Crematory Operators And Silica
On March 25, OSHA published its final Silica Standard with an effective date of June 23, 2016. General industry businesses, such as crematories, have until June 23, 2018 to be fully compliant with the new standard. Affected workplaces could include vault manufacturers, marker/memorial manufacturers/engravers, cemeteries, and crematories. While the most severe exposures to crystalline silica result from stone cutting and sand blasting, done to clean sand and irregularities from memorials, monuments, exteriors of inurnment areas that are stone, and the like, the silica rule does also apply to crematory brick maintenance within the retort.
Brick maintenance, whether done by the crematory or by an outsourced company, will be a source of risk for silica exposure. But also consider the deterioration of bricks in the retort floor over time. Particles of bricks that are co-mingled with cremated remains constitute potential respirable silica which could result in employee exposure during retrieval of the cremated remains as well as during the processing/handling of the cremated remains until final disposition. For crematories performing a high volume of cremations, OSHA could easily deem this a daily practice involving respirable silica. Even lower volume crematories will likely cross the monthly practice threshold.
So how do you comply? Read on for a sampling of just a few of the things that need to be done. Then read the full article from Paul Harris in Volume 52, Issue 3 of The Cremationist, and sign up for the CANA-hosted webinar with Paul on this very topic January 19, 2017 at 1:00pm CST. Go to to register for the webinar today.
The Exposure Control Plan
The first step is to establish and implement a written exposure control plan that identifies tasks involving exposure to silica and methods to protect employees. It cannot be stressed strongly enough that the program needs to be real, not just on paper.
Employers must perform air testing to ensure that respirable crystalline silica is below the permissible exposure limit (PEL) 50 μg/m3 averaged over an 8-hour shift OR an employer may be exempt with Objective Data.
OSHA included specifics regarding medical examination. Beginning June 23, 2018, employees exposed above the PEL for 30 or more days a year must be offered medical examinations. Beginning June 23, 2020, employees exposed at or above the action level for 30 or more days a year must be offered medical examinations. Medical surveillance must be available at no cost to each employee. Since the action level is lower than the PEL threshold, after June 23, 2020, ALL exposed employees must be offered medical examinations in accordance with the standard.
The Physical Plant
When/If an employer finds that an employee’s exposure to airborne concentrations of respirable crystalline silica is, or can reasonably be expected to be, in excess of the PEL, the employer must establish a regulated area to prevent employees working in unrelated areas from exposure.
Engineering Controls and Work Practices
Employers must implement a plan involving the best engineering controls and work practices as a primary task. Wherever such feasible engineering and work practice controls are not sufficient to reduce limits, the employer shall use them nonetheless to reduce employee exposure to the lowest feasible level and shall supplement them with respiratory protection.
Personal Protective Equipment
The good news is that OSHA states the agency “only allows respirators when engineering and work practice controls cannot maintain exposures at or below the PEL.” However, the new standard requires respiratory protection when: air levels exceed the PEL for work periods even though the employer is implementing feasible engineering and work practice controls; air levels exceed the PEL during certain maintenance and repair tasks where engineering and work practice controls are not feasible; engineering and work practice controls are implemented and such controls are not sufficient to reduce air levels to or below the PEL; and during periods when the employee is in a regulated area.
Hazard Communication and Training
Employers must train employees about hazards and risks from crystalline silica exposure, control and work measures, and exposure monitoring.
As with any workplace safety program, documentation is essential for full compliance. OSHA will not accept an employer’s good word that a safety program exists; therefore good records will help employers avoid costly penalties.
While full compliance with the new Silica Standard is required by June 23, 2018, don’t be complacent. Begin creating or revising silica safety policies NOW!