Bloomberg BNA Features Special Counsel Joseph J. Green on OSHA Acid Regulations
January 25, 2016

Special counsel Joseph Green was quoted in the article “Steel Industry Pushing For OSHA Changes to Acid Regulations” in Bloomberg BNA’s Chemical Regulation Reporter. The steel industry is pushing the Occupational Safety and Health Administration (OSHA) to harmonize its process safety management (PSM) thresholds for hydrochloric and hydrofluoric acids with Environmental Protection Agency standards, arguing that alignment advances the Obama administration’s goal of improving agency coordination to avert catastrophes. Steel producers are responding to the Occupational Safety and Health Administration’s June 5, 2015, revision to PSM, a change that now forces manufacturers to comply with those requirements if HHCs are used in specified amounts at 1 percent purity or greater. The previous policy required PSM compliance if the concentration limits exceeded the maximum commercial grade. Joe notes that, ‘‘The OSHA concentration limits were much higher, and now they’ve come back and said it’s 1 percent. ‘Now there’s confusion and we’re asking for relief.’’ He goes on to sum up the issues by saying that, ‘‘We’re in this limbo right here. If steel mills are required to present a program, and a year later, the regulations change, that would be a big waste of time and resources.’’