INGAA believes that OSHA’s current silica standard adequately addresses silica exposure and protects employees in the natural gas transmission industry. OSHA’s proposed standard, however, is unrealistic and imposes an unreasonable burden on the transmission industry. The proposed standard is economically unreasonable, technically infeasible and unnecessary with regard to the transmission industry.
To ensure that the current silica standard adequately protects employees in the natural gas transmission industry, INGAA conducted a survey of our member companies. A significant majority of our members responded. The survey questions were:
1) Over the last ten years, have you had any OSHA recordable illnesses related to silica exposure, such as silicosis?
Response: Every member who responded to the survey responded: No.
2) Over the last ten years, have you had any workers’ compensation matters related to silica exposure, such as silicosis?
Response: Every member who responded to the survey responded: No.
3) While performing operations where there is a risk of silica exposure, such as sandblasting, do you require your employees to utilize PPE, such as compliant respirators?
Response: Every member who responded to the survey responded: Yes.
The survey results demonstrate several key points. First, INGAA’s members operate in compliance with the current silica standard. Second, the current silica standard adequately protects employees in the natural gas transmission industry against silica-related illnesses. Third, the current standard is effective, in part, because the exposure level in this industry is relatively minimal.
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