Supplement to ASSE Comments OSHA Silica Proposed Rules Addresses "Competent Person"

During the questioning period of the March 21, 2014, public hearing for OSHA's proposed rule on respirable crystalline silica, OSHA's staff asked ASSE's witness, Adele L. Abrams, to supplement the Society's comments by elaborating on OSHA's proposal to require a “competent person” to be responsible for establishing and overseeing written access control plans where respirators and protective clothing would be required if silica over-exposures were anticipated.  ASSE's response provides a thoughtful overview of competent person in the context of the proposal, offers a possible definition based on wording used in similar contexts, argues for a presumption that a CSP or CIH is competent, and discusses training options. 


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