Identify the task and record its controls before concrete work
Before concrete work, record the specific task, planned controls, exposure evidence or oversight, respiratory protection, and housekeeping and access restrictions.
Key takeaways
- Identify the task and material.
- Record planned engineering controls.
- Identify exposure evidence or competent oversight.
- Record respiratory protection and fit evidence.
- Specify housekeeping and access restrictions.
Under the United States federal construction standard reproduced by Cornell Legal Information Institute, an employer must fully and properly implement the engineering controls, work practices, and respiratory protection specified for a task identified on Table 1. This obligation applies unless the employer assesses and limits the employee's exposure to respirable crystalline silica in accordance with paragraph (d) of that section. The record must reflect which path was taken: implementing the Table 1 controls or documenting the exposure assessment.
The "competent person" is a specific role defined in this same standard. According to Cornell Legal Information Institute, a competent person means an individual who is capable of identifying existing and foreseeable respirable crystalline silica hazards in the workplace and who has authorization to take prompt corrective measures to eliminate or minimize them.
This guide outlines five editorial record fields to help you organize this information. These fields are recommendations for your internal documentation, not a statutory form or a guarantee of legal compliance.
How task-specific control methods and exposure evidence differ
The distinction between implementing fixed controls and measuring actual exposure defines the two main branches of the record. This creates a binary choice in the task record: either the specific controls listed for that exact task are implemented, or an exposure assessment is conducted to limit the exposure.
Exposure assessment is not a guess based on visual cues. The employer shall assess the 8-hour TWA exposure for each employee on the basis of any combination of air monitoring data or objective data sufficient to accurately characterize employee exposures to respirable crystalline silica, according to Cornell Legal Information Institute. The term "8-hour TWA" refers to the time-weighted average over an eight-hour period. The evidence required is either air monitoring data or objective data that accurately characterizes the exposure. A task record that relies on the assessment route must therefore document the specific data source used to characterize the exposure for that employee.
In contrast to the specific task-based implementation required by the US federal standard, Canadian guidance frames the approach around the origin of the dust. Engineering controls are selected to control emissions at their source, according to CCOHS. When recording controls for a concrete task, the distinction matters: one entry documents the implementation of the specific engineering controls, work practices, and respiratory protection mandated for a Table 1 task, while the other documents the assessment of the 8-hour TWA exposure using air monitoring or objective data.
A reference table of silica-control evidence by publisher
The following table summarizes the specific checks and definitions provided by the supplied sources. Each row lists the publisher, its jurisdiction or scope, the stated check from the source text, and an editorial suggestion for how a contractor might record that detail in a task-specific file. These record implications are editorial recommendations for organizing site data; they are not statutory forms or universal legal requirements.
| Publisher | Jurisdiction/scope | Stated check | Record implication |
|---|---|---|---|
| Cornell Legal Information Institute | United States federal construction standard | See the competent person definition above, according to Cornell Legal Information Institute. | Record the name of the individual designated as the competent person and note their authorization to take prompt corrective measures. |
| HSE | Great Britain construction grinding-dust guidance | "On-tool extraction – use specially adapted equipment with on-tool extraction." according to HSE. | Note whether the specific grinder or scabbler used for the task is equipped with on-tool extraction. |
| HSE | Great Britain construction grinding-dust guidance | "The Workplace Exposure Limit for silica is 0.1 mg/m3 when averaged over 8 hours." according to HSE. | Record the 8-hour average Workplace Exposure Limit of 0.1 mg/m3 as the reference value for Great Britain grinding tasks. |
| CCOHS | Canadian silicosis prevention guidance | See the source-control guidance above, according to CCOHS. | Document that engineering controls for the task are selected specifically to control emissions at their source. |
| WorkSafe New Zealand | New Zealand workplace silica-dust guidance | "RCS dust is created when materials containing silica are cut, ground, drilled, sanded, polished or otherwise disturbed." according to WorkSafe New Zealand. | Identify the specific material disturbance action, such as cutting, grinding or drilling, that creates RCS dust for the task. |
| WorkSafe New Zealand | New Zealand workplace silica-dust guidance | "Set up exclusion zones with signs to mark the boundaries of work areas where RCS dust is created." according to WorkSafe New Zealand. | Record the location of signs marking the boundaries of exclusion zones where RCS dust is created. |
Use this table to verify that your task record includes the specific jurisdictional checks relevant to your site. For example, if you are working in Great Britain, the HSE rows provide the specific extraction method and exposure limit to note. If you are in New Zealand, the WorkSafe New Zealand rows specify the dust creation triggers and the guidance for signed exclusion zones. The record implication column offers a practical way to translate these source statements into a line item in your daily log. You can also use this structure to track which specific equipment or personnel are assigned to meet each check.
Keep the jurisdiction and scope columns distinct when copying data from this table. Do not mix the Great Britain exposure limit with the United States competent person definition in a single task record unless your project explicitly involves both regulatory frameworks. The table serves as a reference for what each source states; it does not replace the need to consult the full text of the applicable regulations for your specific project.
Finally, add the record implication as a note to yourself about what to verify on site.
For a contractor coordinating with a competent person, the Cornell Legal Information Institute row is particularly useful. It points to the role definition, allowing you to document that the individual has the capability and authorization required. This definition helps clarify responsibilities during the pre-work meeting.
The HSE rows provide specific technical details for grinding and scabbling. These details are specific to Great Britain and should be recorded as such.
What to record about extraction, respiratory protection and fit testing
Record the specific extraction method selected for the task. Note that this guidance applies specifically to grinding-dust scenarios in Great Britain; do not generalize this requirement to other jurisdictions, equipment types, or concrete tasks.
Document the Respiratory Protective Equipment (RPE) required for the task. The source specifies that you need RPE with an assigned protection factor of 20, such as an FFP3 disposable mask or a half mask with a P3 filter HSE. This protection factor applies within the scope of Great Britain construction grinding-dust guidance.
If the work involves longer duration, specifically over an hour without a break, record the consideration for powered RPE with the same protection level. The source suggests considering powered RPE with the same protection, for example a TH2 powered hood/helmet HSE. This recommendation is scoped to Great Britain construction grinding-dust guidance and applies to tasks exceeding one hour without a break.
Record the fit testing requirement for the selected RPE. The source states that fit testing is needed for tight fitting masks HSE. This requirement is part of the Great Britain construction grinding-dust guidance.
Document the inspection interval for dust extraction equipment. The source states that someone competent should examine any dust extraction equipment thoroughly and test its performance at least once every 14 months HSE. This interval applies to the scope of Great Britain construction grinding-dust guidance.
Record the task, the specific extraction equipment, the RPE type and protection factor, the fit testing status, and the next inspection date in your task record.
How to record housekeeping, exclusion zones and competent follow-up
Record housekeeping methods as a distinct entry in the task record, specifying whether wet sweeping, HEPA-filtered vacuuming, or other exposure-minimizing methods are planned. Under the United States federal construction standard, the employer shall not allow dry sweeping or dry brushing where such activity could contribute to employee exposure to respirable crystalline silica unless wet sweeping, HEPA-filtered vacuuming or other methods that minimize the likelihood of exposure are not feasible, according to Cornell Legal Information Institute. For tasks involving concrete or engineered stone, WorkSafe New Zealand guidance states to keep the work material wet while work is carried out on them, such as cutting or polishing, according to WorkSafe New Zealand.
Exclusion zones require a separate record entry that details the physical boundaries and signage. Your record should list the specific signs used and the location of the boundary relative to the cutting or grinding equipment. Do not assume that a general site perimeter covers these specific dust-generating areas; the record must identify the exact zone for the task at hand.
Competent person follow-up is a mandatory coordination step in the United States. The employer shall designate a competent person to make frequent and regular inspections of job sites, materials, and equipment to implement the written exposure control plan, according to Cornell Legal Information Institute. Record the name of the designated competent person and the scheduled frequency of these inspections in your task record. This entry ensures that the inspection duty is assigned to a specific individual rather than remaining a general responsibility.
When documenting exposure evidence, remember that monitoring results do not negate the need for physical controls. WorkSafe New Zealand states that exposure monitoring does not replace the need for control measures, according to WorkSafe New Zealand. Therefore, even if air monitoring results are low, the record should still document the planned control measures. Do not use a clean monitoring result to justify omitting the housekeeping or exclusion zone entries from the task record.
Your next step before concrete work
Take the next concrete-work task to the site's competent person and record the named task, planned controls and missing evidence in the existing task record before the crew starts. You can integrate this task record into your broader site documentation, such as your Construction Daily Log Checklist for Supervisors. For other pre-work checks, use the site's portable ladder checks.
FAQ: concrete-work silica-control records
What goes in a task-specific silica-control record?
Record five distinct editorial fields: the specific task and material, the engineering controls planned, the exposure evidence or competent oversight, the respiratory protection and fit evidence, and the housekeeping and access restrictions. These fields organize your task record but do not constitute a statutory written exposure control plan.
Does low visible dust prove that exposure is low?
No. Do not use a visual check of dust levels as proof that exposure is low.
Is a respirator a substitute for engineering controls?
No; use the applicable control route described above.
Which facts apply specifically to grinding rather than every concrete task?
The HSE extraction and RPE guidance here applies specifically to scabbling or grinding in Great Britain. This guidance is scoped to scabbling or grinding; do not generalize its assigned protection factor or extraction advice to every concrete task or other jurisdictions.
How should housekeeping and access restrictions be recorded?
Record the specific housekeeping method, such as wet sweeping or HEPA vacuuming, and the location of exclusion zone signs. Keep these jurisdiction-specific limits separate in your records.