The BlueGreen Alliance (BGA) commented in support of the U.S. Department of Labor Mine Safety and Health Administration’s (OSHA) proposed standard on Lowering Miners’ Exposure to Respirable Crystalline Silica and Improving Respiratory Protection [Docket No. MSHA–2023–0001] RIN 1219-AB36.
BGA supports the reduction of the permissible exposure level (PEL) of respirable silica to 50 micrograms per cubic meter (ug/m3) and 25 ug/m3 as an action level for a full shift, aligning the MSHA protection of miners with the OSHA standard for other workers. However, we note that the NCOSH recommendation of 50 ug/m3 on which the proposal is based is almost 50 years old. The standard should prioritize engineering controls, administrative actions, and education and training that recognize that PELS and action levels are not synonymous with NOAELs (No Observed Adverse Effect Levels) and encourage practices that lower the levels of respirable silica that miners breathe as much as possible.
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