Submitting Comments to OSHA

PackSafe continues to urge the U.S. Occupational Safety and Health Administration (OSHA) to evaluate and correct its references to inadequate and out-of-date guidelines involving workplace regulations on ignitable liquids.

In response to a call for public comments on a draft OSHA document titled, “Safety and Health Program Management Guidelines,” PackSafe submitted a letter reiterating concerns related to the transportation and warehousing of both hazardous and non-hazardous materials. Specifically, the letter sought to persuade OSHA to bring their regulations in-line with the current National Fire Protection Association code (NFPA 30) that provides safeguards to reduce the hazards associated with the storage, handling and use of flammable and combustible liquids.

In June 2015, PackSafe sent a letter to Dr. David Michaels, Assistant Secretary of OSHA, urging agency action surrounding the transportation and warehousing of both hazardous and non-hazardous materials.

In July 2015, OSHA’s director of standards and guidance, Mr. William G. Perry, replied via a letter that, “a rulemaking to update § 1910.106…would be a far more complex undertaking,” citing technical and economic challenges that would be difficult to overcome. Mr. Perry also noted that, between 1996 and 2001, a comprehensive update to 29 C.F.R. § 1910.106 had been listed on the Department of Labor’s Unified Regulatory Agenda, but subsequently was removed due to resource constraints. The letter concluded that OSHA does not have plans to revise this provision.