Proposed Standard Modified To Reduce
Impact on Small Businesses
| Change to Proposed Regulation | Impact on Small Businesses |
Compliance Schedules:
< 20 employees:
- initial monitoring: 300 days
- engineering controls: 3 years
- all other provisions: 1 year
Foam manufacturers 20-99 employees:
- initial monitoring: 210 days
- engineering controls: 2 years
- all other provisions: 270 days
All other employers:
- initial monitoring: 120 days
- engineering controls: 1 year
- all other provisions: 180 days
|
More performance oriented and flexible, reduces costs to
small businesses in first two years by 30 to 40 %, allows
small businesses time to plan major
expenditures. Specifically addresses Small Business
Administration concerns for foam
manufacturers with fewer than 100 employees. |
| Allows the use of licenced health care professionals in
addition to physicians for medical
surveillance |
Provides greater flexibility |
| Laboratory tests are at the discretion of physician
rather than automatically required |
Reduces costs, more performance oriented |
| Employees under 45 are required to have a physical every
three years rather than annually |
Reduces costs of medical
surveillance 30 percent |
| Respirators required in regulated areas only when
PEL is likely to be exceeded |
Decreases
respirator use and costs for small business |
| If MC is used less than 30 days per year,
monitoring may be conducted with direct reading
instruments |
Significantly reduces costs of monitoring for establishments
making limited use of
MC; this provision will be especially helpful in construction |
| Written Compliance Plans are no longer required |
Reduces paperwork |
| Hazard communication requirements do
not go beyond what is already required by hazard
communication standard |
Reduces paperwork and costs |
| Employee training only as needed rather than annually;
training requirements have been
simplified and most training and information requirements
only apply to employers with
employees exposed to MC above the AL |
More performance oriented, reduces costs of
training 80 percent |
| Simplified exposure monitoring recordkeeping
requirements for small businesses |
Reduces
paperwork |
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