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OSHARulemakingOSHA-2009-0023

Combustible Dust

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American Coatings Association filings
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American Coatings Association filed 1 comment on this docket between Jan 12, 2010 and Jan 12, 2010. 67 other organizations filed here. The comment window closed 6019d ago.

What American Coatings Association filed (1)

Jan 12, 2010· Comment from Taylor, Stacey-Ann, American Coatings Association· OSHA-2009-0023-0048

January 4, 2010 OSHA Docket Office Docket No. OSHA-2009-0023 Technical Data Center, Room N-2625 U.S. Department of Labor 200 Constitution Avenue, NW Washington DC 20210 Re Docket No. OSHA-2009-0023; Advanced Notice of Proposed Rulemaking, Request for Comments Dear Sir/Madam: The American Coatings Association, Inc. (ACA) is a voluntary, nonprofit trade association representing some 300 manufacturers of paints, coatings, adhesives, sealants, and caulks, raw materials suppliers to the industry, and product distributors. As the preeminent organization representing the coatings industry in the United States, ACA's primary role is to serve as ally and advocate on legislative, regulatory and judicial issues at the international, federal, state, and local levels. Over the past months, we have worked with our members to answer as many of the questions in the ANPRM on Combustible Dust as possible. However, please note that there are several questions that we as a trade association were not able to address because these questions are simply better left to our individual member companies to answer. Those responses are noted as "Member Inputs" throughout the attached document. Thankfully, a number of our members will also be submitting their own responses to the questions in the ANPRM that we were unable to answer. We sincerely hope that OSHA will carefully consider our comments before moving forward. We look forward to an ongoing dialogue with your organization during the regulatory process. If you have any questions concerning this letter, please do not hesitate to contact either of the undersigned. We may be reached at (202) 462-6272 or sedwards@paint.org and staylor@paint.org. Sincerely, Lance "Skip" Edwards, CIHStacey-Ann Taylor Director, Health & Safety AffairsCounsel, Government Affairs Comments Provided Electronically Attachment: Questions and Answers II. Request for Data, Information, and Comments A. Industry Background 1. What business are you in? What NAICS industry or industries are you in? Industry Comment: Our industry manufactures and distributes paints and coatings. The paints and coatings can be divided into architectural coatings (house paints – both water based and solvent based) and industrial coatings (also water and solvent based) which are used on automobiles, bridges, appliances, etc. Finally, the industry produces products that are both liquid and powdered coatings. Our industry's NAICS is 32551: Paint and Coatings Manufacturing. 2. How many employees do you have? How many are production employees? How many employees work in areas where combustible dusts are present? What types of jobs do they perform? Industry Comment: The NPCA represents approximately 285 manufacturers and facilities throughout the United States. We represent approximately 90% of the gallons of paint and coatings produced. The 2007 Economic Census (the most recent) reports the following for the entire paint and coatings industry (NAICS 32551) Number of Manufacturing companies: 1,131 Number of Manufacturing Facilities those companies have in total: 1,369 Number of employees those companies employ: 41,893 Total value of shipments ($1,000): $23,574,988 Members Inputs for the second, third and fourth parts to this question. 3. What is the area of your facility? What percentage of this area has combustible dusts normally present? What percentage is subject to possible fugitive dust accumulations? Member Inputs 4. What type or types of combustible dusts are present? Industry Comment: Our industry uses organic pigments; dusts from dried, granular resins; adipic acid; aluminum powders; powdered waxes (flow modifiers); and carbon black. 5. Would you expect other firms in your industry to have similar combustible dusts hazards or are the products or processes that generate combustible dust in your facility unusual for your industry? Why? Industry Comment: Yes, as they all perform the same basic function as identified in qu…

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Abstract

Materials supporting combustible dust ANPR

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