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OSHA Standards Interpretation and Compliance Letters
07/14/1975 - Mass concentration standard for amorphous silica originally listed incorrectly.

OSHA Standard Interpretation and Compliance Letters - Table of Contents OSHA Standard Interpretation and Compliance Letters - Table of Contents
  • Record Type: INTERPRETATION
  • Standard Number: 1910.1000
  • Subject: Mass concentration standard for amorphous silica originally listed incorrectly.
  • Information Date:07/14/1975

29 CFR 1910.1000 Table Z-3

July 14, 1975

MEMORANDUM FOR: DAVID H. RHONE
                Assistant Regional Director,
                Philadelphia

FROM:           BARRY J. WHITE
                Associate Assistant Secretary for
                Regional Programs

SUBJECT:        Mass Concentration Standard for Amorphous Silica
This is in response to your memorandum of April 29, 1975.

The formula for calculating the mass concentration exposure limit for total dust containing amorphous silica was listed incorrectly when originally promulgated under the Walsh-Healey Public Contracts Act. The correct formula is:

80 mg/M3
--------
% Si02+ 5.33% rather than


80 mg/M3
--------
% Si02

as listed in Table Z-3, 29 CFR 1910.1000 (formerly Table G-3), 29 CFR 1910.93 recodified May 28, 1975). The Solicitor's Office advises that since the formula was listed incorrectly when originally promulgated under Walsh-Healey, OSHA cannot enforce the proper formula until it has followed through with the requirements of section 6(b) of the Occupational Safety and Health Act of 1970.

Thus

80 mg/M3
--------
% Si02

is currently the lawful formula for calculating mass exposure limits for dust containing amorphous silica. Note that when the amorphous silica content of the dust falls below 5.33%, the exposure limit calculated from the formula exceeds the total dust exposure limit of 15 mg/M3 for inert (or nuisance) dust. Therefore at amorphous silica content below 5.33%, apply the total dust exposure limit for inert dust. Do not include the cyclone in the air sampling train since this is a total dust standard.

Any questions may be directed to Gail Brinkerhoff at 202/523-8096.


OSHA Standard Interpretation and Compliance Letters - Table of Contents OSHA Standard Interpretation and Compliance Letters - Table of Contents
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