Silica exposure control plan: what 1926.1153 requires and how to write yours

Who 1926.1153 covers and what sets it off

The construction standard applies to every occupational exposure to respirable crystalline silica in construction work unless exposure will stay below 25 µg/m³ as an 8-hour time-weighted average under any foreseeable conditions (1926.1153(a)). That 25 µg/m³ is the action level; the permissible exposure limit is 50 µg/m³ (1926.1153(b), (d)(1)). "Employee exposure" means what the worker would breathe without a respirator (1926.1153(b)), so a dust mask does not take a task out of the standard. Anything that cuts, grinds, drills, chips or breaks concrete, mortar, block, brick, tile, stone or rock makes the dust.

In Texas that is flatwork and concrete cutting, masonry and tuckpointing, demolition, utility crews ripping rock or caliche, road milling, and the countertop shops around Dallas–Fort Worth and Houston, which are general industry (covered below). OSHA has run a National Emphasis Program on silica since February 4, 2020 (CPL 03-00-023): it expressly includes employers with fewer than 10 workers, expects most of its inspections to be in construction, and puts at least 2 percent of each Region's inspections on silica. Texas is federal OSHA, Region VI. The 2026 maximums are $16,550 per serious violation and $165,514 per willful or repeated one; the missing plan, the missing competent person and the dry sweeping are separate lines.

Two paths: Table 1 or air monitoring

Every task takes one of two paths, and the plan has to say which.

Path one: Table 1, specified exposure control methods

For each employee on a task listed in Table 1, you fully and properly implement the engineering controls, work practices and respiratory protection the table specifies (1926.1153(c)(1)). Do that and you owe no air monitoring for the task, and you have met the respirator selection rules of 1910.134 for silica (1926.1153(e)(3)). Every row carries three conditions (1926.1153(c)(2)): exhaust indoors as needed against visible dust, enough water to keep visible dust down, and a cab that actually seals and filters. When one worker's Table 1 tasks add up to more than four hours in a shift, every task uses the over-four-hours respirator entry (1926.1153(c)(3)).

Path two: alternative exposure control methods

For a task not on Table 1, or where you do not fully implement the row, you are under 1926.1153(d): keep every employee at or below the 50 µg/m³ PEL, and assess the exposure of anyone who may be at or above the action level, with air monitoring data or objective data, or by scheduled personal sampling repeated every six months between the action level and the PEL and every three months above it (1926.1153(d)(2)). Controls come first; respirators cover only what the controls cannot (1926.1153(d)(3)). Objective data has to match or exceed your own conditions (1926.1153(b)); a tool brochure rarely does. For most crews, path two means an industrial hygienist for a day. Path one means buying the right saw.

Table 1: the 18 tasks, the control and the respirator

Table 1 of 1926.1153(c)(1), condensed. "Water" means an integrated water delivery system that continuously feeds the blade, not a helper with a hose. "Vac" means a commercially available shroud and dust collector with a 99 percent filter and the airflow and filter cleaning the row calls for. Every row also requires running the tool per the manufacturer's instructions. APF 10 is a half-mask or N95; APF 25 is a loose-fitting powered air-purifying respirator.

The written exposure control plan: paragraph (g)

Whichever path you take, you need a written exposure control plan, and 1926.1153(g)(1) lists what it contains at minimum:

1. A description of the tasks in the workplace that involve exposure to silica (1926.1153(g)(1)(i)). Your tasks, with your tools. Not all 18 rows.
2. The engineering controls, work practices and respiratory protection used for each task (1926.1153(g)(1)(ii)). For a Table 1 task, the row written out with your saw, your vacuum, indoors versus outdoors and the respirator by shift length.
3. The housekeeping measures (1926.1153(g)(1)(iii)). Wet methods, HEPA vacuum, no dry sweeping, no compressed air.
4. The procedures used to restrict access to work areas, when necessary, to minimize the number of employees exposed and their level of exposure (1926.1153(g)(1)(iv)), including exposure generated by other employers or sole proprietors on the site. Cones, tape, other trades out of the cut and upwind.

Three duties go with the document. Review and evaluate its effectiveness at least annually and update it as necessary (1926.1153(g)(2)). Make it available on request to each covered employee, their representatives, OSHA and NIOSH (1926.1153(g)(3)). And designate a competent person to make frequent and regular inspections of job sites, materials and equipment to implement the plan (1926.1153(g)(4)): someone capable of identifying existing and foreseeable silica hazards, with authorization to take prompt corrective measures (1926.1153(b)). On a six-person crew that is the foreman, by name.

Housekeeping, respirators, medical exams, training and records

Housekeeping (1926.1153(f))

No dry sweeping or dry brushing where it could add to silica exposure, unless wet sweeping, HEPA vacuuming or another method that minimizes exposure is not feasible. No compressed air on clothing or surfaces unless it is used with a ventilation system that captures the dust cloud, or no alternative is feasible. On a slab: squeegee and wet vac for slurry, HEPA vac for dust, nobody blowing off their pants.

Respirators (1926.1153(e) and 1910.134)

Where Table 1 or your assessment requires a respirator, it is required use, and the respiratory protection program of 29 CFR 1910.134 comes with it: a written program, a medical evaluation before first use, a fit test for any tight-fitting facepiece including an N95, and training (1926.1153(e)(2)). An N95 from a box with none of that is a citation under two standards.

Medical surveillance (1926.1153(h))

The trigger in construction is respirator days: medical surveillance is made available, at no cost, to each employee who will be required by this standard to use a respirator for 30 or more days a year (1926.1153(h)(1)(i)). The initial exam comes within 30 days of assignment and includes a medical and work history, a physical with emphasis on the respiratory system, a chest X-ray read by a NIOSH-certified B Reader, spirometry and a test for latent tuberculosis (1926.1153(h)(2)). Periodic exams repeat at least every three years, without the TB test (1926.1153(h)(3)). You get a written opinion limited to the date, that the exam met the standard, and any respirator limitations (1926.1153(h)(6)).

Hazard communication and training (1926.1153(i))

Silica goes into your hazard communication program under 1910.1200, covering cancer, lung effects, immune system effects and kidney effects (1926.1153(i)(1)). Each covered employee also has to demonstrate knowledge of the health hazards, the tasks on your jobs that create exposure, the controls and respirators you use, the contents of the standard, who the competent person is, and the purpose of medical surveillance (1926.1153(i)(2)(i)). A toolbox talk that walks the crew through your own plan, with a sign-in, covers the list.

Records (1926.1153(j))

Air monitoring results, any objective data you relied on, and the medical surveillance file for each covered worker, all kept under 29 CFR 1910.1020 (1926.1153(j)(1) to (3)): exposure records at least 30 years, medical records the duration of employment plus 30 years (1910.1020(d)(1)). On Table 1 with nobody at 30 respirator days, the plan, the competent person designation and the training records are the file.

Shops: 1910.1053 for countertop fabrication, foundries and abrasive blasting

Everything that is not construction work is under 29 CFR 1910.1053, the general industry standard, which also steps aside where objective data show exposure will stay below 25 µg/m³ under any foreseeable conditions (1910.1053(a)(2)). The differences that matter in a shop:

• No Table 1. The PEL is the same 50 µg/m³ (1910.1053(c)), and anyone who may be at or above the action level gets an exposure assessment (1910.1053(d)).
• Regulated areas (1910.1053(e)). Wherever exposure is or can reasonably be expected to be above the PEL, you mark off the area, limit entry, require a respirator inside, and post the sign in 1910.1053(j)(2): DANGER, RESPIRABLE CRYSTALLINE SILICA, MAY CAUSE CANCER, CAUSES DAMAGE TO LUNGS, WEAR RESPIRATORY PROTECTION IN THIS AREA, AUTHORIZED PERSONNEL ONLY.
• The written exposure control plan (1910.1053(f)(2)) has three elements: the tasks, the controls and respirators for each task, and the housekeeping. Annual review and availability are the same. There is no competent person requirement, though someone still has to own the plan.
• Medical surveillance triggers on exposure, not respirators: anyone at or above the action level for 30 or more days a year (1910.1053(i)(1)(i)). In a fabrication shop that is usually everyone on the saws.

Engineered stone is the material to take most seriously: OSHA's hazard alert on countertop work puts crystalline silica at up to 95 percent of it, against up to 50 percent in granite and little or none in marble, and reports engineered stone workers developing silicosis. The installer trimming a slab at the customer's house with a handheld saw is doing construction work, Table 1 row (ii).

A worked example: a six-person concrete crew

A flatwork crew: a foreman, a saw operator, a grinder, two laborers and a skid steer operator. The week is control joints in a new slab outdoors, grinding the high spots, and a few block openings with a cut-off saw. The plan is three task pages, two paragraphs and one name.

• Walk-behind saw, outdoors (row iv). Integrated water to the blade, flow set so there is no visible dust. Respirator: none. Inside a building: APF 10 from the first cut, and that line is in the plan because the same operator does both.
• Handheld grinder on joints and edges, outdoors (row xii). Shroud with a vacuum rated 25 cfm per inch of wheel diameter (a 7-inch wheel needs 175 cfm), 99 percent filter and cyclonic pre-separator. Respirator: none outdoors; APF 10 indoors past four hours.
• Handheld cut-off saw on block, outdoors (row ii). Water kit on the saw. Respirator: none up to four hours, APF 10 beyond. The laborer who cuts block in the morning and grinds in the afternoon adds the two times together (1926.1153(c)(3)).
• Housekeeping. Slurry squeegeed and wet-vacuumed before it dries, dry dust HEPA-vacuumed, no brooms, no compressed air.
• Access. Cones and tape around the cut, laborers upwind, other trades told at the general contractor's huddle.
• Competent person. The foreman, by name, who checks water flow and vacuum filters at the start of the shift and after every move, and who can stop a cut.

Nobody here needs a respirator unless the work goes indoors or past four hours on the cut-off saw, but the foreman logs required-respirator days from the first one, because at 30 in a year medical surveillance is owed.

Writing it in an afternoon

1. Walk the trailer. List every tool that touches concrete, masonry, stone or tile and match each to a Table 1 row. Anything that does not match goes on a second list for monitoring.
2. Write one page per task: tool, the control as the row says it with your make and model, indoors or outdoors, the respirator by shift length, who does it. Then the housekeeping paragraph, the access paragraph and the competent person's name.
3. Attach the respirator program if any row requires one, the medical surveillance tracking and the training record; date it, set the annual review date, and train the crew on it with a sign-in.

The mistakes we see

• "We use water, so we're fine." Table 1 says an integrated water delivery system that continuously feeds the blade. A helper with a garden hose, a pump sprayer, or a saw with the water kit removed is a path-two task with no monitoring behind it.
• No competent person named, or the name of a superintendent who covers six jobs and is never at the saw.
• Dry sweeping the slab at quitting time, and the compressor used to blow off boots and tools.
• Respirators without the program. N95s from a box, no medical evaluation, no fit test, and nobody counting the days toward the 30-day medical surveillance trigger.
• A plan copied from a vendor or a download with milling machines and crushers in it and nothing about the crew's cut-off saw. The inspector asks the crew which page is theirs.
• Written in 2017 and never reviewed. The review date is the first thing an inspector looks for after the competent person's name.

Questions we get

Not sure how this applies to your work? Ask the 29Safety safety team in the chat, or email safetyteam@29safety.com.