No Excuses: A Framing Safety Director’s Take on OSHA Standards

Originally published by: National Framers CouncilSeptember 26, 2017

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Editor’s Note: OSHA will begin enforcement of the crystalline silica standard in the construction industry as of September 23, 2017. Employers will be expected to continue taking steps to either come into compliance with the new permissible exposure limit, or to implement specific silica controls for certain operations as provided in Table 1 of the standard. With the goal of making this new standard as easy to understand as possible for the framing community, the safety committee of the National Framers Council (NFC) put together a guidance document and other tools for FrameSAFE subscribers to use to get their arms around this topic. Development included understanding the issue from both a framer and a GC’s perspective, which led to the following article from Dan Blankfeld, CHSM, SMS, CSMP, the national director of safety for NFC member CBG Building Company.


Safety managers and directors at all levels face pushback from workers and managers who believe the old line, “We have done it this way for years, so why do we have to change?” This attitude is why so many work place injuries and illnesses occur in the first place. Change can be difficult, but managers and workers must realize that, when changes in safety requirements occur, it’s always in the best interest of the worker. All injuries in the work place are preventable; there is no excuse for a worker to sustain an injury in modern construction.

Every business in the construction industry, regardless of size, should be fully aware of the legal requirements listed in the Code of Federal Regulations under OSHA Act 29 CFR 1926. Being unaware of the requirements set forth in these standards is not an excuse for noncompliance. Ignoring best safety practices puts workers at risk of injury or death.

When looking at compliance issues the first question to address is, “What is OSHA actually trying to do here?” OSHA is not a tax; it is not here to interrupt business or to close down jobsites. The sole mission of OSHA is to “ensure a place of employment free from recognized hazards that are likely to cause serious harm or physical injury to working men and women.” The bottom line? OSHA exists to protect workers.

A good example of the need to implement changing work standards is the recently enacted Silica Rule for Construction (29 CFR 1926.1153). This standard lowered the Permissible Exposure Limit (PEL) to one-fifth of the previous requirement and added medical clearance screening for silica-exposed workers who are required to wear respiratory protection for more than 30 calendar days per year.  

What’s important to recognize is that OSHA already had rules governing the exposure to silica, and under 29 CFR 1910.134 requirements for respiratory protection, training and medical evaluation were already established. Under the new standard, there are only a couple of new requirements to which the framing industry should be able to easily adapt. Silica has been a known health hazard since the Department of Labor released its findings in 1938; work practice controls have been available since 1937. Again, the goal of this requirement is to protect workers from exposure and ensure they do not develop preventable work-related illnesses.

Construction is inherently dangerous, but with pre-planning, proper training and adherence to safety practices we can successfully control the risks and make sure every worker goes home safely each and every day!

For more information about NFC’s FrameSAFE program, visit The NFC safety committee recommends this video for a concise overview of the new crystalline silica standard.

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