Silica Limits for Oil and Gas Operations
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June 23, 2018 will bring new standards into play for the producers of our nation’s oil and gas resources, particularly the unconventional operations utilizing hydraulic fracturing. The long expected regulations on exposure to crystalline silica are scheduled to become effective on that date. These rules by the federal Occupational Health and Safety Administration (OSHA) require workers to be protected from exposure to respirable crystalline silica. These rules establish a new permissible exposure limit (PEL) of 50 micrograms of respirable crystalline silica per cubic meter of air averaged over an eight hour time period. The large amounts of sand and associated silica dust associated with hydraulic fracturing are targeted by these new standards. While many operators and service providers have already adopted measures to monitor and reduce silica exposure, the remaining operators and their service providers will be required to adopt these measures to stay ahead of eventual inspections and potential enforcement actions by OSHA.
Respirable silica particles are typically 100 times smaller than the sand found on beaches and playgrounds. According to OSHA, there is strong scientific evidence that exposure to respirable silica can increase a person’s risk of developing lung cancer. The World Health Organization, the National Institute of Health and the American Cancer Society have all designated crystalline silica a known human carcinogen. Once fully implemented for all covered industrial activities, OSHA expects to prevent 600 deaths a year from silica-related diseases.
While the exposure limitations become effective on June 23, 2018 for the oil and gas industry, the industry will have until June 23, 2021 to implement on-site engineering controls to comply with the exposure limits. Until then, employees can continue to wear respirators if their exposure exceeds the limitations. Additionally, industry employers are required to offer medical examinations to employees exposed above the PEL for 30 or more days beginning on June 23, 2018 and medical examinations to employees exposed at or above the PEL for 30 or more days beginning on June 23, 2020.
At this time it is uncertain what level of enforcement the oil and gas industry will see from OSHA, but it is best to be prepared to demonstrate a high level of compliance and understanding as these requirements move forward.
If you have questions about how these new standards may affect your business, please contact the author of this alert or a member of our energy or environmental team.