Stephanie Salmon, AFS Washington Office; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C. WASHINGTON ALERT
OSHA Examining Revisions to Electronic Reporting Rule
COMMENT PERIOD ON THE INJURY AND ILLNESS REPORTING RULE HAS BEEN EXTENDED.
In August, the U.S. Occupational Safety and Health Administration (OSHA) announced it is looking at revising its controversial electronic recordkeeping proposed rule it released in No- vember 2013. Specifically, OSHA would like inter- ested parties to comment on whether the agency should potentially bolster requirements that employers inform their employees of their right to report injuries and illnesses, as well as strengthen whistleblower protec- tions. The additional changes are in response to some concerns that the
ON THE HILL
New EPA Ozone Regulations Could Be Costliest in U.S. History According to NAM Study
A recent report released by the National Association of Manufacturers (NAM) indicates the impact of lowering the current National Ambient Air Quality Standard (NAAQS) for ground-level ozone could end up being the costliest regulation in U.S. history, with compli- ance costs adding up to $270 billion per year and a total bill of $3.4 trillion over the next 25 years. The study, conducted by the National Economic Research Associa- tion (NERA), assessed the potential consequences of reducing the existing ozone standard from 75 parts per bil- lion (ppb) to 60 ppb, as called for by a number of public interest groups. Ac- cording to NERA, meeting a standard of 60 ppb would leave nearly all of the U.S. in a so-called “nonattainment zone.” Manufacturers, including metalcasting facilities of all sizes, in nonattainment areas would not be able to make invest- ments and expand operations without
other businesses reducing their emissions or closing their operations.
The U.S. Environmental Protection Agency (EPA) has until December 1 to decide whether to keep or change current national air quality standards for ozone. EPA’s previous attempt to promulgate a lower ozone air quality standard was delayed by President Obama in 2011.
AFS Submits Post-Hearing on OSHA’s Proposed Silica Standard
In August, as part of the U.S. Occupa- tional Safety and Health Administration’s (OSHA) rulemaking process governing its proposed standard on occupational exposure to respirable crystalline silica, AFS submitted a post-hearing brief. With the docket closing, this is the as- sociation’s final document which further substantiates the industry’s positions on the silica rulemaking.
OSHA formally unveiled in September 2013 a comprehensive and complicated regulation to control crystalline silica. It is one of the safety agency’s farthest-reach- ing regulatory initiatives ever proposed for
the metalcasting industry and a number of other key sectors. In addition to the 50% reduction in the permissible exposure limit (PEL), OSHA is proposing requirements including, but not limited to, medical surveil- lance, record keeping and prohibitions on certain work practices, including com- pressed air and dry sweeping.
AFS argues the current PEL is adequate to protect the health of exposed workers from silica-related disease when it is fully complied with and enforced. OSHA esti- mates the rule will result in approximately $44 million in annual costs to the industry. This stands in sharp contrast to industry analyses whereby AFS estimates a con- servative cost to the industry of $2.2 billion per year or 276% of profits. OSHA expects to issue a final rulemaking by 2016. For copies of any of the materials AFS submitted to OSHA, contact Stephanie Salmon in the AFS Washington office a
ssalmon@afsinc.org or visit
www.afsinc. org/silica.
For additional information, contact Stephanie Salmon, AFS Washington Off ice,
202-842-4864,
ssalmon@afsinc.org. September 2014 MODERN CASTING | 19
proposed electronic posting of injury and illness information on OSHA’s website might lead employers to retaliate against employees who re- port injuries and illnesses. OSHA is extending the comment period on its proposed electronic-reporting rule
until October 14. In November 2013, OSHA published a proposed rule that would amend the agency’s current recordkeep- ing regulations to require 38,000 establishments with more than 250 employees to electronically submit the records to OSHA on a quar- terly basis. Te 440,000 U.S. companies with more than 20 employees but fewer than
250 that are in certain industries with high injury and illness rates, likely to include a large number of metalcast- ing facilities, would be required to electronically submit their records to OSHA once a year.
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