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Stephanie Salmon, AFS Washington Office; Jeff Hannapel & Christian Richter, The Policy Group, Washington, D.C.

ate effectiveness of control plan at least annually and as neces- sary. Te control plan must be available for examination, upon request, to each employee covered by this section, their designated representatives, the Assistant Secretary and OSHA Director.

Regulated Areas Companies are required to estab-

lish a regulated area to limit access to areas where exposure to silica exceeds the PEL. Employers must mark off regulated areas, and limit access to regulated areas to persons authorized by the employer and required by work duties to be present in the regulated area, persons observing exposure monitoring, or any person authorized by the OSH Act or regulations issued under it to be in a regulated area. Employers are required to provide each employee and the employee’s designated representative entering a regulated area with an appropriate respirator and require its use while in the regulated area.

Signage for Regulated Areas Employers must post signs with

mandatory language at all entrances to regulated areas:


House Bill Looks to Provide More Time for States to Comply With New EPA Ozone Standards

A group of lawmakers recently introduced legislation, the Ozone Stan- dards Implementation Act of 2016 (H.R. 4775), to give states more time and flex- ibility to comply with the Environmental Protection Agency’s (EPA) revised ground-level ozone standards which were released in October 2015. H.R. 4775 would phase-in imple- mentation of the 2008 and 2015 ozone standards, while extending to 2025 the date for final designation of the 2015 standard. The bill also would change the mandatory review of National Ambient Air Quality Standards (NAAQS) from five to 10 years, authorize the EPA administrator to consider technological feasibility as a secondary consideration

when revising NAAQS, and direct EPA to submit a report to Congress within two years regarding the impacts of foreign emissions on NAAQS compliance and related matters.

OSHA Raises Fines for Failing to Report Serious Injuries

In March, the Occupation Safety and Health Administration (OSHA) issued a revised enforcement procedures document which serves as enforcement guidance for compliance officers when issuing citations to employers for failing to report severe workplace injuries (fatality, inpatient hospi- talization, amputation, or loss of an eye). The key revisions to the enforcement procedures include increased penalties for failure to report and monitoring inspec- tions of closed Rapid Response Inspec- tions (RRIs). Manufacturers, including

metalcasting facilities, are required to report to OSHA all inpatient hospitaliza- tion, amputations, and loss of an eye within 24 hours of the work-related incident. Fatalities must be reported within eight hours. Failing to report will now result in a penalty of $5,000-$7,000. Previously it was $1,000.

Second, after an employer has re- ported an event, OSHA makes a decision based on the type of incident whether to conduct an on-site inspection or have an employer fill out paperwork and send back to OSHA.

The revised procedures provide for monitoring inspections of closed RRIs on a “randomized selection” of investigations.

For additional information, contact Stephanie Salmon, AFS Washington Off ice,

202/842-4864, April 2016 MODERN CASTING | 15





Medical Surveillance Medical surveillance must be made

available to employees exposed to silica at or above the PEL for 30 or more days per year, effective June 23, 2018; and to employees exposed to silica at or above the action level for 30 or more days per year, effective June 23, 2020. Examination includes x-ray and pulmonary function tests every three years and initial TB test. Employer shall provide examining health care provider with: • Copy of standard. • Description of duties. • Silica exposure levels. • PPE used. • Results of previous medical test under control of employer.

Written Medical Opinion

Te rule limits information provid- ed to employer to date of examination, a statement that the examination has


met the requirements of the standard, and any recommended limitations on the employee’s use of respirators. Te health provider will provide a detailed report for the employee. Sample forms and reports are included in a non-mandatory Appendix B. If a medical opinion indicates additional examination by a specialist the exam must be completed within 30 days.

Recordkeeping: Air Monitoring Data

Companies must make and maintain record of all exposure mea- surements taken to assess employee exposure to respirable silica. Te record must include: • Date of measurement for each sample taken.

• Task monitored. • Sampling and analytical methods used.

• Number, duration and results of samples taken.

• Identity of laboratory that per- formed the analysis.

• Type of PPE, such as respirators, worn by the employees monitored.

• Name, social security number and job classification of all employees represented by the monitoring, indicating which employees were actually monitored.

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