NACOSH Recommendations to the Secretaries of Labor and Health and Human
Services

December 14-15, 2011

Silica Rulemaking

NACOSH strongly supports OSHA’s efforts to update its standard on
occupational exposure to silica.  The current standard is many decades
old and is insufficient to protect workers from this serious
occupational health hazard.

NACOSH is deeply distressed that the proposed silica standard has now
been held by OMB for review for more than 10 months, far longer than the
4.5 month review period provided for in Executive Order 12866.  The
silica rule delay is extraordinary and without explanation, and there is
no indication as to when the review will be concluded.

Further, it has been 14 years since OSHA initiated the silica
rulemaking, and eight years since the small business panel completed its
review of the draft silica rule under the Small Business Regulatory
Enforcement Fairness Act [SBREFA], and a proposed rule has yet to be
issued.

Therefore, NACOSH urges the Secretary of Labor and OSHA to enhance their
efforts to get OMB to finish its review, and issue the proposed silica
rule without further delay, so that the public hearings and comment
period can commence, and a final silica standard issued to protect
workers from this serious workplace hazard.

Current Status:

NPRM:  February 2012

Transition from Standard Industrial Classifications (SIC) to North
American Industry Classification System (NAICS)

NACOSH supports OSHA’s efforts to transition from use of SIC
designations to NAICS.  Now that the comment period for the proposed
rule has closed, NACSOH encourages OSHA to complete a final rule in 2012
so that changes can become effective for reporting in 2013.

Current Status

The Docket for the NAICS update and reporting revisions notice of
proposed rulemaking (RIN 1218-AC50) closed October 28, 2011.  OSHA has
completed review of the approximately 100 public comments submitted to
the docket and is in the process of writing the final rule.  OSHA
expects to publish the final rule by June 2012 with an implementation
date of January 2013.

Injury and Illness Prevention Program Rulemaking

NACOSH recommends that OSHA keep the Injury Illness Prevention Program
proposed rule as the highest priority on its regulatory agenda.  NACOSH
continues to be concerned and disappointed that the June/July 2011
timeline for initiation of the SBREFA process set forth by OSHA for the
Injury Illness Prevention Program proposed rule at the June 2011 NACOSH
meeting has not been met and that there has been no apparent progress on
this rule.

Current Status:

SBREFA Panel in January 2012.

Injury and Illness Prevention Program Symposium

Consistent with our recommendations from the February 14, 2011 and June
22, 2011 meetings, NACOSH recommends that OSHA, NIOSH and other
appropriate parties support and fund a symposium in 2012 to present best
practices of small, medium and large workplaces on injury and illness
prevention programs.  This symposium would demonstrate the value of
health and safety programs while working to share best practices from
companies representing a broad cross section of size and industry.  In
order to achieve this important outcome, NACOSH recommends that:

OSHA and NIOSH support and fund a national symposium led by OSHA, NIOSH
and other interested organizations.

OSHA and NIOSH convene a planning group to develop a schedule, work
plan, target audience and budget for a national symposium.

OSHA and NIOSH also explore additional methods to achieve the goal of
outreach to participation from the broader community of health and
safety professionals about effective health and safety programs (for
example, a series of regional conferences).

Current Status:

OAS Decision

