Silica Enforcement Delayed for those in Construction 

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By Rachel Morgan, MPH, ASP
EHS Specialist at Palmetto EHS

The enforcement date for OSHA’s new Crystalline Silica in Construction Standard has been delayed from June 23, 2017 until September 23, 2017. The delay in enforcement is in order to give OSHA more time for the “development of additional guidance materials” as well as to give them “the opportunity to conduct additional outreach to the regulated community and to provide additional time to train compliance officers.” OSHA has released Fact Sheets about the new respirable crystalline silica rule for both construction and general industry employers, however at this time a Small Entity Compliance Guide has only been released for those covered by the construction standard. Sometime in the spring of 2017, they are expected to also release a Small Entity Compliance Guide for those covered under the general industry and maritime standards. Although enforcement of the written Silica Exposure Control Plans for those in construction will not commence until September 23, 2017, it is advisable that those covered by the new rule begin the development and implementation of Exposure Control Plans now. If you need help writing your Exposure Control Plan or sampling for respirable crystalline silica, contact us.

For more information about the delay of enforcement, see , and for more information from OSHA about the new silica rule, see

Beryllium Rule Effective Date Delayed

In February, we posted an article about OSHA’s final rule on beryllium in the workplace and noted that the the effective date of the final rule had been pushed back from March 10, 2017 to March 21, 2017. That effective date has now been postponed to May 20, 2017. The delays in the effective date of the final beryllium rule are due to the “Regulatory Freeze Pending Review” memorandum and is intended to give OSHA more time to review, evaluate, and asses the rule. Although the effective date of the beryllium rule has been pushed back, the compliance dates within the rule will not change, and most of the rule becomes enforceable on March 12, 2018. Contact us if you need help becoming compliant with the final beryllium rule.

OSHA’s New Beryllium Rule Takes Effect this Month

rachel photo-websiteBy Rachel Morgan, MPH, ASP
EHS Specialist with Palmetto EHS

OSHA has reduced the Permissible Exposure Limit (PEL) for beryllium from 2 μg/m3 to 0.2 μg/m3. The Short Term Exposure Limit (STEL) for beryllium has also been reduced from 5 μg/m3 (previously a Ceiling Limit) to 2 μg/m3. Both of the new exposure limits become effective on March 21, 2017, which was extended from March 10, 2017. Employers in general industry have until March 12, 2018 to become compliant with most of the requirements of the new rule, which is when it becomes enforceable by OSHA. The rule does give extended time for some of the provisions to be implemented, such as the requirements for some employers to have change rooms and showers for employees, and some of the required engineering controls.

Compliance with the reduced beryllium PEL is expected to reduce the risk of developing/dying from Chronic Beryllium Disease (CBD) and lung cancer. Some of the engineering controls to be used in order to obtain compliance include isolating the process, installing of ventilated enclosures, and using local exhaust ventilation. Employers should also evaluate employees work practices to control airborne and dermal exposure to beryllium, which may include using HEPA-filtered vacuums to keep work surfaces as free from beryllium as possible, and no longer dry sweeping dust/debris containing beryllium. In time, with compliance to the new rule, OSHA expects that 90 lives will be saved from diseases related to beryllium exposure per year, and 46 new cases of CBD will be avoided per year.

If you are in need of sampling employees exposed to beryllium, contact us.

Do Your Employees Have Exposure to Hexavalent Chromium?

Safety, industrial hygiene, OSHA compliance, training

By Rachel Morgan, MPH, ASP

Hexavalent chromium is a form of chromium that is present in many industrial operations and can cause a variety of illnesses. Welding on stainless steel is one of the main sources of hexavalent chromium exposure in the workplace. Other sources of exposure include smelting of ferro-chromium ore and chrome plating with chromic acid. Hexavalent chromium is a carcinogen and has the potential to cause lung cancer, respiratory tract irritation, and damage to the skin and eyes. Wheezing and shortness of breath are sometimes found in workers who become allergic to hexavalent chromium over time as well.

The Occupational Safety and Health Administration (OSHA) has both an Action Level (2.5 µg/m3) and a Permissible Exposure Limit (5.0 µg/m3) for hexavalent chromium. If initial monitoring of workers indicates that that they are exposed above the Action Level, employers are required to begin sampling every six months, however if workers are exposed above the Permissible Exposure Limit, employers are then required to sample every three months. If controls are put in place and resampling indicates that exposure has dropped below the Action Level, then the sampling can be discontinued if the results are confirmed by a second sampling event taking place a minimum of seven days later.

Any time conditions change in the workplace, such as a change in materials, equipment, ventilation, other control methods, processes, etc., the employer is required to perform sampling if they have any reason to believe that employee exposure is above the Action Level. In addition to the sampling requirements, OSHA’s Hexavalent Chromium standard also stipulates various other requirements, such as housekeeping, medical surveillance, hygiene areas, PPE, etc., when employees are exposed above OSHA limits.

If you are in need of initial sampling, periodic sampling, or sampling because you’ve implemented controls, contact us and we’ll be happy to help.

Respiratory Protection: Are You in Compliance?

Respirator Fit TestingBy Rachel Morgan, ASP
EHS Specialist at Palmetto EHS

Respiratory protection in general industry was the 4th most frequently cited OSHA standard by Federal OSHA in fiscal year 2015. With 5 million workers estimated to be wearing respirators, we thought it would be a good time to talk about achieving or remaining in compliance with OSHA’s Respiratory Protection Standard.

To begin, employers must have a written Respiratory Protection Program in place for employees using voluntary or required respirators (the written program is not required if employees are wearing dust masks voluntarily).

Employers must also ensure that employees are medically able to wear the respirator through a medical evaluation using a medical questionnaire that includes all of the information contained in Appendix C of OSHA’s Respiratory Protection Standard.

After employees have been medically cleared to wear the respirator, they must then be fit tested for all tight fitting facepiece respirators. It is also important, and required by OSHA, that the fit test be conducted with the same make, model, style, and size of the respirator that the employee will be using in the workplace. The fit testing can be performed quantitatively or qualitatively.

Once these steps have been completed, the employer must ensure that the respirators are being maintained appropriately, which includes cleaning and disinfecting, storage, inspection, and repair of the respirators.

Employees wearing respirators must also go through training about the respirators and their use. OSHA’s Respiratory Protection Standard outlines the topics that employees must be able to demonstrate knowledge about after going through training. The fit testing and training aspects are annual requirements required by OSHA.

If it has been more than a year since your employees were fit tested and trained, or if you need medical evaluations or help developing a written Respiratory Protection Program, contact us and we’ll help you get into compliance.

For more information on specifics regarding respiratory protection, please visit

Protecting Workers from Exposure to Zika

mosquitoBy Rachel Morgan, MPH, ASP, EHS Specialist at Palmetto EHS
Locally transmitted mosquito-borne Zika cases are slowly edging their way closer to South Carolina. Four cases were reported in Florida last week and mosquitoes in two areas within Miami-Dade County, including part of Miami Beach, are spreading the virus. Aedes aegypti and Aedes albopictus mosquitoes, both found in the southern United States, can carry the Zika virus and are aggressive daytime bitters (however, they will also bite at night). If bitten by one of these mosquitoes carrying the virus, roughly one out of five people will develop symptoms between two and seven days following the transmission. Symptoms include red/pink in the eyes, joint pain, rash, fever, and sometimes muscle pain and headaches as well.

Workers that spend most of their time outdoors likely have the greatest risk for exposure to the Zika virus. Because of this, OSHA has recommended the following for outdoor workers:

  • Inform workers about their risks of exposure to Zika virus through mosquito bites and train them out to protect themselves.
  • Provide insect repellents and encourage their use. (Appropriate insect repellents will contain an EPA-registered active ingredient.)
  • Provide workers with, and encourage them to wear, clothing that covers their hands, arms, legs, and other exposed skin. Consider providing workers with hats with mosquito netting to protect the face and neck.
  • In warm weather, encourage workers to wear lightweight, loose-fitting clothing. This type of clothing protects workers against the sun’s harmful rays and provides a barrier to mosquitoes. Always provide workers with adequate water, rest, and shade, and monitor workers for signs and symptoms of heat illness.
  • Get rid of standing water whenever possible to reduce or eliminate mosquito breeding areas. Train workers about the importance of eliminating areas where mosquitos can breed at the worksite.

If requested by a worker, consider reassigning anyone who indicates that she is or may become pregnant, or who is male and has a partner who is or may become pregnant, to indoor tasks to reduce their risk of mosquito bites.

In addition to outdoor workers, healthcare workers and those that work in labs who may be exposed to blood or other bodily fluids containing the virus are also at an increased risk for exposure to the Zika virus. OSHA has also released guidelines to help protect these workers as well. To see these guidelines and recommendations, as well as get more information about workers and the Zika virus, please visit!tab1.

OSHA’s Silica Standard is Effective June 23, 2016 – Are You Ready?

rachel photo-websiteBy Rachel Morgan, EHS Specialist at Palmetto EHS

OSHA has released a final rule containing two standards (one for maritime and general industry and the other for construction) to limit worker exposure to respirable crystalline silica. The rule, which was proposed in September of 2013, becomes effective June 23, 2016 and is estimated to prevent nearly 900 cases of silicosis each year and 600 deaths per year. Employers covered under construction have one year to comply with the standard, while those covered under general industry and maritime have two years. The new rule changes the PEL from a calculation based on the percent of silica dioxide to a standard 50 μg/m3 as an 8-hour TWA for general industry, construction, and maritime alike.

A few important requirements under the new standard for employers in general industry and maritime include:

  • Sample workers who may be exposed to respirable crystalline silica equal to or above the action level of 25 μg/m3 (0.025 mg/m3) as an 8-hour TWA.
  • Protect workers exposed at or above the new PEL of 50 μg/m3 (0.05 mg/m3)
  • Limit worker access in areas where there are high levels of respirable crystalline silica.
  • Control dust (with ventilation or wet methods) in areas where silica exposures are above the PEL (and provide them respirators when dust controls cannot lower levels below the PEL).
  • For workers exposed equal to or above the AL for 30 or more days/year, medical exams must be offered every three years (starting June 23, 2020). For workers exposed equal to or above the PEL for 30 or more days/year, medical exams must be offered every three years (starting June 23, 2018).
  • Develop a written exposure control plan.
  • Train workers on the risks involved with silica exposure and how to limit their exposures.

For more information on the new standards and the final rule, please visit the following

If you need help with silica sampling or OSHA Compliance, please contact us.


Cold Stress: What You Need to Know

coldBy Rachel Morgan, EHS Specialist with Palmetto EHS

We do not typically associate cold stress with South Carolina. However, with the return of the “polar vortex,” employers in the southeast must consider those workers at risk for developing injuries and illnesses associated with cold stress. Workers who are not acclimatized to colder temperatures are at risk for developing injuries and illnesses triggered by the cold, in addition to employees that are dressed inappropriately for the temperatures, have pre-existing medical conditions, or have wet clothing or skin as a result of their job duties.

Hypothermia, frostbite, and trench foot are three of the most well-known and common types of cold stress injuries and illnesses.

  • Hypothermia occurs when the internal body temperature falls below 95° The symptoms begin with the person shivering and progress to the cessation of shivering, confusion, slowed heart and breathing rates, and eventually can lead to unconsciousness and death if the person does not bring their body temperature back up.
  • Frostbite occurs when skin and tissues of the body freeze. This usually occurs in the extremities such as the hands and feet and will occur more quickly the lower the temperature. The symptoms begin with numbness and reddening of the affected area and progress to the development of white to gray patches on the skin, a hardening of the area, and possibly even blistering. In severe cases, amputation may be necessary.
  • Trench foot occurs when the feet are exposed to cold temperatures and a wet environment for a prolonged period of time. The tissues do not freeze, however the feet will become numb, turn red, swell, and blister.

For the health and safety of workers, employers have a responsibility to train employees on the hazards associated with cold stress, recognizing the symptoms, and how they can prevent and reduce the risk of developing injuries and illnesses caused by the cold. If possible, engineering controls should also be implemented to help reduce the risk of injuries and illness due to the cold temperatures. Additionally, employers should acclimatize their employees to the environment gradually and monitor the workers for signs and symptoms of cold stress. This is especially important in the southeast where workers are not typically exposed to extreme cold temperatures.

Cold stress can be prevented and managed when employers are willing to work with employees and employees are willing to work with each other. Proper precautions, training, and education are all necessary in keeping workers injury and illness free due to cold stress.

For more information and guidelines on what to do if you see someone experiencing the signs and symptoms of cold stress, please visit

OSHA’s Proposed Beryllium Rule

rachel photo-websiteBy Rachel Morgan, EHS Specialist

Beryllium is a necessary metal in various types of industry in the United States, ranging from the medical field to aerospace, defense, and electronics. It is a strong, yet lightweight metal that is frequently used as an alloy with other metals.

It is estimated that as many as 35,000 general industry workers are exposed to beryllium. Workers exposed to beryllium, through dermal contact or inhalation, can become sensitized to the metal. After sensitization, further exposure to beryllium can cause chronic or acute beryllium disease and increase workers risk of developing lung cancer. No cure is known for those who develop chronic beryllium disease and development of the disease can occur in workers exposed to beryllium below the current exposure limits.

The current OSHA PEL for beryllium is 2 μg/m3, however the agency has proposed a new rulemaking that would reduce the PEL to 0.2 μg/m3. The proposed rule would also require provisions such medical surveillance, regulated work areas, recordkeeping, training. OSHA estimates that the proposed PEL would prevent nearly 100 worker casualties every year. The agency also estimates that the proposed PEL would prevent 50 new cases of chronic beryllium disease each year.

Comments to OSHA about the proposed rule are due by November 5, 2015. For more information, please see

OSHA News Release on Changes to TB Directive

By Rachel Morgan, EHS Specialist

Tuberculosis is an infectious disease caused by the bacteria Mycobacterium tuberculosis. This bacteria causes 1.5 million deaths each year and worldwide about a third of the population is infected with the bacteria, according to the CDC. Protecting workers in health care settings that may come into contact with this bacteria is an important part of what OSHA has been tasked with.

Since 1996, OSHA has been using guidance from the “Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Facilities” report that was released by the CDC in 1994 to guide OSHA inspections and citations. In 2005 the CDC updated their report and released new guidelines pertaining to preventing the transmission of Mycobacterium tuberculosis. Using this 2005 version of guidelines from the CDC, OSHA updated its instructions for inspectors working in healthcare settings.

The new OSHA Instruction contains a few substantial changes. These include:

  • Classification of healthcare settings according to their risk for transmission.
  • In some cases, fewer tuberculosis screenings for workers.
  • Replacing “Purified Protein Derivative Test” (PPD) with “Tuberculin Skin Test” (TST).
  • Introduction of a new screening method – BAMT (Blood Analysis for Mycobacterium tuberculosis).
  • Coverage of added workplaces considered as healthcare settings.

With a disease as infectious as tuberculosis, keeping workers with the potential to be exposed as safe as possible is a must. For more information, please visit