Silica Standard (Part 7): Employee Understanding of Standard and Requirements

Miller & Martin PLLC Blog | November 20, 2018

One of the first items OSHA will request during a silica enforcement inspection will be the written exposure control plan. OSHA will also likely request training records regarding the plan and interview employees in order to demonstrate that each employee can demonstrate knowledge and understanding of the Standard and its requirements. The Standard requires that employees not only demonstrate knowledge of the plan and Standard, but demonstrate understanding of the plan. In the event initial training is not sufficient to convey knowledge and understanding to the level of OSHA’s satisfaction, it is suggested that on-going training regarding this Standard continue for all employees.

Employees must be able to:

  1. Demonstrate knowledge and understanding of the health hazards associated with exposure tasks in the workplace which may result in exposure;
  2. Identify specific measures implemented by the employer to protect employees from exposure;
  3. Understand the contents of the Silica Standard;
  4. Identify the competent person related to the Standard; and
  5. Understand the purpose and overview of the medical surveillance program.

This concludes the 7-part blog series on OSHA's Respirable Crystalline Silica Standard. If you have questions, contact Miller & Martin Attorney Neil Brunetz.

Tags: OSHA, Crystalline Silica Standard