Update on Standards and Guidance

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Update on Standards and Guidance

• OSHAs Regulatory Agenda and Guidance Projects

Dorothy Dougherty, Acting Director Directorate of
Standards and Guidance
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THE REGULATORY PROCESS
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Analytical Requirements

• Significant risk determination.
• Technological feasibility.
• Economic feasibility/cost effectiveness
• Information collection requirements under the
  Paperwork Reduction Act.
• Where there is impact on significant number of
  small businesses, Small Business Regulatory
  Enforcement Fairness Act (SBREFA) panel.
• Peer review requirements.

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Regulatory Agenda

• DSG has about 20 regulatory projects.
• Current regulatory agenda was published on
  4/24/2006.
• Can be accessed through OSHAs web page under the
  unified agenda.

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Hexavalent Chromium

• Previous standard dated to 1971 and was based on
  controlling irritation and damage to nasal
  tissues.
• Final rule published
  February 28 2006.
• Separate standards for
  general industry,
  construction, maritime

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Assigned Protection Factors

• Amendment to the Respiratory Protection Standard.
• Adds protection factors for classes of
  respirators to indicate the expected level of
  protection.
• Final rule has been prepared and is in the review
  process. Expect to publish later this year.

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Final Rules Safety

• Subpart S General Industry Electrical
• Consensus Standards
• Vertical Tandem Lifts
• Subpart V Construction Electric Power
  Generation and Distribution

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Subpart V

• OSHA has two standards covering electric power
  work.
• Subpart V of Part 1926 covering construction.
• 1910.269 covering general industry maintenance.
• Employees suffer 74 fatalities and 444 injuries
  annually.
• Proposal would reduce fatalities and injuries by
  25 percent.

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Subpart V

• Proposal published June 2005
• Public hearing March 2006
• Posthearing comment dates
• May 15additional data and evidence due
• July 14comments and briefs due

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Consensus Standards

• More than 200 consensus standards are used in
  about 500 OSHA provisions
• Nearly all 200 are out of date
• OSHA Rulemaking cannot keep pace with updates

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How OSHA Uses Consensus Standards

• Basis - of an OSHA standard extracting wording
• Citing - as a reference - to indicate an
  acceptable means to meet a performance-language
  requirement
• Incorporating by reference - citing the name,
  year, and part/section of the consensus standard
• Notes or Appendices - for additional information
  or compliance assistance

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Proposed Rules

• Crystalline Silica
• Beryllium
• Explosives
• General Working Conditions in Shipyards

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RFIs and ANPRs

• Hazard Communication/Globally Harmonized System
• SIPS III
• Emergency Response and Preparedness
• Ionizing Radiation

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Emergency Response/Preparedness

• OSHAs jurisdiction is limited, but its standards
  are used by state and local authorities.
• Experience in preparing guidance.
• Publishing request for information to solicit
  input on whether rulemaking should be done, and
  what form it should take. Issues related to PPE,
  training, medical surveillance.

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Hazard Communication

• Considering adoption of the Globally Harmonized
  System of Classification and Labeling of
  Chemicals (GHS).
• Added to the new regulatory agenda, with the next
  step being an advance notice of proposed
  rulemaking (ANPR).
• ANPR is currently being reviewed by OMB.

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Motor Vehicle Safety Guidance

• Recently published guidance on motor vehicle
  safety.
• Joint project with NHTSA, NETS and OSHA to
  address motor vehicle injuries and fatalities.

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Current Guidance Projects

• Chrome VI outreach
• Hazards of Scrap Metal Recycling
• Hazard Communication/GHS
• PPE for Emergency Response
• Silica Exposure in Construction

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Current Guidance Projects

• Ergonomics in Shipyards
• Slings
• Electrical Safety
• Motor Vehicle Safety in Marine Terminals
• Fire Service Manual

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Emerging Issues

• Control Banding
• Co-sponsor international workshop
• Participated in national workshop
• Nanotechnology
• National Nanotechnology Initiative
• Best practices
• Methamphetamine Laboratories
• Researching potential hazards to first responders
  and private-sector clean-up workers

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Clandestine Drug Labs
Courtesy DEA
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Courtesy DEA
Fast growing national problem 1999 - 7,400 meth
lab raids nationwide  2004 - 17,000 meth labs
identified nationwide
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Clandestine lab habitat

• Rental properties
• Farmhouses
• Apartments
• Hotels
• Motels
• Self storage units
• Vehicles

Courtesy DEA
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Individuals at Risk

• Lab operators
• First responders/EMT/Hazmat
• Cleanup crews
• Neighbors
• Residents in same building

Courtesy DEA
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Potential Exposure Hazards

• Strong Acids and Bases
• Ammonia
• Solvents
• Lead
• Mercury
• Methamphetamine

Courtesy DEA
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Avian/Pandemic Flu

• Guidance on Avian Flu -- Laboratory workers --
  Healthcare workers -- Food handlers -- Workers
  stationed abroad
• -- Poultry workers and animal handlers
• Participating on workgroup to develop guidance
  for pandemic flu

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Conclusion

• A new regulatory agenda was published on
  4/24/2006. It provides the goals for completing
  the various steps of each project.
• Rulemaking is an iterative and deliberative
  process. It includes many checks and balances to
  ensure the Agency is basing its decisions on the
  best available evidence.
• Guidance is an additional tool to provide
  information to help address safety and health
  issues.