OSHA’s proposed rule to control workplace exposure to respirable crystalline silica makes excessive demands on small companies. This was the message delivered to OSHA by the leadership of ACMA’s Government Affairs Committee in a December 4 meeting.

ACMA believes OSHA’s proposed requirement for all workplaces with potential silica exposures to conduct employee exposure testing does not recognize the practical, financial and technical difficulties this would present to small manufacturers. The proposed requirement for employers to install engineering control to reduce exposures to OSHA’s proposed permissible exposure level is also a feasibility problem for smaller companies.

Under an alternative approach proposed by ACMA, small companies could use exposure factors developed for typical industry operating scenarios, such as mixing and molded product finishing. The exposure factors would lead to certain pre-determined controls, such as powered ventilation and wet-system cutting.

Companies qualifying for this option would not need to conduct uncertain and expensive exposure tests, and would not have to install engineering controls that may or may not be sufficient to meet OSHA’s exposure limit. All composites manufacturers would have the option of complying with the final OSHA rule if they wished.

In the December 4 meeting, OSHA management expressed a willingness to consider ACMA’s proposal. The GAC will proceed to develop a plan for testing silica exposures and developing control options for common composites industry operations.