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.

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, NACOSH encourages OSHA to complete a final rule in 2012 so that changes can become effective for reporting in 2013.

Injury and Illness Prevention Program Rulemaking

NACOSH recommends that OSHA keep the Injury and 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 and 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.

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:

  1. OSHA and NIOSH support and fund a national symposium led by OSHA, NIOSH and other interested organizations.
  2. OSHA and NIOSH convene a planning group to develop a schedule, work plan, target audience and budget for a national symposium.
  3. 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).