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| > | Safety Overview | > | HSPP Overview | > | Communications |
OSHA's Letter to NAIMA
|
U.S. Department of Labor |
Assistant Secretary for |
 |
|
May 18, 1999
Mr. Kenneth Mentzer
Executive Vice President
North American Insulation Manufacturers Association
44 Canal Center Plaza
Suite 310
Alexandria, VA 22314
Dear Mr. Mentzer:
On behalf of OSHA, I am pleased to express our support for the "Health and Safety Partnership Program" (HSPP) developed by NAIMA to help protect employees involved in manufacturing, installing, and removing products containing synthetic vitreous fibers (SVF). Workers in all segments of the industry can benefit from NAIMA’s commitment to work with the users of SVF products and employees of the SVF industry. OSHA will review the progress of NAIMA’s HSPP in reducing employee exposures and promoting safer products and work practices, and will help pass on information about the benefits of this partnership both for this industry and as a possible model for future collaborative efforts of this type.
OSHA believes that the many specific commitments NAIMA and the users of its products have made in developing this Program together form an important step towards further improving worker protection. The 1 fiber/cc exposure level recommended in the Program, the specific engineering controls and work practices detailed in the Program, and the recognition that respiratory protection is appropriate in certain operations will help reduce exposures of the workers who handle SVF products daily. We are particularly impressed that the Program allocates responsibilities to both the manufacturers and the users of SVF materials, appropriate to their ability to efficiently reduce worker risks. I commend NAIMA and its member companies, along with the two major user groups (the Insulation Contractors Association of America and the National Insulation Association) who have agreed to their own programs modeled upon the HSPP, for the substantial effort involved in protecting workers. The documents NAIMA has presented to me show a great deal of creative thought and innovation, which OSHA acknowledges and appreciates.
Moreover, many of the provisions in the HSPP demonstrate NAIMA’s and the major user groups’ determination to offer the best possible protections for workers. In particular, I point to the acknowledgement that "where worker exposures can readily be reduced to below 1 fiber/cc, NAIMA recognizes that it is prudent to do so" and the provision that where exposures are currently below the voluntary 1 fiber/cc time-weighted average, "NAIMA's member companies are committed to maintaining those exposures and preventing increased exposure in the workplace."
Although the success of the HSPP cannot be evaluated until the progress reports specified in the Program are reviewed, the actions the manufacturers and users have committed to take help address the concerns that led to OSHA’s identifying SVF as a high priority for action in its 1995 Priority Planning Process. OSHA and its stakeholders added SVF to the 1995 list because of concern about the breadth and magnitude of worker exposures. The HSPP holds great promise for reducing those exposures and increasing the use of effective control measures.
OSHA does not, at this time, consider SVF a regulatory priority. We will not list it on our regulatory agenda for action. We will, however, continue to monitor developments in the scientific literature, the recommendations of expert bodies, and the effectiveness of the Program and will periodically review our approach to SVF based on this information. We also intend to work with the participants in the HSPP towards continuous improvement in the safe handling of SVF products, commensurate with the best available scientific information on the potential hazards thereof. In this regard, we commend the manufacturers’ commitment to explore reformulation of SVF products, and look forward to technical discussions involving NAIMA companies and the broader scientific community so that OSHA can better understand the merits of this action.
OSHA retains all of its pre-existing enforcement authorities, as is noted in the HSPP. In addition, the Program provides new actions on the part of manufacturers and users that OSHA expects will be taken. It is my hope that implementing the HSPP will conserve OSHA’s regulatory and compliance resources, and that the periodic reports will demonstrate that companies can readily fulfill the provisions of the Program. It is with this optimism and gratitude for your efforts that OSHA salutes this ambitious worker protection effort.
Sincerely yours,
Charles N. Jeffress
Assistant Secretary
cc: Angus Crane, NAIMA