Looking back to September 2017 when OSHA’s Crystalline Silica Rule was implemented, I’m wondering, in 2019, how many flooring contractors are following the OSHA regulation requirements of Table 1: “Specified Exposure Control Methods When Working with Materials Containing Crystalline Silica.”
My article in the November/December 2017 issue covered the regulation and requirements. Fast forward to today, and I still see a lot of contractors using small handheld floor grinders with nothing but a shop vac and no dust mask. And with tile setters, I often don’t even see a vacuum being used when they’re cutting tiles inside a home. Just a reminder that a Vacuum Dust Collection System (VDCS) is required anytime you’re working indoors.
So, can a shop vac be enough to meet OSHA requirements? There are a few things to look at. First, does the vacuum have enough CFMs (cubic feet per minute) for the size of the tool? In the table I referenced at the top of this article, it states: “Dust collector must provide 25 cubic feet per minute (CFM) or greater of airflow per inch of wheel diameter and have a filter with 99% or greater efficiency and a cyclonic pre-separator or filter cleaning mechanism.” That means for a 7 in. grinding wheel, which is common for flooring contractors, a minimum of 175 CFM is required. Look at your vacuum to see what it is rated at.
Next, does the filter meet the 99% or greater efficiency? If you’re purchasing the cheapest filter and running directly to the vacuum, chances are you are not in compliance. On a regular shop vac, you will need to get a cyclonic pre-filter. For the actual filter on the vacuum, my recommendation to installers is to just use a true HEPA filter. The HEPA standard requires that all true HEPA filters are able to remove 99.97% of airborne particles down to the size of 0.3 microns. And they do sell these types of filters for shop vacs. Remember, if you see dust blowing out from the exhaust port of your vacuum, you are not achieving 99% or greater efficiency.
According to the regulations, the Vacuum Dust Collection System (VDCS) must include:
- Hood or shroud recommended by the tool manufacturer.
- Vacuum recommended by the tool manufacturer with enough suction to capture dust at the cutting point.
- Filter with a 99% or greater efficiency in the vacuum exhaust and a filter cleaning mechanism.
- Vacuum exhaust hose capable of providing the airflow recommended by the tool manufacturer. A 1.5 to 2 in. diameter vacuum exhaust hose is typically adequate.
Using a handheld grinder with a VDCS indoors or in an enclosed area may not be enough to keep exposure to crystalline silica dust low, so extra ventilation may be needed. This can be supplied by using exhaust trunks, portable fans, air ducts and other means of mechanical ventilation to ensure air flow is not impeded by the movements of employees during work, or by the opening or closing of doors and windows.
When using walk-behind milling machines or floor grinders equipped with a VCDS indoors or in an enclosed area where dust can build up, a HEPA-filtered vacuum must be used between passes to remove loose dust.
The week prior to me writing this article, the regional instructors for the National Wood Flooring Association (NWFA) received training at the Festool distribution center in Lebanon, Ind. We had two great instructors: Brian “Sedge” Sedgeley and Brent Shively. My thoughts on the event? WOW! I’ve been using Festool products since about 1998 and I, as well as the other trainers on hand, realized how little we knew about the potential of the tools and their uses. For those of you who have not had the pleasure of working with Festool tools, it’s worth the investment (and yes, it is an investment). I still have the majority of tools I purchased around 1998 and they still work great along with my other Festool tools purchased over the years. If you ever have the opportunity to attend a training event, I highly recommend it, but be forewarned, you will be investing in more tools!
So, how does Festool relate to silica dust? Many flooring installers work around wood dust, which is also a carcinogen. Festool has dust extractors with true HEPA filtration that connect to their tools, and they also have the 204083 CT Cyclone Dust Collection Pre-Separator CT-VA 20 which stacks directly onto the extractors, which means they also meet the Table 1 silica regulations. I’ve also learned that there is a Festool Owners Group called FOG on the internet and have joined it so that I can keep learning from fellow professionals.
If you’re creating dust on your jobs and not using the dust containment systems out in the marketplace that comply to OSHA’s Table 1, don’t you think it’s about time? Especially since it’s required by OSHA and for best practices. After all, what end-user wants to be exposed to dust with the potential to cause health issues? So, why would you and your team?
For more information on OSHA’s silica standard, visit osha.gov/silica.