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IMA-NA Comments on OSHA Lock-Out/Tag-Out

Posted By Ariel Hill-Davis, Wednesday, January 4, 2017

IMA-NA recently filed comments on an OSHA proposed rule, Standards Improvement Project - Phase IV, through which OSHA ostensibly intended to "remove or revise outdated, duplicative, unnecessary and inconsistent requirements in OSHA's safety and health standards." However, some of the proposals would have made substantive changes in the standards. For instance, the proposal would remove the well-established and relied upon term "unexpected" from the lock-out/tag-out (LOTO) standard. When the LOTO standard was first adopted by OSHA in 1989 it was specifically limited to only cover "the servicing and maintenance operations in which the unexpected energization or startup of the machines or equipment, or the release of stored energy could cause injury to employees." Contrary to the intent of the Standards Improvement Project, the proposal would significantly change the meaning and scope of the LOTO standard. The comments do not suggest that OSHA could not properly delete the term "unexpected" from the LOTO standard; they maintain that to do so OSHA should engage in a formal rulemaking process and not the Standards Improvement Project.

To read IMA-NA's comments please open the attachment below.

Download File (PDF)

Tags:  comments  LOTO  osha  Regulations  rulemaking 

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Mark Ellis Featured on Heartland Institute's Silica Podcast

Posted By Ariel Hill-Davis, Tuesday, April 12, 2016

On the heels of OSHA's release of the finalized Rule on Respirable Crystalline Silica, IMA-NA and NISA's President, Mark Ellis sat down with Isaac Orr to offer insight on the rule for the Heartland Institute's Daily Podcast. Mark provided the historical context for OSHA's decision to update the rule, outlined how the rule has changed, and spoke to the impact on different industries.  Throughout the podcast Mark took the opportunity to speak to NISA's role as a leader in the industry through the proactive development of the Silicosis Prevention Program (SPP) and spoke to the ability to prevent silicosis without OSHA moving the Permissible Exposure Limit (PEL) to 50 micrograms. The Heartland Institute's podcast offered another opportunity to highlight the industrial sand industry's ongoing work to keep workers safe and healthy outside of OSHA's standard setting for crystalline silica. 

To listen to the podcast click here.

Tags:  IMA-NA  news  NISA  osha  regulations  silica 

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WEBINAR: Mining & EHS - A Compliance Case Study

Posted By Ariel Hill-Davis, Monday, March 28, 2016

Are you benchmarking IT systems for your Environmental, Health & Safety (EH&S) and Sustainability Management programs? Join us for our webinar, Mining & EHS - A Compliance Case Study, on Wednesday March 30, at 2:00 EST. Led by our Associate Member Gensuite, this webinar will feature an integrated suite of award-winning, cloud-based Web applications for compliance, operational excellence, and risk management.  Learn how to improve your EHS programs by utilizing some of the tools on the market including: intuitive interfaces, real-time data analytics and Mobile capabilities. 

The webinar will use a case study to feature EHS compliance best practices of a leading silica mining and manufacturing company. Gensuite will share practical insights into how your peers in the mining and related industries are addressing MSHA and OSHA requirements, driving accountability throughout the enterprise, and improving compliance performance through the use of web-based systems with a suite of fully-integrated and mobile-enabled compliance and risk management tools. Learn how companies such as U.S. Silica, PotashCorp, Ingersoll Rand, and General Electric are engaging employees at all levels of the organization in driving EHS performance improvements and operational efficiencies.

Click here to register

Tags:  associate member  compliance  EHS  Gensuite  msha  osha  silica  technology  webinar 

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Upcoming Webinars: OSHA Weight of Evidence Guidance and Mining & EHS - A Case Study

Posted By Ariel Hill-Davis, Wednesday, March 23, 2016

Over the next week IMA-NA would like to encourage you to participate in three webinars offering insight into various aspects of the mining industry. In addition to the two webinars IMA-NA is hosting: Friday's OSHA Weight of Evidence Guidance and next Wednesday's Mining & EHS - A Case Study, the Association is co-sponsoring the Minerals Sciences & Information Coalition's webinar: Underpinning Innovation: The Science and Supply of America's Critical Minerals and Materials. These three webinars handle both practical topics for running your operations as well as educational topics, such as, the importance of federal investment in the U.S. Geological Survey.  Below you will find brief descriptions of each webinar as well as links to register.

 

Webinar Title: OSHA Weight of Evidence Guidance

Date/Time: Friday March 25, 2:00 EST

Click here to register 

OSHA’s new guidance on how to apply the Weight of Evidence approach for assessing complex scientific studies under its GHS HazCom rule is open for comment until May 2, 2016, and will impact IMA-NA members who must prepare Safety Data Sheets and warning labels for their products. The "weight of evidence" approach is intended to assist both manufacturers and employers in evaluating scientific studies on the potential health hazards of a chemical and determine what information must be disclosed. Attorneys Adele Abrams CMSP and Brian Yellin CIH of the Law Office of Adele L Abrams PC will present the legal and technical information you need to weigh in on this important subject.  

 

Webinar Title: Underpinning Innovation: The Science and Supply of America's Critical Minerals and Materials

Date/Time: Wednesday March 30, 1:00 EST

Click here to register

Minerals are a part of almost every product we use on a daily basis, either as the raw materials for manufacturing processes or as the end products themselves. Advanced technologies for communications, clean energy, medical devices, and national security rely on raw materials from mines throughout the world. In 2010, China curtailed exports of rare earth metals and sparked major concern about the security of global supply chains for a range of vital minerals and materials. This webinar is based on a Congressional briefing organized by AGI on behalf of the Mineral Science & Information Coalition (3 March 2016). The webinar will address the efforts being taken at the federal level to ensure a steady supply of critical minerals and materials.

 

Webinar Title: Mining & EHS - A Case Study

Date/Time: Wednesday March 30, 2:00 EST

Click here to register

Join us for a webinar where we will feature EHS compliance best practices of a leading silica mining and manufacturing company. Gensuite will share practical insights into how your peers in the mining and related industries are addressing MSHA and OSHA requirements, driving accountability throughout the enterprise, and improving compliance performance through the use of web-based systems with a suite of fully-integrated and mobile-enabled compliance and risk management tools. Learn how companies such as U.S. Silica, PotashCorp, Ingersoll Rand, and General Electric are engaging employees at all levels of the organization in driving EHS performance improvements and operational efficiencies.

 

Tags:  Associate Member  case study  compliance  EHS  industrial minerals industry  minerals science  msic  OSHA  regulations  usgs  webinars 

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WEBINAR: Mining & EHS - A Compliance Case Study

Posted By Ariel Hill-Davis, Wednesday, March 9, 2016

Please register for Mining & EHS - A Compliance Case Study on March 30, 2016 2:00 PM EST by clicking here. 

As technologies are improved and adapted for use in different sectors, more tools become available for the mining industry to continuously improve EHS at their operations. IMA-NA members are already industry leaders in Safety & Health, but its the desire to constantly improves that keeps us ahead of the rest of the industry. Aside from creating safe and healthy work environments, our members need to comply with what seem to be ever changing requirements and focus areas from OSHA and MSHA. Against the backdrop of tightening regulations and improved technological support systems, IMA-NA is happy to announce a webinar which will demonstrate some tools available to help coordinate EHS efforts.  Led by IMA-NA Associate Member, Gensuite, we will explore an example of a web-based platform developed to make MSHA and OSHA compliance simpler.

Description:

Gensuite will share practical insights into how your peers in the mining and related industries are addressing MSHA and OSHA requirements, driving accountability throughout the enterprise, and improving compliance performance through the use of web-based systems with a suite of fully-integrated and mobile-enabled compliance and risk management tools.

Learn how companies such as U.S. Silica, PotashCorp, Ingersoll Rand, and General Electric are engaging employees at all levels of the organization in driving EHS performance improvements and operational efficiencies.

Date/Time:

Wednesday, March 30th, 2:00 EST

Click here to register

 

Tags:  Associate Member  compliance  EHS  MSHA  OSHA  technology  webinar 

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Coalition for Workplace Safety Submits Comments on OSHA's Record keeping Rule

Posted By Ariel Hill-Davis, Thursday, October 29, 2015

IMA-NA along with over 60 other associations and organizations comprise the Coalition for Workplace Safety (CWS), a coalition established to support improving workplace safety through cooperation, assistance, transparency, clarity, and accountability.  On October 27th, CWS submitted comments to the record on OSHA's Notice of Proposed Rulemaking (“NPRM”), theClarification of Employer’s Continuing Obligation to Make and Maintain an Accurate Record of Each Recordable Injury and Illness. The comments focused on OSHA's attempt to circumvent both Congressional and Judiciary authority through the rulemaking process on this issue.  OSHA's proposed rule to alter record keeping standards to impose a continuing obligation categorically ignores the six month statute of limitations on record keeping citations established by Congress in the OSH Act. Not only does this rule attempt to bypass the intent of the OSH Act as enumerated by Congress but the statute of limitations has been reinforced through the U.S. Court of Appeals in multiple decisions. The comments also highlight the punitive nature of OSHA's expansion of grounds for citation by changing the nature of injury and illness record keeping to a continuing obligation.  CWS argues that this NPRM is out of line with precedent, acts as jurisdictional overreach and demonstrates the Agency's misguided belief that more citations create safer workplaces. 

To read the comments please open the attachment. 

Download File (PDF)

Tags:  coalition  comments  CWS  health  legislation  OSHA  record keeping  regulations  safety 

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Sponsor Spotlight: Law Office of Adele L. Abrams PC

Posted By Ariel Hill-Davis, Thursday, August 6, 2015

During the lead up to the Annual Meeting, IMA-NA will take the opportunity to highlight our sponsors.  This week we are highlighting the Law Office of Adele L. Abrams PC, which is sponsoring the "Longest Putt" prize for our golf outing. The Law Office of Adele L. Abrams PC is a full service law firm, focusing on occupational and mine safety and health, employment, and environmental law. Adele and her team are no strangers to IMA-NA membership, regularly offering their legal expertise in the form of webinars and presentations at our Technology Workshop.  With offices in Maryland, West Virginia, and Colorado the team offers both consulting and legal services related to OSHA, MSHA, and the EPA. Adele herself, is not only an active member at IMA-NA but she formerly acted as the Chair for the Associate Member Section. Working with regulatory bodies, particularly the enforcement branches, is a reality of doing business but the process is often both confusing and time consuming.  Luckily IMA-NA can count on Associate members, like Adele and her team, to provide expertise and representation to simplify the processes. 

 

For more information on the Law Office of Adele L. Abrams PC and their services click here.

To register for the Annual Meeting click here

To inquire about Sponsorship opportunities please contact Ariel Hill-Davis.

Tags:  2015 annual meeting  Adele Abrams  Associate Member  msha  osha  sponsorships 

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OSHA Releases Instructions for New Hazard Communication Standard Compliance Enforcement

Posted By Ariel Hill-Davis, Tuesday, July 21, 2015

The Occupational Safety and Health Administration (OSHA) released the instructions for compliance safety and health officers to enforce the new Hazard Communication Standard (HCS) with consistency across the nation.  In 2012, OSHA revised the US Hazard Communication standard in order to bring it into alignment with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS).  The new HCS is set to be fully implemented by June 1, 2016; although various phase ins have gone into effect since late 2013.  OSHA's instructions for compliance contain a framework for enforcement during both the transition period and final implementation in 2016. Additionally, it appears as though the instructions will allow inspectors to support chemical-related enforcement under the General Duty Clause.

 

To read OSHA's press release click here

The instructions can be found on the attachment.

 Attached Files:

Tags:  chemicals  ghs  hcs  osha  standards 

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