Respirable crystalline silica limit value for foreign crews

EU law caps exposure to respirable crystalline silica dust at 0.1 mg/m3, measured over an eight hour reference period. The limit comes from Directive (EU) 2017/2398, which also listed silica dust work as a carcinogenic process. It applies to every worker on a site, including newly arrived foreign crews.

The failure mode: dry cutting with no measurement

A typical breach looks like this. A construction or manufacturing site takes on a foreign crew for cutting, grinding or drilling stone, concrete or ceramic material. The work is done dry, no exposure measurement is made, and the crew has no record of health surveillance. An inspection then measures respirable silica above 0.1 mg/m3 over eight hours, and the work stops until controls and surveillance are in place.

The cost falls on the employer's calendar as much as on its budget. A stopped task delays the following trades, and the crew stays on the payroll while measurement, engineering controls and medical arrangements are organised. Each of those steps is cheaper before the crew starts than after an inspection.

What Directive (EU) 2017/2398 changed

The directive amended Directive 2004/37/EC on carcinogens and mutagens at work in three places that matter to a site manager. It added a binding limit value for silica to Annex III. It added work exposing people to respirable crystalline silica dust generated by a work process to Annex I, the list of carcinogenic processes. It amended Article 14 on health surveillance. Member States had until 17 January 2020 to transpose it, so the rules now sit in national occupational safety law across the EU.

Because silica work is a listed carcinogenic process, the full set of employer duties under Directive 2004/37/EC applies to it, not only the numerical limit. The consolidated text is on EUR-Lex, and the amending act is published in the 2017/2398 text.

Who is affected and why the health record travels

The Commission estimates that about 9 million workers in the EU are exposed to respirable crystalline silica. It links inhaled silica dust to lung cancer, silicosis, chronic obstructive pulmonary disease and cardiovascular disease. Those diseases can appear years after exposure, which is why Article 14 lets the doctor or authority in charge require surveillance to continue after the work ends.

For a foreign crew on a fixed term assignment, this has a practical consequence. The worker may leave the site, or the country, before any effect shows. The employer should keep the exposure and surveillance records in a form that can follow the worker, and should explain the surveillance arrangement in a language the crew understands.

The social partners also run a voluntary track. The NEPSI agreement on the good handling and use of crystalline silica, signed in 2006, reaches over 375,000 employees at upwards of 9,170 sites, the Commission reports. Its outputs include a good practices guide, SME toolkits, e-learning and a standard method for measuring silica exposure. The Commission is also reviewing whether current EU exposure limits remain appropriate, in view of a possible seventh revision of the carcinogens directive.

Checklist before a foreign crew starts

• An exposure assessment for every cutting, grinding, drilling or blasting task, measured against 0.1 mg/m3 over eight hours.
• Controls in place before work begins, such as wet cutting or local extraction, with the method recorded.
• Health surveillance arranged for each crew member, with records kept beyond the end of the assignment.
• Safety instructions given in the crew's working language.

Similar duties apply in yards and coating shops, described in our guides to shipbuilding safety standards for foreign workers and to painters and blasters in shipbuilding. Current construction and manufacturing roles are on the Werklist job board.