Approval (SME): | ______________________________ | Date: | _______________ |
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Approval (Office Dir.): | ______________________________ | Date: | _______________ |
Other Reviewers: |
Call ID: | D19-04-002 | Date Recd: | 4-25-2019 | |||||
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Received By: | Handled By: | |||||||
Subject: | Silica Workers Silica Medical Surveillance | |||||||
OPS Office: | ||||||||
Call Status: |
Caller Information | |||||||
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Name: | Employee Type: | ||||||
Phone: | Email: |
Question And Response Information | |||
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Reviewer: | |||
Keeler, Robin | |||
GC: | |||
HQ POC: | Field POC: | ||
Kara Bush | Kara Bush | ||
Enforcement: | |||
Question: | |||
Does the assessment below correctly outline requirements for enrollment of Silica Workers in Silica Medical Surveillance at Department of Energy DOE facilities? If not, what is the correct interpretation of these requirements? | |||
CFR Citation: | |||
10 CFR §851.23, Safety and health standards; 29 CFR §1926.1153, Respirable Crystalline Silica | |||
Regulatory Review: | |||
Question: Do I correctly understand that based on regulatory requirements and DOE Letters of Interpretation, that DOE contractors are only to count days on which 1 employees are “required under the RCS standard for construction to use a respirator for 30 or more days per year” AND 2 “exposures exceed the PEL” toward the 30-day medical surveillance enrollment requirement? No. Silica medical surveillance must be made available to employees who use respirators for 30 or more days per year in situations where respirators are required OR when workers will be occupationally exposed to respirable crystalline silica at or above the ACGIH TLV (a concentration of airborne respirable crystalline silica of 25 μg/m3, calculated as an eight-hour time-weighted average) for 30 or more days per year. Note that DOE contractors may use a modified Table 1 (See responses D19-02-001 and D19-03-002); if respirator use is dictated by a modified Table 1, then DOE contractors must offer medical surveillance if the worker is required to wear a respirator for 30 days or more per year, even if a worker wears a respirator for only a few minutes per day for short duration tasks. | |||
Attchment(s): | |||
https://responseline.doe.gov/pres/attachments/DOE Response Line - 30 Day Silica Medical FInal.pdf | |||
https://responseline.doe.gov/pres/attachments/D19-04-002_Medical Surveillance and Silica_FINAL_ 1-22-20.pdf | |||
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