In a letter to Rep. George Miller (D-CA), chairman of the Committee on Education and Labor, the American Industrial Hygiene Association (AIHA) expresses its support and additional recommendations regarding Miller’s bill that would direct OSHA to issue an interim and final standard regarding worker exposure to combustible dust.

The Chemical Safety and Hazard Investigation Board has recommended OSHA issue a standard designed to prevent combustible dust fires and explosions in general industry. But OSHA has not formally acted on this recommendation.

AIHA states it remains concerned the OSHA Hazard Communication Standard (HCS) inadequately addresses dust explosion hazards and fails to ensure safe work practices and guidance documents are included in MSDSs. “Because of this, AIHA believes there is an urgent need for further action from the agency to address this issue,” according to the letter. AIHA supports the mandate to direct OSHA to promulgate an interim final standard regulating combustible dusts and a final standard not later than 18 months after enactment of the legislation.

AIHA recommends “requirements for the periodic inspection and maintenance of engineering controls and equipment, recordkeeping of the results of the inspections, and correction of any problems found during the inspections within a reasonable time.”

AIHA also suggests “when considering this legislation the Committee seriously determine whether or not it is possible for OSHA to promulgate a final standard within 18 months of enactment of the legislation. While AIHA does not wish for any delay in promulgating a final standard, it may be difficult for the agency to promulgate a final standard in this length of time.”

AIHA concludes by stating: “We are also hopeful this issue is one of the first priorities for the Assistant Secretary of Labor for OSHA when an individual is confirmed for the position.”