Wet methods are the best control method for demolition operations. Half-mask respirators equipped with HEPA filters are also used for demolition work on concrete. This stakeholder stated that exposure monitoring conducted over the last two years showed only two cases in excess of the current PEL and that therefore a reduction in the PEL by half would be acceptable. A stakeholder from the construction industry noted that bystander exposure is a significant concern. He described a case in which a tuckpointer was working in an occupied building where the building owner was reluctant to shut down the HVAC system, thus potentially exposing the building occupants.
Employees use safety equipment and respirators and stay upwind of the dust.
He noted that wet methods do not work in foundries. A stakeholder that did not represent any specific industry sector requested that OSHA make available BLS data on silicosis and the SEP data. He further indicated that the PAT results for silica were a significant issue and that, as a result, all monitoring results are questionable. Finally this stakeholder suggested that OSHA reverse the hierarchy of controls and allow the use of respiratory protection before all feasible engineering, work practice and administrative controls are instituted. Not all operations can be enclosed.