrino, R., Viegi, G., and Wanger, J. (2005). 

American Thoracic Society/European 

Respiratory Society (ATS/ERS) Task Force: 

Standardisation of Spirometry. Eur Respir J, 

26, 319-338.

National Toxicology Program (NTP) (2014). 

Report on Carcinogens, Thirteenth Edition. 

Silica, Crystalline (respirable Size). Research 

Triangle Park, NC: U.S. Department of Health 

and Human Services, Public Health Service.

http://ntp.niehs.nih.gov/ntp/roc/content/

profiles/silica.pdf

Occupational Safety and Health 

Administration/National Institute for 

Occupational Safety and Health (OSHA/

NIOSH) (2012). Hazard Alert. Worker exposure 

to silica during hydraulic fracturing. 

Occupational Safety and Health Administration/

National Institute for Occupational Safety and 

Health (OSHA/NIOSH) (2015). Hazard alert. 

Worker exposure to silica during countertop 

manufacturing, finishing, and installation. 

(OSHA- HA-3768-2015). 

Redlich, C. A., Tarlo, S. M., Hankinson, J. L., 

Townsend, M. C, Eschenbacher, W. L., Von 

Essen, S. G., Sigsgaard, T., Weissman, D. N. 

(2014). Official American Thoracic Society 

technical standards: spirometry in the 

occupational setting. Am J Respir Crit Care 

Med; 189, 984-994.
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 89

Rees, D. and Murray, J. (2007). Silica, silicosis 

and tuberculosis. Int J Tuberc Lung Dis, 11(5), 

474-484.

Shtraichman, O., Blanc, P. D., Ollech, J. E., 

Fridel, L., Fuks, L., Fireman, E., and Kramer, 

M. R. (2015). Outbreak of autoimmune 

disease in silicosis linked to artificial stone. 

Occup Med, 65, 444-450.

Slater, M. L., Welland, G., Pai, M., Parsonnet, 

J., and Banaei, N. (2013). Challenges with 

QuantiFERON-TB gold assay for large-scale, 

routine screening of U.S. healthcare workers. 

Am J Respir Crit Care Med, 188,1005-1010. 

Steenland, K., Mannetje, A., Boffetta, P., 

Stayner, L., Attfield, M., Chen, J., Dosemeci, 

M., DeKlerk, N., Hnizdo, E., Koskela, R., and 

Checkoway, H. (2001). International Agency 

for Research on Cancer. Pooled exposureresponse analyses and risk assessment for 

lung cancer in 10 cohorts of silica-exposed 

workers: an IARC multicentre study. Cancer 

Causes Control,12(9):773-84. 

Steenland, K. and Ward E. (2014). Silica: A 

lung carcinogen. CA Cancer J Clin, 64, 63-69. 

Townsend, M. C. ACOEM Guidance 

Statement. (2011). Spirometry in the 

occupational health setting – 2011 Update. J 

Occup Environ Med, 53, 569-584.

7. Sample Forms.

Three sample forms are provided. The first 

is a sample written medical report for the 

employee. The second is a sample written 

medical opinion for the employer. And 

the third is a sample written authorization 

form that employees sign to clarify what 

information the employee is authorizing to be 

released to the employer.
9 0 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Small Entity Compliance Guide for Construction 

Draft – Do not Quote or Cite 5/25/2016 

117 

WRITTEN MEDICAL REPORT FOR EMPLOYEE

EMPLOYEE NAME: ____________________________________ DATE OF EXAMINATION: _______________

TYPE OF EXAMINATION: 

[ ] Initial examination [ ] Periodic examination [ ] Specialist examination 

[ ] Other: _______________________________________________________________________________________ 

RESULTS OF MEDICAL EXAMINATION: 

Physical Examination – [ ] Normal [ ] Abnormal (see below) [ ] Not performed 

Chest X-Ray – [ ] Normal [ ] Abnormal (see below) [ ] Not performed 

Breathing Test (Spirometry) – [ ] Normal [ ] Abnormal (see below) [ ] Not performed 

Test for Tuberculosis – [ ] Normal [ ] Abnormal (see below) [ ] Not performed 

Other:___________________ [ ] Normal [ ] Abnormal (see below) [ ] Not performed 

Results reported as abnormal: ____________________________________________________________________ 

__________________________________________________________________________________________________

[ ] Your health may be at increased risk from exposure to respirable crystalline silica due to the following: 

_________________________________________________________________________________________________ 

RECOMMENDATIONS: 

[ ] No limitations on respirator use 

[ ] Recommended limitations on use of respirator: ________________________________________________________

[ ] Recommended limitations on exposure to respirable crystalline silica: ______________________________________

_________________________________________________________________________________________________ 

Dates for recommended limitations, if applicable: _______________ to _____________

 MM/DD/YYYY MM/DD/YYYY

[ ] I recommend that you be examined by a Board Certified Specialist in Pulmonary Disease or Occupational Medicine

[ ] Other recommendations*: 

__________________________________________________________________________ 

__________________________________________________________________________________________________

Your next periodic examination for silica exposure should be in: [ ] 3 years [ ] Other: ___________________

 MM/DD/YYYY 

Examining Provider: ________________________________________ Date: _____________________ 

 (signature) 

Provider Name: ___________________________________________

Office Address: ____________________________________________ Office Phone: ___________________

*These findings may not be related to respirable crystalline silica exposure or may not be work-related, and therefore 

may not be covered by the employer. These findings may necessitate follow-up and treatment by your personal 

physician.

Respirable Crystalline Silica standard (§ 1910.1053 or 1926.1153) 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 91

Small Entity Compliance Guide for Construction 

Draft – Do not Quote or Cite 5/25/2016 

118 

WRITTEN MEDICAL OPINION FOR EMPLOYER

EMPLOYER: ____________________________________________ 

EMPLOYEE NAME: _______________________________________ DATE OF EXAMINATION: _______________ 

TYPE OF EXAMINATION:

[ ] Initial examination [ ] Periodic examination [ ] Specialist examination 

[ ] Other: _______________________________________________________________________________________ 

USE OF RESPIRATOR: 

[ ] No limitations on respirator use 

[ ] Recommended limitations on use of respirator:_________________________________________________________ 

Dates for recommended limitations, if applicable: _______________ to _______________

 MM/DD/YYYY MM/DD/YYYY

The employee has provided written authorization for disclosure of the following to the employer (if applicable): 

[ ] This employee should be examined by an American Board Certified Specialist in Pulmonary Disease or Occupational 

Medicine 

[ ] Recommended limitations on exposure to respirable crystalline silica:_______________________________________

__________________________________________________________________________________________________ 

Dates for exposure limitations noted above: _______________ to _______________

 MM/DD/YYYY MM/DD/YYYY

NEXT PERIODIC EVALUATION: [ ] 3 years [ ] Other: ______________ 

 MM/DD/YYYY

Examining Provider: ______________________________________ Date: ___________

 (signature) 

Provider Name: _________________________________________ Provider’s specialty:_______________________

Office Address: _________________________________________ Office Phone: ______________

[ ] I attest that the results have been explained to the employee. 

The following is required to be checked by the Physician or other Licensed Health Care Professional (PLHCP): 

[ ] I attest that this medical examination has met the requirements of the medical surveillance section of the OSHA 

Respirable Crystalline Silica standard (§ 1910.1053(h) or 1926.1153(h)). 
92 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Small Entity Compliance Guide for Construction 

Draft – Do not Quote or Cite 5/25/2016 

119 

AUTHORIZATION FOR CRYSTALLINE SILICA OPINION TO EMPLOYER 

This medical examination for exposure to crystalline silica could reveal a medical condition that 

results in recommendations for (1) limitations on respirator use, (2) limitations on exposure to 

crystalline silica, or (3) examination by a specialist in pulmonary disease or occupational 

medicine. Recommended limitations on respirator use will be included in the written opinion to 

the employer. If you want your employer to know about limitations on crystalline silica exposure 

or recommendations for a specialist examination, you will need to give authorization for the 

written opinion to the employer to include one or both of those recommendations. 

I hereby authorize the opinion to the employer to contain the following information, if relevant 

(please check all that apply): 

 Recommendations for limitations on crystalline silica exposure 

 Recommendation for a specialist examination 

OR

 I do not authorize the opinion to the employer to contain anything other than recommended 

limitations on respirator use. 

Please read and initial: 

___ I understand that if I do not authorize my employer to receive the recommendation for 

specialist examination, the employer will not be responsible for arranging and covering 

costs of a specialist examination. 

________________________________ 

Name (printed) 

________________________________ ______________________ 

Signature Date 
SMALL ENTITY COMPLIANCE GUIDE FOR THE RESPIRABLE CRYSTALLINE SILICA STANDARD FOR CONSTRUCTION 93

WORKERS’ RIGHTS

Workers have the right to: 

¢ Working conditions that do not pose a risk 

of serious harm.

¢ Receive information and training (in a 

language and vocabulary the worker 

understands) about workplace hazards, 

methods to prevent them, and the OSHA 

standards that apply to their workplace.

¢ Review records of work-related injuries 

and illnesses.

¢ File a complaint asking OSHA to inspect 

their workplace if they believe there is a 

serious hazard or that their employer is not 

following OSHA’s rules. OSHA will keep all 

identities confidential.

¢ Exercise their rights under the law without 

retaliation, including reporting an injury or 

raising health and safety concerns with their 

employer or OSHA. If a worker has been 

retaliated against for using their rights, they 

must file a complaint with OSHA as soon as 

possible, but no later than 30 days. 

For additional information, see OSHA’s 

Workers page (www.osha.gov/workers).

OSHA ASSISTANCE, SERVICES, AND PROGRAMS 

OSHA has a great deal of information to 

assist employers in complying with their 

responsibilities under OSHA law. Several OSHA 

programs and services can help employers 

identify and correct job hazards, as well as 

improve their safety and health program.

Establishing a Safety and 

Health Program

Safety and health programs are systems that 

can substantially reduce the number and 

severity of workplace injuries and illnesses, 

while reducing costs to employers. 

Visit www.osha.gov/safety-management for 

more information.

Compliance Assistance Specialists

OSHA compliance assistance specialists can 

provide information to employers and workers 

about OSHA standards, short educational 

programs on specific hazards or OSHA rights 

and responsibilities, and information on 

additional compliance assistance resources. 

Visit www.osha.gov/complianceassistance/cas

or call 1-800-321-OSHA (6742) to contact your 

local OSHA office.

No-Cost On-Site Safety and 

Health Consultation Services for 

Small Business

OSHA’s On-Site Consultation Program offers 

no‐cost and confidential advice to small and

medium-sized businesses in all states, with 

priority given to high-hazard worksites. OnSite consultation services are separate from 

enforcement and do not result in penalties 

or citations. 

For more information or to find the local OnSite Consultation office in your state, visit 

www.osha.gov/consultation, or call 1-800-321-

OSHA (6742).

Under the consultation program, certain 

exemplary employers may request 

participation in OSHA’s Safety and Health 

Achievement Recognition Program (SHARP). 

Worksites that receive SHARP recognition are 

exempt from programmed inspections during 

the period that the SHARP certification is valid.
9 4 OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION

Cooperative Programs

OSHA offers cooperative programs under 

which businesses, labor groups and other 

organizations can work cooperatively with 

OSHA. To find out more about any of the 

following programs, visit www.osha.gov/

cooperativeprograms

Strategic Partnerships and Alliances

The OSHA Strategic Partnerships (OSP) 

provide the opportunity for OSHA to partner 

with employers, workers, professional or trade 

associations, labor organizations, and/or other 

interested stakeholders. Through the Alliance 

Program, OSHA works with groups to develop 

compliance assistance tools and resources 

to share with workers and employers, and 

educate workers and employers about their 

rights and responsibilities.

Voluntary Protection Programs (VPP)

The VPP recognize employers and workers in 

the private sector and federal agencies who 

have implemented effective safety and health 

programs and maintain injury and illness 

rates below the national average for their 

respective industries.

Occupational Safety and Health 

Training Courses

OSHA partners with more than 25 OSHA 

Training Institute Education Centers at 

multiple locations throughout the United 

States to deliver courses on OSHA standards 

and occupational safety and health topics 

to thousands of students a year. For more 

information on training courses, visit 

www.osha.gov/otiec.

OSHA Educational Materials

OSHA has many types of educational 

materials to assist employers and workers in 

finding and preventing workplace hazards. 

All OSHA publications are free at 

www.osha.gov/publications and 

www.osha.gov/ebooks. You can also 

call 1-800-321-OSHA (6742) to 

order publications.

Employers and safety and health professionals 

can sign-up for QuickTakes, OSHA’s free, twicemonthly online newsletter with the latest news 

about OSHA initiatives and products to assist in 

finding and preventing workplace hazards. To 

sign up, visit www.osha.gov/quicktakes.

OSHA REGIONAL OFFICES

Region 1

Boston Regional Office

(CT*, ME*, MA*, NH, RI, VT*)

JFK Federal Building

25 New Sudbury Street, Room E340 

Boston, MA 02203

(617) 565-9860 (617) 565-9827 Fax 

Region 2

New York Regional Office

(NJ*, NY*, PR*, VI*)

Federal Building

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378 (212) 337-2371 Fax

Region 3

Philadelphia Regional Office

(DE, DC, MD*, PA, VA*, WV)

1835 Market Street 

Mailstop OSHA-RO/19

Philadelphia, PA 19103

(215) 861-4900 (215) 861-4904 Fax

Region 4 

Atlanta Regional Office

(AL, FL, GA, KY*, MS, NC*, SC*, TN*)

Sam Nunn Atlanta Federal Center

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(678) 237-0400 (678) 237-0447 Fax
Region 5

Chicago Regional Office

(IL*, IN*, MI*, MN*, OH, WI)

John C. Kluczynski Federal Building 

230 South Dearborn Street, Room 3244

Chicago, IL 60604

(312) 353-2220 (312) 353-7774 Fax

Region 6

Dallas Regional Office

(AR, LA, NM*, OK, TX)

A. Maceo Smith Federal Building

525 Griffin Street, Room 602

Dallas, TX 75202

(972) 850-4145 (972) 850-4149 Fax

Region 7

Kansas City Regional Office

(IA*, KS, MO, NE)

Two Pershing Square Building

2300 Main Street, Suite 1010

Kansas City, MO 64108-2416

(816) 283-8745 (816) 283-0547 Fax

Region 8

Denver Regional Office

(CO, MT, ND, SD, UT*, WY*)

Cesar Chavez Memorial Building

1244 Speer Boulevard, Suite 551

Denver, CO 80204

(720) 264-6550 (720) 264-6585 Fax

Region 9 

San Francisco Regional Office

(AZ*, CA*, HI*, NV*, and American Samoa, 

Guam and the Northern Mariana Islands)

San Francisco Federal Building 

90 7th Street, Suite 2-650

San Francisco, CA 94103

(415) 625-2547 (415) 625-2534 Fax

Region 10

Seattle Regional Office

(AK*, ID, OR*, WA*)

909 1st Ave, Suite 201A

Seattle, WA 98104 

Mailing address:

20425 72nd Ave South, Suite 150A 

Kent, WA 98032-2388

(206) 757-6700 (206) 757-6705 Fax

*These states and territories operate their own

OSHA-approved job safety and health plans and

cover state and local government employees as well

as private sector employees. The Connecticut, Illinois,

Maine, Massachusetts, New Jersey, New York and

Virgin Islands programs cover public employees only.

(Private sector workers in these states are covered by

Federal OSHA). States with approved programs must

have standards that are identical to, or at least as

effective as, the Federal OSHA standards.

Note: To get contact information for OSHA area 

offices, OSHA-approved State Plans and OSHA 

consultation projects, please visit us online at 

www.osha.gov or call us at 1-800-321-OSHA (6742).

HOW TO CONTACT OSHA

Under the Occupational Safety and Health Act of 1970, employers are responsible for 

providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure 

these conditions for America’s workers by setting and enforcing standards, and providing 

training, education and assistance. For more information, visit www.osha.gov or call OSHA 

at 1-800-321-OSHA (6742), TTY 1-877-889-5627.

For assistance, contact us.

We are OSHA. We can help.

Follow OSHA on X!
U.S. Department of Labor

For more information:

Occupational 

Safety and Health

Administration

www.osha.gov (800) 321-OSHA (6742)