The Silica Exposure Control Plan SOP

Purpose

This procedure produces and keeps current the written exposure control plan that 29 CFR 1926.1153(g) requires of a construction employer whose employees are exposed to respirable crystalline silica, and keeps it short enough to stay true. The failure it prevents: a plan downloaded once, filed, and never matched against the work the shop actually did. A task the plan never named is a task nobody chose a control for.

The general-industry plan at 29 CFR 1910.1053(f)(2) asks for tasks, controls and housekeeping; the construction plan adds an access procedure and a competent person. Most service shops core, cut and grind under the construction standard, so this plan is written to 1926.1153 and covers both. The exposure numbers and compliance paths are owned elsewhere (see related: Respirable Crystalline Silica and the Construction Standard).

Scope

Covers: building the plan the first time, keeping it current when a new task appears, the annual review the standard requires at 1926.1153(g)(2), designating the competent person, and making the plan available.

Does not cover: setting up the controls on a given job (see related: The Dusty Task Setup SOP), following a specific Table 1 entry (see related: How to Follow Table 1 When You Core or Grind Concrete), measuring exposure for a task outside Table 1 (see related: The Exposure Assessment SOP), or the respirator program itself, which lives under 29 CFR 1910.134 and its own written program.

Roles and responsibilities

Procedure

1. Inventory the tasks from your own tickets, not from memory. The office searches the last 12 months of job tickets and notes for the words that mean silica dust: core, chase, cut, grind, chip, drill, demo, tile, block, brick, stucco, concrete, mortar, fiber cement, quartz, countertop. The competent person turns each hit into a task line naming tool, material and location (outdoors, garage, finished interior). Acceptance: every hit is a task line or marked "not a silica task" with the reason. Wrong looks like a list written from memory, which drops the once-a-quarter tasks; stop rule: if the ticket search cannot be run, the review waits until it can. Hazard: none at this step, it is desk work.

2. Match each task to a Table 1 entry or mark it for assessment. For each task line, the competent person names the Table 1 entry it falls under at 1926.1153(c)(1) and writes the control that entry lists, including any respirator and its four-hour split. A task fits Table 1 only if the crew will fully and properly implement every control the entry lists; a partial match is not a match. Acceptance: every task carries either an entry name with its controls copied in, or the word "ASSESS" with a pointer to the exposure assessment. Wrong looks like a task assigned to the nearest-sounding entry because the right one would need a tool the shop does not own; stop rule: that task goes to the owner to buy the tool, assess, decline or subcontract, and it is not performed while it sits undecided. Hazard: none at this step, it is desk work.

3. Write the housekeeping and the respirator link per task. For each task, state how dust is cleaned up: HEPA-filtered vacuum or wet methods, never dry sweeping or dry brushing where it could add to exposure, and never compressed air on clothing or surfaces, both as 1926.1153(f) restricts them. Where an entry requires a respirator, the line names the respirator and says it is worn under the shop's written 1910.134 program. Acceptance: no task line says "clean up" without a method, and every respirator line names the program. Wrong looks like a respirator listed with no program behind it; stop rule: that task is not performed by anyone who has not been medically evaluated and fit tested, and the crew does the work without a respirator only if the entry requires none. Hazard: none at this step, it is desk work.

4. Write the access procedure for each place the work happens. For every task, state how other people are kept out of the dust: a closed door with the opening taped, a cone line at a stated distance outdoors, a stop on other trades entering, and the conversation with the occupant. 1926.1153(g)(1)(iv) asks for procedures to restrict access when necessary to minimize the number of employees exposed, including exposures generated by other employers or sole proprietors. The occupant is not your employee and OSHA does not reach them, but the same barrier protects them under your ordinary duty of care. Acceptance: each work location type carries a written access line. Wrong looks like a single "keep people away" sentence for every task; stop rule: a task with no access line is returned to step 2. Hazard: none at this step, it is desk work.

5. Designate the competent person and set the inspection cadence. The owner names, in writing, the person who can identify existing and foreseeable silica hazards and who has authority to take prompt corrective action, as 1926.1153(b) defines the role and (g)(4) requires one. The plan states a cadence: a field inspection of at least one silica task per month, plus the first time any new task is performed. Acceptance: a named person, a backup, and a cadence in the plan. Wrong looks like the owner named because nobody else was asked, with no time to inspect; stop rule: if the named person cannot meet the cadence in a given month, the backup does, and a missed month is logged, not skipped. Hazard: at each field inspection the inspector stands in the same dust as the crew, so the inspector wears whatever respirator the task's entry requires, under the same 1910.134 program, or watches from outside the access boundary.

6. Make the plan available and train to it. File the signed plan where any employee can read it (it must be available on request to employees, their representatives, OSHA and NIOSH under (g)(3)), give each tech the task table page, and train on the tasks each person performs, per 1926.1153(i). Acceptance: every tech can answer "what does the plan say for the task you did last week" in one sentence, checked by the competent person in a five-minute conversation. Wrong looks like a tech who knows the tool but not the plan entry; stop rule: that tech does not perform the task until retrained. Hazard: none at this step, it is a conversation.

7. Handle a task the plan does not list, the day it arrives. A tech or estimator who meets an unlisted task calls the competent person before the first cut. The competent person either writes the line that day through steps 2 to 4, or the task is not performed. Acceptance: the plan carries a dated amendment before the work starts, or the ticket shows the task declined or subcontracted. Wrong looks like "we will add it at the annual review"; stop rule: the task waits. Hazard: the tech on site has stopped with the tool unplugged and the material undisturbed, so no dust has been made; do not start a "quick test cut" to see how dusty it is.

8. Review the whole plan at least once a year. At the review the competent person reruns step 1 against the year's tickets, compares the new task list to the plan, checks the office's respirator-use tally per person against the 30-day trigger for medical surveillance under 1926.1153(h), observes at least one task in the field, and updates the plan. Acceptance: a dated, signed revision, or a signed note that nothing changed with the ticket count that supports it. Wrong looks like a re-signature with no ticket search; stop rule: no signature until the search is attached. Hazard: the field observation is a silica task in progress, so the observer wears what that task's entry requires or watches from beyond its access line.

The record this produces

The signed, dated plan and task table; the ticket search for each review; dated step 7 amendments; the competent person designation; the inspection log (date, job, task, finding, correction); training records; and the respirator-day tally per person. Air monitoring and objective data from step 2 are kept under 1926.1153(j), medical surveillance records under 29 CFR 1910.1020. Readers later: an inspector, a new competent person, and an owner asked by an insurer what the shop knew in a given year.

Worked pass: an annual review that found a task the plan could not hold

A nine-person plumbing and electrical shop runs its review in March. Plan version: last April.

SILICA PLAN TASK TABLE  rev. March (excerpt)
Task               Where     Table 1 entry   Resp
Core 4 in slab     garage    rig-mounted     none
Rotary drill       any       drills          none
 anchors in block            (shroud + HEPA)
Chase block wall   interior  grinder, other  APF 10
 for conduit                 than tuckpoint  over 4 hr
Cut fiber cement   outdoors  fiber-cement    none
 for vent boot               saw, 8 in max
Faucet hole in     interior  NONE MATCHED    -
 quartz top                  -> declined, sub
Housekeeping: HEPA vac all tasks, no dry sweep
Access: door taped (interior), 10 ft cones (outdoor)
Competent person: lead electrician; backup: owner

Step 1. The search returned 61 hits: 47 became task lines across five tasks, 14 were not silica tasks (units set on existing pads). New: 6 tickets in four months where a plumber drilled a faucet hole through an installed engineered-stone countertop. Pass.

Step 2 fails. The method was a wet diamond core bit fed from a spray bottle, indoors. The Table 1 drill entry lists a shroud with a dust collector and a HEPA-filtered vacuum, not a spray bottle, so no entry was fully implemented, and engineered stone carries far more crystalline silica than granite. Stop rule taken: the owner chose not to buy tooling or assess for six jobs a year and wrote the task as declined, with the fabricator drilling faucet holes before delivery. The task did not run again while undecided.

Step 3. Housekeeping read HEPA vacuum on all lines. The chasing line carries APF 10 over four hours; two techs chase. Pass.

Step 4. The core-drilling line had an access entry for garages only, but two of its tickets were in finished basements. A basement entry was added: door taped, the room's return grille covered while the rig runs, occupants out. Pass after amendment.

Step 5. The inspection log showed 10 of 12 months inspected and the 2 missed months logged as missed. Pass.

Steps 6 and 7. The five-minute check got a one-sentence answer from 8 of 9 techs; the ninth, hired in January, had never been given the task table page and was retrained before his next block job. The faucet task itself was a step 7 miss: six jobs ran without a call to the competent person. The fix was a line on the estimating checklist, "drilling or cutting stone, tile or masonry not on the task table: call before booking."

Step 8. The office's tally showed the two chasing techs at 11 and 7 respirator days, under the 30-day trigger, so no medical surveillance was owed under the standard on that count. The competent person watched one block-chasing job from outside the taped door, and signed the revision with the 61-hit search attached.

References

• 29 CFR 1926.1153, Respirable Crystalline Silica (construction): (b) competent person, (c) Table 1, (f) housekeeping, (g) written exposure control plan, (h) medical surveillance, (i) training, (j) recordkeeping
• 29 CFR 1910.1053(f)(2), the general-industry written exposure control plan
• 29 CFR 1910.134, Respiratory Protection, the program every respirator line points to
• See related: Respirable Crystalline Silica and the Construction Standard; How to Follow Table 1 When You Core or Grind Concrete; The Exposure Assessment SOP; The Dusty Task Setup SOP; Silica in Materials You Might Not Expect