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OSHA's Regulatory Agenda to Impact
Metalcasting Industry

Released January 4, 2010

OSHA’s latest semiannual regulatory agenda, released in December, includes nearly 30 regulatory items ranging from crystalline silica and combustible dust to musculoskeletal disorder reporting requirements.

Of particular interest to the metalcasting industry is the agency’s decision to move forward on a rulemaking to reinstate the “musculoskeletal disorders column” on its injury and illness recordkeeping forms (OSHA 300 Log) and add a definition of such musculoskeletal disorders to the Occupational Safety and Health Act. The MSD column was removed from the OSHA 300 Log in 2003. OSHA’s intention to collect this type of data reflects that musculoskeletal injuries are a very high priority and a possible interest in developing some form of an ergonomics standard.

Other agenda items impacting the metalcasting Industry include:

• Silica: OSHA is moving ahead with plans to propose a comprehensive standard for crystalline silica for general industry. The proposal will likely contain a 50% reduction in the permissible exposure limit (PEL) to .05 mg/m3 from .1 mg/m3 of respirable crystalline silica per cubic meter of air. The proposed standard is expected to also include medical monitoring and a host of other provisions. A substantially lower PEL will present major technological and economic challenges to the metalcasting industry. The rulemaking is driven by concern over the risks of silicosis, as well as lung cancer—which OSHA contends is significant at the existing PEL. OSHA plans to publish its proposed standard in the Federal Register in July 2010.
• Combustible Dust: OSHA is engaged in the early stages of rulemaking to develop a combustible dust standard for general industry. The agency is holding stakeholder meetings and seeking comments which are due by January 19, 2010. OSHA plans to use this information to help develop a combustible dust rule. AFS will be submitting comments.
• Walking/Working Surfaces, Subparts D & I: This proposed standard will update OSHA’s rules covering slip, trip and fall hazards and establish requirements for personal fall protection systems. The rule affects all manufacturing facilities. The proposal will be issued in March 2010.
• Global Harmonization System (GHS) of Classification and Labeling of Chemicals: OSHA is revising its Hazard Communication Standard to make it consistent with the GHS. The new standard will include more specific requirements for hazard classification, as well as standardized label components which will provide consistent information and definitions for hazardous chemicals and a standard approach to conveying information on material safety data sheets. OSHA is preparing for hearings in March 2010. AFS submitted comments in January.
• Beryllium – OSHA is developing a rule to update the permissible exposure limit and establish additional provisions. The agency intends to initiate a peer review of health effects and risk assessment in March 2010.

For more information, contact Stephanie Salmon, Metalcasters Alliance for Government Affairs Washington Office, at ss@wafed.com or 202/842-4864.