Countdown To Compliance Under OSHA’s Final Silica Rule: Best Practices For Developing A Written Exposure Control Plan
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Under OSHA’s final silica rule, which was finalized on March 24, 2016, there are many significant changes to exposure limits and additional requirements for training, respiratory protection, written plans, monitoring, and record-keeping. Companies affected by the new regulations will therefore need to make significant changes in existing programs once they go into effect.
According to some industry experts, certain components of the rule may still be economically infeasible, especially for small companies.
Many stakeholders have already noted that there is a scarcity of accredited laboratories for testing elements of the rule, raising concerns over technological feasibility.
Additionally, determining what kinds of engineering and work place controls will best achieve compliance initially will be tricky. OSHA will likely try to implement specific controls after publication of the final rule, under the guise of future memorandums or letters of interpretation and argue that, under Chevron deference, their word is final. The burden would then shift to the employer to prove infeasibility.
At this point, EHS managers potentially affected by the rule need to understand exactly what is required and begin developing the necessary program updates—especially training, monitoring, and preparing a compliant exposure control plan.
Join us when skilled OSHA attorney Adele Abrams will show you where to begin with your written exposure control plan to ensure cost-effective and timely compliance with OSHA’s final rule.
About the Presenter:
- Evaluate the new requirements in detail including:
- the new exposure limit for respirable crystalline silica exposure control measures
- workplace and employee monitoring
- medical surveillance
- training workers about silica-related hazards
- recordkeeping measures
- Explain to senior management what will be required as it relates to your organization
- Identify the timeline for compliance including key compliance dates, possibilities of date revisions, and ongoing rule clarification by OSHA
- Assess the role of ASTM and other organizations will play in the ongoing implementation of the regulations
- Consider strategies for compliance for all areas including written exposure control plans
- Identify the best practices to help you “get ahead of the curve”
- Interpret the impact recent silica litigation issues may have on compliance
Adele Abrams, Esq., CMSP
Law Offices of Adele L. Abrams P.C.
Adele Abrams, Esq., CMSP is recognized as a national expert on occupational safety and health. Ms. Abrams heads a ten-attorney firm that represents employers and contractors nationwide in OSHA and MSHA litigation, and provides safety and health training, auditing, and consultation services. She is a Certified Mine Safety Professional, and a Department of Labor–approved trainer. Ms. Abrams is on the adjunct faculty of Catholic University in Washington, DC, where she teaches employment and labor law.
Ms. Abrams is also a professional member of the American Society of Safety Engineers, and is co-author of several safety-related textbooks. She is chair of the National Safety Council’s Business & Industry Division committee on regulatory and legal affairs. She is admitted to the Bars of MD, DC and PA, as well as multiple federal courts including the US Supreme Court.
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|Keywords For This Course:|
Crystalline silica, ASTM role in the crystalline silica standard, Crystalline silica health issues, NIOSH and crystalline silica health issues, OSHA and the proposed crystalline silica standard
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