In a letter to Rep. George Miller, D-Calif., Chairman of the Committee on Education and Labor, the American Industrial Hygiene Association (AIHA) has expressed concern that OSHA’s Combustible Dust National Emphasis Program (NEP), reissued March 11, does not go far enough in addressing the danger of combustible dust exposure.

Legislation introduced by Miller and Rep. John Barrow, D-Ga., H.R. 5522, Combustible Dust Explosion and Fire Prevention Act, would direct OSHA to issue an interim standard regulating combustible dusts and a final standard not later than 18 months after enactment of the bill.

In the April 4 letter, Donald J. Hart, Ph.D., CIH, AIHA President, acknowledged that AIHA supports HR 5522 and that the reissued NEP will increase enforcement activities as well as focus on specific industry groups that have experienced frequent combustible dust incidents. However, AIHA believes there is need for further action from OSHA.

Specifically, the association has two comments on the bill it hopes the committee will consider:

• Under Section 3, (2) Requirements, AIHA would like to see an additional requirement added: “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 that when considering this legislation the committee determines 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,” the letter said.

The letter continued: “It is our hope that HR 5522 will be the starting point for further debate and action on combustible dust. We support HR 5522 and your efforts.”