From MCAA email
September 21, 2017
Urgent Silica Update
Dear MCAA Members,
We've just received word last night that there is a modified roll out for the new silica rule that begins enforcement on Saturday this week. For the first 30 days of enforcement OSHA will not issue citations to those employers who in good faith are trying to comply with the standard but are unable to reduce exposures or meet the requirements in Table 1. Instead OSHA will focus on providing compliance assistance and outreach in an effort to assist employers implementing the controls in Table 1.
Please understand that you need to working towards implementation and should have your training in place, written control exposure plan, and other components of the rule in place. You need to show that you have been working toward implementation and just have not completed some components yet and may need clarification from them on aspects of the rule. Likely they will not accept not having paperwork done as good faith efforts towards compliance. If they deem you not to be working towards compliance they may issue a citation. There is discussion that during this time frame that we may discuss expanding Table 1 a bit to include tasks that are deemed safe. Please click here to view a directive that was sent out last night from OSHA.
For those who assisted in our request for help in our last alert, we thank you as we think it was effective.