OSHA Silica National Emphasis Program and Who It Targets

OSHA's National Emphasis Program (NEP) on respirable crystalline silica is the directive that tells OSHA offices which employers to put on silica inspection lists and what to check once inspectors arrive. The directive is CPL 03-00-023, effective February 4, 2020. As of September 2026 it is still the active version. No 2026 revision has been issued.

The program determines whether an establishment can be selected for a silica inspection without a complaint, a referral or a fatality. It covers general industry, maritime and construction. It enforces two standards:

• 29 CFR 1910.1053: general industry and maritime
• 29 CFR 1926.1153: construction

Last updated: September 27, 2026.

Selection starts from industry codes. It does not start from individual employers.

1. Appendix A of the directive lists target NAICS codes in general industry, maritime and construction.
2. A code is listed if OSHA believes the industry has the largest numbers of workers doing tasks with silica exposure above 100 μg/m³ as an 8-hour time-weighted average (TWA). That figure is twice the permissible exposure limit (PEL) of 50 μg/m³.
3. Each Area Office uses the list to build a randomized list of establishments for programmed inspections.

An establishment in a listed industry can be selected at random. It does not need a complaint or an injury record to be chosen.

OSHA's directive page names these target industries:

• Glass manufacturing
• Pottery
• Ceramics
• Brick
• Concrete products
• Countertops and artificial (engineered) stone

CPWR's Silica Safe summary adds landscaping services, state and local governments, concrete product manufacturing and machine shops. It also notes two further codes that OSHA tied to engineered stone work: 238140 (Masonry Contractors) and 337127 (Institutional Furniture Manufacturing).

OSHA expected about 2 percent of each region's annual inspections to target silica. It expected most of them to take place in construction, because most silica exposure occurs there.

The directive sets these steps:

• Before the visit. The compliance safety and health officer (CSHO) reviews the establishment's fatality and accident history and its injury and illness records.
• Scheduling. Inspections may be scheduled in any order that uses resources efficiently within a cycle. Where possible, they run at the same time as other programmed inspections.
• Sampling. The CSHO takes personal air samples. Results are compared with the PEL of 50 μg/m³ and the action level of 25 μg/m³, both as 8-hour TWAs.

The program also covers unprogrammed inspections. These start from a complaint, a referral or a fatality rather than from the randomized list.

The sources do not publish a fixed order in which inspectors request documents. They do show which records are checked and which are most often cited as missing.

• Exposure assessment. In general industry, and for construction tasks outside Table 1, the employer must show how exposures were assessed. Missing air monitoring documentation is a common deficiency.
• Table 1 compliance (construction). If a construction employer follows the Table 1 controls exactly for a listed task, no separate exposure monitoring is required. Inspectors check that each task matches its Table 1 method, such as wet methods or HEPA vacuums.
• Written exposure control plan. Inspectors verify that the written exposure control plan exists, including at job sites and trailers.
• Medical surveillance. Medical exams are required for employees exposed at or above the action level for 30 or more days per year.
• Respiratory protection. Inspectors check the written respiratory protection program, annual fit testing and training records.
• Regulated areas. In general industry, inspectors check whether regulated areas have been set up around silica-generating processes.

Under OSHA's separate engineered stone initiative, the violations cited most often were missing exposure control plans, insufficient exposure assessment, inadequate hazard communication and absent medical surveillance programs.

State Plan states must adopt a program equivalent to the NEP. Participation is mandatory, not optional. The sources do not describe each state's version or the dates on which states adopted it.

Brick manufacturing, Pennsylvania. OSHA's inspection of Watsontown Brick Company opened on February 12, 2026. It combined OSHA's Site-Specific Targeting plan with the silica NEP (OSHA news release).

Countertop fabrication, Georgia. In March 2026, OSHA cited two stone product firms after follow-up inspections. Stone Atlanta Countertops Inc. had no written respiratory protection program and no silica exposure control plan. Proposed penalties were $42,699. GT Stone Granite LLC had workers overexposed to silica and to noise. Proposed penalties were $73,607, including 8 repeat violations. Countertop and engineered stone fabrication is one of the industries the NEP names.

OSHA runs a separate engineered stone initiative. It complements the NEP but is a different program. Site-Specific Targeting is also a separate inspection plan. It can overlap with the NEP on a single employer, as it did at Watsontown.

• If the establishment's NAICS code is in Appendix A, it can be selected for a silica inspection with no complaint and no injury.
• If it is selected, inspectors will take personal air samples. They will check the exposure assessment or Table 1 records, the exposure control plan, medical surveillance records and respirator fit tests.
• If the establishment is in a State Plan state, the state's equivalent program applies.

The exposure limits and control requirements an inspection measures against are set out in the 2026 silica standards.