851 Silica Dust Safety in Construction

Written Exposure Control Plan (ECP)

Maintaining and Reviewing the Exposure Control Plan

The employer must review and evaluate the effectiveness of the written Exposure Control Plan (ECP) at least once every year. This review helps make sure that all dust control measures remain effective and that the plan reflects current work practices. The plan must be updated when tasks, equipment, materials, or control methods change in ways that could affect exposure to respirable crystalline silica.

Examples of ECP Review and Updates:

• The ECP was revised to include new dust control measures for a tile saw introduced in March 2025.
• The plan was updated after the company switched from dry cutting to wet cutting methods for concrete work.
• The review identified that the ventilation system filters in the grinding area were no longer performing effectively, leading to a scheduled replacement and update of maintenance procedures.
• A new section was added to include training for temporary workers who assist with sandblasting operations.

Employee Access to the Plan

The written Exposure Control Plan must be readily available to all employees and their designated representatives. Access to the plan helps ensure that workers understand how they are protected, what control measures are used, and who to contact with concerns about silica exposure.

Examples of Employee Access:

• Printed copies of the ECP are stored in the site office and are available upon request from the site supervisor.
• The company maintains a digital copy of the ECP on its internal safety portal, accessible through employees’ mobile devices.
• During weekly safety meetings, supervisors review one section of the ECP with workers and discuss how it applies to current job tasks.
• A summary of key ECP procedures is posted on the jobsite bulletin board in both English and Spanish.

Designating a Competent Person

OSHA requires the employer to assign a competent person to oversee silica safety on the jobsite. A competent person is someone who can identify existing and predictable hazards and has the authority to take prompt corrective action. This person ensures that the Exposure Control Plan is being followed and that dust control measures are maintained in working condition.

Examples of Competent Person Duties:

• The site foreman, trained as a competent person, inspects dust extraction systems daily to verify that hoses and filters are functioning properly.
• The safety manager conducts weekly inspections of silica-generating activities and ensures wet methods and ventilation controls are used as described in the ECP.
• The competent person documents findings during inspections and immediately stops work if dust levels exceed the permissible exposure limit (PEL).
• The competent person ensures that replacement filters and water suppression equipment are available before work begins each day.

ECP Evaluation

Regular inspections and evaluations of the Exposure Control Plan are essential in both general industry and construction workplaces. Evaluating the ECP helps identify areas for improvement and ensures compliance with OSHA standards. Proper documentation of these evaluations also supports a positive outcome during OSHA enforcement inspections.

Examples of ECP Evaluations:

• During a quarterly review, the company compared personal air monitoring results with exposure limits to confirm the effectiveness of engineering controls.
• A follow-up inspection found that vacuum systems used for surface grinding were not collecting enough dust, leading to the purchase of higher-efficiency units.
• After a near-miss incident involving dry sweeping, the ECP was revised to include mandatory wet cleanup procedures for all work areas.
• Annual ECP audits are performed by an outside industrial hygienist to provide an independent evaluation of control measures and documentation practices.

To help ensure an effective ECP and maintain compliance, employers should regularly review each area in the Exposure Control Program Checklist. This proactive approach helps protect employees, reduce exposure to respirable crystalline silica, and maintain a safe and healthy workplace.

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