OSHA Answers Questions About Housekeeping, Other Requirements of New Silica Dust Rule
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Last month, OSHA provided answers to 64 questions about the silica dust rule for general industry. The FAQ covers all aspects of the rule, from exposure assessments to recordkeeping.
Here, we’ve summarized some of the questions and answers about housekeeping.
Does the rule allow industrial sweepers, and are HEPA filters required?OSHA
Yes, industrial sweepers are allowed. And, no, HEPA filtration is not required.
- When sweepers have HEPA filters, “and effectively remove dirt and dust,” their use falls under “HEPA-filtered vacuuming.”
- When sweepers don’t have HEPA filters, their use falls under “other [housekeeping] method.” These sweepers are permitted “as long as they are operated and maintained properly so as to minimize the likelihood of employee exposure.”
That said, OSHA “encourages” employers who are replacing their sweepers to purchase HEPA-filtered equipment.
What does “feasible” mean?
The standard prohibits dry sweeping or dry brushing, except when wet sweeping, HEPA-filtered vacuuming, or other methods to minimize the likelihood of exposure aren’t “feasible.”
OSHA clarifies that “infeasible” is not the same as “impossible.” The infeasibility argument is valid in cases where the preferred methods are either not effective, would cause damage, or would create a hazard.
Examples of situations where wet sweeping may be infeasible:
- The use of water would make an elevated surface slick and create a fall hazard.
- The water could come into contact with electrical panels, outlets, and other electrical equipment and such contact could damage the equipment or pose an electrical hazard.
- The water could come into contact with molten metal and create an explosion hazard.
- The water would cause the dust to harden.
- The use of water would adversely affect the quality of the final product.
Examples of situations where HEPA-filtered vacuuming may be infeasible:
- Tight or obstructed spaces prevent a vacuum, hose, or nozzle from accessing or effectively cleaning the space (such as around some pipes, meters, and gauges).
- Very large amounts of silica-containing materials must be cleaned, and the volume of material cannot effectively be cleaned by vacuuming.
OSHA notes that dry sweeping or dry brushing can be used only if none of the acceptable cleaning methods is feasible. In other words, if wet sweeping isn’t feasible, then try HEPA-filtered vacuuming, and vice versa.
If you wet dust before sweeping, is it “wet sweeping” or “dry sweeping”?
This is considered wet sweeping as long as the dust is still wet when swept.
Our patented DustGuardTM technology, available on some of our industrial sweepers, uses a light misting technique to deliver just enough moisture to attack airborne dust and debris. Learn more.
Do all vacuums need HEPA filters?
No. But…vacuums without HEPA filters can contribute to employee silica exposures. For example, fugitive dust from the discharge can put workers above the PEL.
Bottom line: if you’re going to use non-HEPA-filtered vacuums, make sure you’re taking other steps to reduce exposure.
OSHA addresses many other topics, including the use of compressed air in housekeeping, so if you have questions, check out the full FAQ. To learn more about the cleaning equipment that will help you become compliant, contact us.
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