Dsg standards and Guidance Update


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DSG Standards and Guidance Update


Overview

  • OSHA’s Fall 2010 Regulatory Agenda

  • PELs Update Project

  • DSG Guidance Projects





OSHA’s 2010 Fall Agenda



Items Nearing Completion

  • Standards Improvement Project III

  • General Working Conditions in Shipyards

  • Electric Power Generation, Transmission and Distribution

  • Hazard Communication/GHS



Standards Improvement Project III

  • Proposal published 7/2/10

  • Comment period ended 9/30/10

  • Types of Issues Addressed include:

    • Definition of potable water
    • Transfer of records to NIOSH
    • Outdated medical recommendations in the lab standard
    • Specifications regarding hand dryers and warm air


General Working Conditions in Shipyards (Subpart F)

  • Proposal published 12/20/07

  • Comment period ended 3/19/08

  • Public Hearings 9/10-11/08 and 10/21-22/08

  • Post hearing comment period ended 2/20/09

  • Submitted to OMB 11/2010



General Working Conditions in Shipyards (Subpart F)

  • Goals of the rule are to consolidate, update, and enhance provisions applied to shipyard employment

  • Topics addressed include housekeeping, illumination, sanitation, medical services/first aid, motor vehicle safety and lockout/tagout



Electric Power Generation, Transmission and Distribution (Subpart V)

  • Proposed rule published

  • 6/15/05

  • Public hearings 3/6/06

  • Record re-opened in 10/22/08

  • Record re-opened again 9/14/09 with public hearings 10/28/09

  • Next step: Departmental and OMB review



Electric Power Generation, Transmission and Distribution (Subpart V)

  • Addresses work practices to be used during the construction, operation and repair of electric power lines and equipment

  • Proposal would:

    • Update the existing standard based on latest consensus standards
    • Include new provisions for contractor-host information exchange, protection from electric arcs, minimum approach distances, fall protection from aerial lifts


Revision of the Hazard Communication Standard to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)

  • Proposal published 9/30/09

  • Comment period ended 12/29/09

  • Informal public hearings

    • Washington DC 3/2 -5,2010
    • Pittsburg PA 3/31/10
  • Post hearing comment

  • period ended 6/1/10



Major revisions to the HCS

  • Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.

  • Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.

  • Safety Data Sheets: Will now have a specified 16-section format.



What are the benefits of aligning the HCS to the GHS?

  • The Primary benefit is to increase the quality and consistency of information provided to workers, employers and chemical users

    • Reduce confusion and increase comprehension of hazards
    • Improve downstream risk management
    • Facilitate training
    • Help address literacy problems
  • Other benefits include facilitation of international trade in chemicals



Major Issues raised

  • Inclusion of TLV’s on Safety Data Sheets

  • NFPA sign language vs. GHS

  • Training Times and Costs



Walking & Working Surfaces; Personal Fall Protection Equipment (Subparts D and I)

  • NPRM published

  • 5/24/10

  • Public Hearings held 1/18-21/11

  • Post-hearing comment period ends 4/6/11



Walking & Working Surfaces; Personal Fall Protection Equipment

  • Reflects changes in technology and improvements in industry work practices

  • Provides greater compliance flexibility for the mitigation of fall hazards

  • Reorganizes the rule in a clear, logical manner, thereby facilitating compliance and enhancing employee protection

  • Adds a section to Subpart I providing criteria for fall protection equipment



MSD Column

  • Published the NPRM 1/29/10

  • Comment period closed 3/30/10

  • Public meeting held 3/9/10

  • Submitted to OMB 6/16/10

  • Final rule withdrawn from OMB 1/25/11

  • Special small business stakeholder – 4/11/11 & 4/12/11



Items Nearing Proposal

  • Silica

  • Beryllium



Silica

  • Initiated and completed peer review of the health effects and risk assessment

  • Submitted to OMB for review February 2011

  • Next step: Publish the NPRM

  • Issues: PEL, alternatives to exposure assessment



Beryllium

  • March 2010 initiated peer review of the risk assessment and health effects

  • November 2010 peer review completed

  • Next step:

    • Peer review of economic analysis May 2011
    • NPRM
  • Issues

    • PEL, use of the Beryllium Lymphocyte Proliferation Test (BeLPT), Scope


New Major Initiatives

  • Combustible Dust

  • Injury and Illness Prevention Programs



Combustible Dust

  • Published ANPRM 10/21/09

  • Held Stakeholder meetings

      • December 2009, Washington, DC
      • February 2010, Atlanta, GA,
      • April 2010, Chicago, IL
      • June 2010 Virtual stakeholder meeting
  • Next Step:

      • Initiate SBREFA in April 2011


Issues Raised in Combustible Dust Stakeholder Meetings

  • One size does not fit all – not all dusts are the same

  • Differing opinions on how to define combustible dust

  • Debate over a performance-based vs. specification-oriented standard

  • Some did not want outright adoption of NFPA standards



Injury and Illness Prevention Programs

  • The core elements of Injury and Illness Prevention Programs are:

      • Management leadership;
      • Worker participation;
      • Hazard identification and assessment;
      • Hazard prevention and control; and
      • Education and training


Injury and Illness Prevention Programs

  • Stakeholder meetings

      • June 3, 2010; East Brunswick, NJ
      • June 10, 2010; Dallas, TX
      • June 29, 2010; Washington, DC
      • July 20, 2010: Washington, DC
      • August 2, 2010: Sacramento, CA
  • Next Step: Initiate SBREFA June 2011



PELs Update Project

  • Formation of internal OSHA taskforce in March 2010 to develop options for addressing OSHA’s outdated PELs

  • Stakeholder meeting 6/24/10 with invited experts across business, labor and academia



Options Discussed

  • Substance-by-substance approaches

  • Control-based approaches

  • Policy/process approaches

  • Annotation of OSHA’s Z-Tables

  • Public forum to nominate chemicals of most concern



OSHA PELs Web Forum

  • Web forum to nominate chemicals 8/16-31/2010

  • 130+ comments

  • Top Vote Getters:

    • Isocyanates
    • Halogenated wastes
    • Manganese fume
    • Carbon Dioxide
    • Sulfuric acid
    • Mercury


Guidance Projects



Recently Published/Pending Guidance

  • Updated Bloodborne Pathogen Fact Sheet

  • Respiratory Protection Video for Health Care Workers

  • Aerial Lift Fact Sheet

  • Laboratory Safety Guidance Booklet

  • Subpart S E-Tool



Questions?




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