Document 3NmE49xYLnBG39JwOR5wQDp2y

V/-32 I Re*. 9 57) SHELL OIL COMPANY REFERENCE O/ to SEE ATTACHED DISTRIBUTION LIST date SEPTEMBER 19, 1980 from STAFF ENGINEER - HEALTH & SAFETY OPERATIONS - HEAD OFFICE subject STATUS OF PROPOSED AND NEW OSHA REGULATIONS The attached summary of the "Status of Proposed and New OSHA Regula tions" supplements and updates the summary information provided in our June 23, 1980, memorandum on this subject. (Note -- the "Lead Role" column is an inter nal identifier referring to the HS&E focal point.) On September 8, 1980, the Louisiana Chemical Assocation petitioned the U.S. Court of Appeals for the Fifth Circuit for an emergency stay"of two sections, (e) and (g), of the OSHA access to medical and industrial hygiene records rule covering access and notification. K. C. Crawford Attachment cc - R. L. Brunner H. L. Kusnetz C. F. Phillips J. D. Ransdell J. L. Rivard T. A. Selders For Information Shell Pipe Line Corporation - Mr. L. W. Kinison DPMC-13537 LAM 012166 DISTRIBUTION LIST MR. F. A. ELY MR. J. H. SANDERS DEER PARK MANUFACTURING COMPLEX SUPERINTENDENT - SAFETY AND INDUSTRIAL HYGIENE REFINERY SAFETY MANAGER. CHEMICAL SAFETY MANAGER^ MARTINEZ MANUFACTURING COMPLEX SAFETY MANAGER NORCO MANUFACTURING COMPLEX SUPERINTENDENT - HEALTH, SAFETY AND ENVIRONMENT MANAGER - HEALTH AND SAFETY WILMINGTON MANUFACTURING COMPLEX MANAGER - SAFETY AND "INDUSTRIAL HYGIENE ANACORTES REFINERY SAFETY MANAGER ODESSA/CINIZA REFINERIES SAFETY''REPRESENTATIVE - ODESSA SAFETY REPRESENTATIVE - CINIZA WOOD RIVER REFINERY MANAGER - SAFETY AND INDUSTRIAL HYGIENE DENVER CHEMICAL PLANT MANAGER - SAFETY AND INDUSTRIAL HYGIENE EL PASO CHEMICAL PLANT SAFETY REPRESENTATIVE GEISMAR CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT MARIETTA CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT MOBILE CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT TAFT CHEMICAL PLANT SAFETY REPRESENTATIVE WOODBURY CHEMICAL PLANT MANAGER - HEALTH, SAFETY AND ENVIRONMENT DPMC-13538 LAM 012167 STATUS OF PROPOSED AND NEW OSHA REGULATIONS REGULATION Chemical Substance Identification Labeling LEAD ROLE RHC Generic Standard for Pesticides JDH Walking/Working Surfaces Abrasive Blasting Lock-Out/Tag-Out a. General Industry b. Construction JLR CFP JLR STATUS Under discussion between CMA and OSHA. Timing somewhat delayed, proposed rule now is expected late September, 1980, together with EPA's complementary rules (one acute, one chronic). Final rules expected in early 1981 (45 FR 36960). Shell's comments on Draft #9, Version D, submitted to NACA for discussion with OSHA. Current activity through NACA remains high. Proposed rule delayed, now expected early 1981 after completion of regulatory analysis (Centaur survey). Final rule in mid-1981 (45 FR 36961). Trade association activity. OSHA activity intermittent over four years. Proposed rule likely delayed to spring 1981 per ORC sources. Trade association activity. Proposed ru^ earlier expected in mid-1980 (45 FR 36967), now likely Fall 1980. Advanced notice of proposed rule making published June 1980. Shell comments submitted to meet September 15, 1980, deadline. Proposed rules expected in early 1981 (General Industry) and late 1980 (Construction) [45 FR 36971 DPMC-13539 LAM 012168 REGULATION i Generic Standard for Carcinogens Access to Medical and Exposure Records Fire Protection Subpart L Electrical Standards 2 LEAD ROLE STATUS RHC (1) The Houston District Court (Judge Bue) ruled against the A. (and API) in_finding that the final rule is a regulation reviewable in a District Court rather that a standard reviewab in an Appellate Court. Future activities will reflect this decision. (2) OSHA published their candidate list of 107 compounds requiring further review. The Category I & II Priority Lists will be prepared late? this year and the will also include compounds fron EPA's CAG list of 91 compounds. Shell will request OSHA's data base (fact sheets) for some 60-8 compounds. The DEPT committee will prioritize our rebuttal activities. RHC Final rule became effective August 21,.1980. However, the Louisiana Chemical Association (including Shell) received a two week stay from OSHA. Guidelines have been provided to field locations on this new rule. Litigation is still underway. JLR Final rule published September 12, 1980. JLR Published proposed rule September 25, 1979, as part I of four parts. Shell submitted comments supporting the performance language approach. The final rule for Part I is expected in the fall of 1980. DPMC-13540 LAM 012169 REGULATION UNCHANGED FROM PRIOR ENTRY Noise Underground Construction Confined Spaces Asbestos Chromium I LEAD ROLE STATUS Not Assigned (RHC) Not Assigned (RHC) JLR Not Assigned (RHC) Not Assigned (RHC) OSHA activity intermittent over six years. Final rule in late 1S80 (45 FR 36963). Trade association activity. Proposed rule expected in late 1980 (45 FR 36968). Shell submitted a written response to an advanced notice. High trade association activity. Pro posed rule expected in late 1980 (45 FR 36970). OSHA is proposing to lower the current PEL. A notice of proposed rule making is expected this Fall (45 FR 36973). OSHA is proposing to lower the current PEL for hexavalent chromium and include other types of chromium. A notice of proposed rulemaking is expected tnis Fall (45 FR 36973). DPMC-13541 LAM 012170