11.4 Hazard Communication, Silica, Temporary Power & PPE

11.4 Hazard Communication, Silica, Temporary Power & PPE

OSHA requires employers to control hazards through the applicable standard and the hierarchy of controls. Training and PPE supplement elimination, substitution, engineering controls, and safe work practices; they do not excuse a feasible required engineering control.

Hazard communication

A construction Hazard Communication program covers the hazardous chemicals employees may encounter. Maintain a written program, an inventory linked to product identifiers, shipped and workplace labels, readily accessible safety data sheets, and employee information and training. Coordinate information among employers on a multi-employer project so that other employers know what chemicals are present, how SDSs can be accessed, what precautions apply, and how labeling will be handled.

The standardized SDS has 16 sections. OSHA enforces the occupational content, while sections 12 through 15 address ecological, disposal, transport, and regulatory information administered by other agencies. A portable secondary container can avoid a workplace label only under the narrow immediate-use rule for the employee who performed the transfer. An unlabeled shared bucket or bottle is not immediate personal use.

Respirable crystalline silica

Construction activities such as cutting concrete or masonry, tuckpointing, drilling, grinding, and jackhammering can create respirable crystalline silica. The construction permissible exposure limit is 50 micrograms per cubic meter as an eight-hour time-weighted average. The action level is 25 micrograms per cubic meter as an eight-hour TWA.

Employers can follow OSHA Table 1 for a listed task by fully and properly implementing its equipment, engineering controls, work practices, and respiratory protection for the task and duration. When Table 1 is correctly used, exposure measurement is not required for that task. For a task not handled through Table 1, the employer performs the required exposure assessment and protects workers based on the result.

The written exposure control plan identifies tasks, controls, housekeeping methods, and procedures restricting access. A competent person makes frequent and regular inspections of jobsites, materials, and equipment as necessary to implement the plan; OSHA does not replace that performance duty with a universal once-daily inspection phrase. Avoid dry sweeping or compressed-air cleaning where it could contribute to exposure unless the standard's feasibility conditions are satisfied.

Medical surveillance in construction is tied to employees who must use a respirator under the silica standard for 30 or more days per year, not merely to any measurement at the action level. Required respiratory protection also triggers the respiratory-protection program, including medical evaluation before use, fit testing for tight-fitting facepieces, training, maintenance, and seal restrictions.

Temporary electrical protection

For covered 120-volt, single-phase, 15- and 20-ampere receptacles not part of permanent wiring, the employer provides GFCIs or an assured equipment grounding conductor program. An AEGCP must be written and implemented by competent persons. Inspect cord sets, receptacles, and cord-and-plug equipment before each day's use and after conditions that could cause damage. Test grounding continuity and terminal connection before first use, after repair, after suspected damage, and at intervals not exceeding three months; fixed cord sets not exposed to damage may use the standard's six-month interval where applicable.

The employer keeps the required test record. OSHA allows records by logs, color coding, or other effective means; quarterly colored tape is a common system, not the only legal record. Remove damaged equipment from service until repaired and tested. Flexible cords must be of an approved hard- or extra-hard-service type where required and protected from damage. Field repair or splicing is not answered by a blanket slogan: the repaired cord must retain the insulation, outer sheath, usage characteristics, and equipment-grounding integrity required by the standards and listing.

De-energize and control circuits and equipment before work as required. Tags identify the hazard and locks prevent operation. Employer procedures govern verification and the controlled removal of a lock when the authorized employee is unavailable; never improvise removal.

PPE selection

Select head, eye, face, foot, hearing, hand, high-visibility, and respiratory protection from the hazard assessment and applicable standard. Type I and Type II helmets address impact direction; Class G, E, and C address electrical protection. Class E is appropriate where electrical exposure requires it, not automatically for every framing or commercial task. A face shield generally supplements rather than replaces primary eye protection. Inspect PPE, train users, enforce correct fit, and replace damaged or contaminated equipment.

Exam trap

Separate thresholds from triggers. The silica action level is not itself the medical-surveillance trigger, color tape is not the sole AEGCP record, and a high-voltage hard hat class is not mandatory without the corresponding hazard assessment.

Hazard-control matrix

Engineering and work-practice controls come before relying on PPE where the standard requires that hierarchy. A generic PPE rule cannot cure a missing silica control, unlabeled chemical, or defective temporary-power system.