Yesterday, the NAM filed its comments in response to the Occupational Health and Safety Administration’s (OSHA) proposed rule, which would cut the permissible exposure limit (PEL) to respirable crystalline silica (or sand) in half from its current level. To breakdown what this means is if you took a basic sugar packet and then dispersed it into a building that is the length of a football field and 13 feet high—this would be the amount of sand we are talking about.
Particularly noteworthy in this rulemaking is that OSHA has been working on the rule for well over a decade, starting back in 2003 with the Small Business Review Panel, and then using data points from the 2002-2007 timeframe to justify OSHA’s cost analysis. It is, therefore no wonder OSHA’s cost estimate of $656 million and industry’s of $5 billion are so far apart. Yet, OSHA gave the public only 157 days to read and analyze well over 1,500 pages and gain an understanding of whether a lower PEL and implementing engineering controls were even feasible for companies who work with silica every day.
One thing is for sure, the NAM has serious concerns with lowering the current PEL and what that will mean for manufacturers and questions whether the rule is necessary, the methodologies relied upon are valid and process has been fair.
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