As I sit down to write this, I can't help but think of the faces I've seen and the stories I've heard throughout my career as an industrial hygienist. Each worker and each family depending on them reminds me why our work is so important. It's not just about regulations or compliance—it's about people—real people whose lives we have the power to protect and improve.
As we look ahead to 2025, I feel a sense of urgency and hope. We have challenges to face but also incredible opportunities to make our workplaces safer than ever before.
I want to share with you three critical areas that should be on all our radars. These aren't just items on a checklist; they're chances for us to show how much we truly care about the well-being of our workforce.
1. The new MSHA silica rule: Breathing easier in mining operations
First up, we've got a game-changer in the mining industry: the new Mine Safety and Health Administration (MSHA) silica rule. Published in June 2024, this updated regulation has had significant impacts on how we protect workers from respirable crystalline silica (RCS) dust exposure for coal and metal/nonmetal (MNM) miners.
What's changing?
The new rule:
• Establishes a uniform permissible exposure limit (PEL) and action level (AL) for all mines.
• Specifies methods for controlling RCS.
• Calls for exposure monitoring for RCS.
• Enforces sampling and periodic evaluations.
• Updates the respiratory protection standards by incorporating by reference ASTM International (ASTM) F3387-19, Standard Practice for Respiratory Protection.
• Requires immediate reporting and corrective actions in the case of overexposure results.
• Introduces medical surveillance at MNM mines.
These align more closely with other industries, creating a more consistent approach across industries.
Why should you care?
Silica dust is no joke—it can lead to serious lung diseases like silicosis, lung cancer, and chronic obstructive pulmonary disease (COPD). By implementing stricter controls, we're taking a big step toward safeguarding our miners' long-term health.
Action items
• Evaluate, evaluate, evaluate! Don’t wait to start performing exposure monitoring.
- Options for resources:
- Third-party industrial hygiene firm
- Internal
- Combination of both
- A third party helps with independent evaluation.
- A third party can train internal resources if available.
- Document, document, document!
2. EPA's methylene chloride shake-up: A safer approach to solvents
Next on our list is the US Environmental Protection Agency's (EPA) recent change regarding methylene chloride. The final rule was published in April 2024. This common solvent has been a staple in many industries, but its health risks have prompted a regulatory overhaul.
What's changing?
The EPA is tightening rules about methylene chloride, especially in consumer products. The agency has established new exposure limits:
• An 8-hour average limit of 2 parts per million (ppm)
• A short-term exposure limit of 16 ppm
These are significantly lower than the previous Occupational Safety and Health Administration (OSHA) standards of 25 ppm for long-term exposure and 125 ppm for short-term exposure, aiming to improve chemical safety.
Additionally, a Workplace Chemical Protection Program (WCPP) is required with compliance timelines. There's a push toward phasing out the use of methylene chloride in paint strippers and limiting exposure in industrial settings.
Why should you care?
Methylene chloride exposure can cause dizziness, nausea, and in severe cases, loss of consciousness or even death. By staying ahead of these changes, you're not just complying with regulations—you're actively protecting your workers' lives.
Action items
• Identify all processes using methylene chloride in your workplace.
• Research and test safer alternatives.
• Update your Hazard Communication Programs to include establishing a WCPP (where one of the 13 conditions of use are met).
• Perform initial monitoring and consecutive actions per the EPA fact sheet.
• Implement enhanced ventilation and personal protective equipment (PPE) measures where the chemical is still in use.
3. PFAS exposure: Tackling the “forever chemicals” challenge
Last but certainly not least, we need to talk about per- and polyfluoroalkyl substances (PFAS). These “forever chemicals” are receiving increased scrutiny due to their persistence in the environment and potential health impacts.
What's changing?
Regulatory bodies are ramping up efforts to monitor and control PFAS exposure. We're seeing new guidelines for acceptable levels in drinking water, soil, and air as well as increased pressure on industries to phase out PFAS use.
Why should you care?
PFAS have been linked to various health issues. Staying ahead of PFAS regulations isn't just about compliance—it's about being a responsible steward of both worker and environmental health.
Action items
• Conduct a PFAS inventory in your workplace.
• Implement testing protocols for PFAS in your facility's water and soil.
• Explore PFAS-free alternatives for any processes currently using these chemicals.
• Develop a PFAS phase-out plan to get ahead of future regulations.
Remember, the goal isn't just to meet the minimum requirements; it's to go above and beyond in protecting our workers and communities. Let's embrace these challenges as opportunities to innovate and lead the way in occupational health and safety.
Stay safe out there, and here's to a healthier, more secure future for all our workers.
To learn more about the EPA's new requirements for methylene chloride exposure assessments, register here for our mini webinar with Martin Bermudez, CHMM, CPEA.
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