Summary: A change in the interpretation of the word ‘FEASIBLE’ by OSHA could cause all shop owners whose shops noise level exceeds 85 dB to be REQUIRED by OSHA under this new definition to install expensive engineering or administrative controls to abate the noise to levels below the action level. PPE could no longer be acceptable as the sole means of addressing noise exposure in our shops.
Action You Need to Take:
1) Determine the noise level in your shop to see if it exceeds 85dB TWA.
2) Determine cost to install noise guarding on machines necessary to abate noise levels to below 85dB (engineering control)
3) Determine how many machines must be taken out of service at a time to prevent the noise level from exceeding the 85dB level ( administrative control )
4) Perform a business case analysis to see if your company can remain in business if this change to the definition becomes law, requiring you to purchase sound dampening or reduce production.
5) Document the cost to comply, loss of jobs, and any reduction in competitiveness, capacity or other issue that is a result.
6) Send to Miles Free firstname.lastname@example.org so that I can include in PMPA’s formal comments.
7) Send a letter to the Docket for comments on this proposed change in interpretation as well as one to your congressman and please copy PMPA.
Submit comments at http://www.regulations.gov. Individuals who mail or deliver comments must submit three copies to the OSHA Docket Office, Docket No. OSHA-2010-0032, U.S. Department of Labor, Room N-2625, 200 Constitution Ave., N.W., Washington, D.C. 20210. Submissions not longer than 10 pages may be faxed to 202-693-1648
PMPA and other metalworking associations requested, and received an extension on the Comments deadline so that we could obtain facts needed to properly assess the consequences of this new interpretation. Comments are now due by March 21, 2011. We need your facts to make our case!
We need your data now to effectively represent you on this potentially shop closing issue.
All data that we have seen from Member shops so far has shown that these shops will need to add sound dampening equipment.
Links: Extension letter:
Notice of Proposed Reinterpretation:
PMPA Extension Request Letter:
The shop (and machininst jobs) you save may be your own.