ISHN Guest BlogNot quite sure who lit the fire at OSHA but the level of activity at the agency in the last two months is more activity than we have seen in the last several years combined. Now the question is likely to be whether or not any of this activity will result in completed actions. Here’s a look at the current activity:


The OSHA proposed silica rule is receiving a considerable amount of discussion. The proposed rule that would lower the silica exposure level was proposed on September 12.

Following the announcement, OSHA received numerous requests to extend the comment period for 90 days. OSHA agreed to extend the deadlines for 47 days.

The new deadlines:

Comments Due at OSHA January 27, 2014
Hearings Begin March 18, 2014

Outlook: Don’t be surprised if there is a major push to finalize a silica rule in 2014. Word is that this is one issue that Dr. Michaels would really like to finalize

as soon as possible. However, there will be plenty of opposition to the proposed rule so be prepared for fireworks.


OSHA is also moving forward on a proposed rule on recordkeeping. The proposal was announced on November 7 and involves a move to “electronic submission” of injury and illness rates. Employers with more than 250 employees would be required to submit reports quarterly and employers with more than 20 employees would be required to submit reports on an annual basis.

OSHA makes it clear that the agency is not requiring employers to keep track of any new data than is currently required. OSHA also says one purpose of the rule is to make it easier for employers to compare their injury and illness data to other employers as all data would be available on the OSHA web site.

The deadlines:

Deadline for Notice of Intent to Appear at Meetings January 3, 2014
Meetings Begin January 9, 2014
Comments Due at OSHA February 6, 2014

Outlook: There is much more opposition to this proposed rule than one would think. Some in industry are afraid the information will be used against them if it is made public. While OSHA hopes to move forward rather quickly, don’t be surprised if this rulemaking drags on for some time.

Chemical Safety

OSHA announced a request for information (RFI) seeking public comments on potential revisions to its Process Safety Management standard and related standards on December 3. The purpose of this RFI is to seek ways to improve chemical facility safety and security following the April explosion in West, Texas that killed 15. The agency asks for information and data on specific rulemaking and policy options and the workplace hazards they address. OSHA will then determine what actions, if any, it may take.

Comments on the RFI are due at OSHA March 10, 2014.

Protecting Temporary Workers

OSHA launched an initiative on protecting temporary workers on April 29. OSHA has now drafted a document (November) for Best Practices for Protecting Temporary Workers. AIHA was given an opportunity to review the document and provide input.

AIHA supported the document and provided a few recommendations.