As I sit down to write this, I can't help but think of the faces I've seen and the stories I've heard throughout my career as an industrial hygienist. Each worker and each family depending on them reminds me why our work is so important. It's not just about regulations or compliance—it's about people—real people whose lives we have the power to protect and improve.
As we look ahead toward the second half of 2025, we have challenges to face but also incredible opportunities to make our workplaces safer than ever before. With several critical compliance deadlines approaching, now is the time to take action.
I want to share with you three critical areas that should be on all our radars, with a particular focus on the deadlines we need to meet.
- The new MSHA Silica Rule: Breathing easier in mining operations
The Mine Safety and Health Administration (MSHA) issued a final rule on April 18, 2024, aimed at reducing miners' exposure to respirable crystalline silica (RCS), a known cause of silicosis and other serious lung diseases.
What's changing
The new rule establishes:
- A uniform permissible exposure limit (PEL) of 50 micrograms per cubic meter (µg/m³) over an 8-hour time-weighted average.
- An action level at 25 µg/m³.
- Requirements for exposure monitoring.
- Specific methods for controlling RCS.
- Immediate reporting protocols for overexposure.
- Updated respiratory protection standards by incorporating ASTM International (ASTM) F3387-19.
- Medical surveillance requirements for metal and nonmetal (MNM) mines.
Critical Deadlines
- August 18, 2025: Compliance deadline for coal mine operators (extended from the original April 14, 2025, deadline due to implementation challenges)
- April 8, 2026: Compliance deadline for MNM mine operators (remains unchanged)
Why should you care?
Silica dust is no joke. It can lead to serious lung diseases like silicosis, lung cancer, and chronic obstructive pulmonary disease (COPD). By implementing stricter controls, we're taking a big step toward safeguarding our miners' long-term health.
Action items
- Start now: Begin exposure monitoring immediately—don't wait until the deadline approaches.
- Resource options:
- Third-party industrial hygiene firm
- Internal resources
- Combination of both
- A third party helps with independent evaluation and can train internal resources.
- Document everything throughout your compliance process.
- The EPA's methylene chloride shake-up: A safer approach to solvents
In April 2024, the US Environmental Protection Agency (EPA) finalized a comprehensive risk management rule under the Toxic Substances Control Act (TSCA) to address the health hazards posed by methylene chloride.
What's changing
- Prohibition of manufacturing, processing, and distribution for all consumer uses and most industrial and commercial applications
- Complete phase-out of these uses within two years of the effective date
- Certain critical uses permitted to continue under stringent workplace controls
- Establishment of new exposure limits:
- Eight-hour average limit of 2 parts per million (ppm) (down from the Occupational Safety and Health Administration’s [OSHA] 25 ppm)
- Short-term exposure limit of 16 ppm (down from OSHA's 125 ppm)
- Implementation of a Workplace Chemical Protection Program (WCPP) for exempted uses
Critical deadlines
- July 8, 2024: Effective date of the rule
- May 5, 2025: Deadline for baseline sampling
- January 8, 2026: Deadline for facilities engaged in exempted uses to comply with WCPP requirements (18 months from effective date)
Why should you care?
Methylene chloride exposure can cause dizziness, nausea, and in severe cases, loss of consciousness or even death. By staying ahead of these changes, you're not just complying with regulations—you're actively protecting your workers' lives.
Action items
- Identify all processes using methylene chloride in your workplace.
- Research and test safer alternatives immediately.
- Update your Hazard Communication Programs to include establishing a WCPP (where one of the 13 conditions of use are met).
- Perform initial monitoring well ahead of the May 2025 deadline.
- Implement enhanced ventilation and personal protective equipment (PPE) measures where the chemical is still in use.
- PFAS exposure: Tackling the “forever chemicals” challenge
In April 2024, the EPA finalized its first-ever national drinking water standards for six per- and polyfluoroalkyl substances (PFAS), commonly known as “forever chemicals,” under the Safe Drinking Water Act.
What’s changing
- Enforceable limits requiring public water systems to reduce PFAS levels to near-zero concentrations
- Maximum contaminant levels (MCLs) as low as 4 parts per trillion (ppt) for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS)
- Certification requirements for laboratories conducting PFAS analyses
- Allocation of nearly $1 billion in funding to support compliance as part of a broader $9 billion investment from the Bipartisan Infrastructure Law
Critical deadlines
- June 25, 2024: All PFAS analyses must be conducted by laboratories certified by the EPA or the respective state primacy agency
- April 2027: Deadline for water systems to complete initial monitoring
- April 2029: Deadline for implementing necessary treatment solutions if PFAS levels exceed the MCLs
Why should you care?
PFAS have been linked to various health issues. Staying ahead of PFAS regulations isn't just about compliance—it's about being a responsible steward of both worker and environmental health.
Action items
- Conduct a PFAS inventory in your workplace.
- Implement testing protocols for PFAS in your facility's water and soil using only certified laboratories.
- Explore PFAS-free alternatives for any processes currently using these chemicals.
- Develop a PFAS phase-out plan to get ahead of future regulations.
- For eligible small or disadvantaged communities, explore funding opportunities through the Emerging Contaminants in Small or Disadvantaged Communities (EC-SDC) grant program (available through fiscal year 2026).
Remember, the goal isn't just to meet the minimum requirements; it's to go above and beyond in protecting our workers and communities. Let's embrace these challenges as opportunities to innovate and lead the way in occupational health and safety.
Stay safe out there, and here's to a healthier, more secure future for all our workers.
Be on the look-out for our upcoming e-book Beyond forever chemicals: PFAS fundamentals for successful risk management.
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