• Providing respirators to workers when dust controls cannot limit exposures to the PEL.
• Offering medical exams, includ- ing chest X-rays and lung function tests, every three years for workers exposed above the PEL for 30 or more days each year.
• Keeping records of workers’ silica exposure and medical exams. Based on industry input, OSHA
has made some adjustments to the language of the standard in the last couple of years, including basing the
standard on current sampling tech- nology so a new method or procedure will not have to be tested, vetted and learned. Additionally, OSHA agreed to begin medical surveillance of PEL after 30 days, every three years, avoid- ing unnecessary testing costs on indi- viduals who do not remain employed at a plant for more than a month. Following the public hearing held
this March, participants who filed notice of intent to appear, including AFS, have the opportunity to file post- hearing submissions. Additional rel-
evant information and data were due June 3 and final briefs, arguments and summations will be accepted through July 18. AFS is in the process of put- ting together responses to questions from OSHA and final arguments/ briefs to meet the deadline. For the rest of this year and into
2014, OSHA is expected to review and evaluate the written comments, hearing transcripts and post-hearing briefs. During this time, the agency will determine if changes are necessary and can make revisions to the text of
June 2014 MODERN CASTING | 23
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