Paca conveyor
PACA Conveyor – Week of July 9, 2020
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1. Regulatory - Safety News
2. PACA – Building and Connecting Communities

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Regulatory - Safety News
Regulatory - Safety News
As reported by Josie Gaskey, PACA's Director of Environmental, Safety & Health.
Regulatory - Safety News
Manganese Update
We have been informing you that DEP will be proposing revised Chapter 93 Water Quality Criteria for manganese.

This package will be published in the PA Bulletin on July 25 as an official proposed rulemaking package. Virtual public hearings will be held September 8 at 6 pm, September 9 at 2 pm and September 10 at 6 pm.

DEP is proposing a 0.3 mg/l limit on manganese, the current limit 1 mg/l. Because this is a Water Quality Criteria standard, the limit must be met in all surface waters 99% of the time. This package also includes language which supports two alternative points of compliance for the proposed manganese criterion. The first alternative, consistent with Act 40, is to move the point of compliance to the point of all existing or planned surface potable water supply withdrawals. The second alternative is to maintain the existing point of compliance in all surface waters (i.e., at the point of discharge).

Due to the challenges and cost of meeting this limit, as well as the poor science behind it, we will also need your help in contacting your legislators. We will be developing bullet points and a draft letter for you to do so. We will also need your testimony at the virtual public hearings, as to the effects on your facilities.

Should you have any questions or comments, contact Josie Gaskey.
Regulatory - Safety News
Updated OSHA Compliance Directive on Silica
On June 25, 2020, OSHA issued a compliance directive effective June 25, 2020 regarding inspection and enforcement procedures for the Respirable Crystalline Silica exposures in general industry, maritime and construction.

In the new directive, OSHA has clarified major topics, such as alternative exposure control methods when a construction employer does not fully and properly implement Table 1, variability in sampling, multi-employer situations, and temporary workers. In general, the new document gives OSHA inspectors guidance on how to enforce the silica standards requirements in major topic areas:

  • Exposure assessments
  • Regulated areas
  • Respiratory protection
  • Methods of compliance
  • Table 1 tasks and specified exposure control methods
  • Recordkeeping
  • Housekeeping
  • Employee information and training
  • Medical surveillance
  • How to communicate hazards
Please note the Inspection Guidelines and Citation Guidelines for each major category listed in the index.

Should you have any questions, contactJosie Gaskey.
Regulatory - Safety News
MSHA Updates
The federal Administration publishes a semi annual Regulatory Agenda for each Agency. As a heads up, MSHA is listing quartz silica as proposed rulemaking for August 2020.

At last week’s MSHA Quarterly Stakeholder call, MSHA was asked about this date and they indicated it is on the agenda, but that they are running a bit behind.

PACA will be coordinating with NSSGA on this issue. Neither organization has seen a preview of the proposed rulemaking at this time, but it is expected that the exposure limit will be 50 ug/m3.

Additionally, the powered haulage proposed rulemaking is scheduled to be out in July. This will be focused on companies creating a program around their powered haulage and mobile equipment.

Should you have any questions or comments, contact Josie Gaskey.
Regulatory - Safety News
MSHA Falls Initiative
MSHA’s Falls Initiative is due to deaths from falls having increased from 8% to 19% of mining fatalities in the last two years. This includes working without fall protection on top of trucks, in aerial lift baskets, and while getting off and on other mobile equipment, as well as when performing maintenance on crushers, screens, conveyors, and other milling equipment.

Between January 2019 and June 2020, MSHA issued 92 imminent danger orders for people working at heights without fall protection. The most common violations were truck drivers climbing atop their vehicles, and maintenance and quarry personnel climbing to or working without fall protection in high places.

Attached is MSHA's safety alert, which we are being asked to distribute, along with MSHA's Walk and Talk Bullets on this initiative attached below.

Should you have any questions, contact Josie Gaskey.
Regulatory - Safety News
Slips and Falls and Safety
At the recent MSHA Stakeholder call, the focus of their safety presentation was on the number of slips and falls accidents. We bring this to your attention because if you look at the information on pages 12-14 of the presentation, particularly with respect to the slips and falls by TYPE and ACTIVITY, you will note that while the statistics are representative of the mines, many of these are normal Types and Activities found in not only mine sites, but also in ready mixed concrete and cement work activities, as well as in your personal lives. Pages 17 – 20 are safety reminders associated with slips and falls that might be helpful to review. Training videos resource information if needed, can be found on page 29.

Additionally, we wanted to bring to your attention a Ladder Safety App, developed by NIOSH, which is a measuring tool that utilizes visual, sound and vibration cues that allows you to set an extension ladder at the proper position. Once you download the NIOSH Ladder Safety app, you hold your phone against the ladder to ensure the ladder it is set properly. This app is free from the App Store and here is the link to a fact sheet on this app. You may find this helpful not only at work, but also in your personal life.

Should you have any questions, don’t hesitate to contact Josie Gaskey.
PACA – Building and Connecting Communities