Product Stewardship Program & OSHA Documentation

In 2002, the Occupational Safety and Health Administration (OSHA) endorsed a five-year voluntary product stewardship program called PSP 2002. On May 23, 2007, HTIW Coalition’s predecessor, RCFC, and its member companies renewed this voluntary product stewardship agreement with OSHA. On April 16, 2012, this agreement was again renewed with PSP 2012, another five-year program. PSP 2017 was signed on October 24, 2017 and again was in place for five years. A new five-year agreement was prepared and signed on May 4, 2022. This new five-year program, called PSP 2022, continues and builds upon the earlier programs. The HTIW Coalition PSP is a highly acclaimed, multi-faceted strategic risk management initiative designed specifically to reduce workplace exposures to refractory ceramic fiber (RCF). PSP 2022 was developed for use wherever RCF is manufactured, fabricated, installed, or removed as well as in other occupational settings where workers have potential exposure to airborne RCF. HTIW Coalition will continue to report its progress on the implementation of PSP 2022 to OSHA annually. Although there are no reporting provisions for non-HTIW Coalition member companies, all RCF users are encouraged to adopt the key elements of PSP 2022. The provisions of PSP 2022 are consistent with the 2006 NIOSH Criteria Document for RCF where NIOSH adopted a Recommended Exposure Limit (REL) of 0.5 fibers per cubic centimeter, which is the same as the HTIW Coalition Recommended Exposure Guideline (REG). OSHA has made a special point to commend HTIW Coalition for its attention to the safety and health of workers who use RCF. In a 2022 letter to HTIW Coalition, Deputy Assistant Secretary of Labor for Occupational Safety and Health James S. Frederick said: “We commend the HTIW Coalition and its member companies for this program to protect workers involved in manufacturing, forming, installing and removing products containing RCF. Workers in all segments of the industry can benefit from your Coalition’s commitment to product stewardship and safe use of RCF products . . . . It is with . . . optimism and gratitude for your efforts that OSHA reaffirms its support for this ambitious protection effort for America’s fiber workers.” HTIW Coalition has long believed that product stewardship for RCF is the most responsible risk management strategy that the industry could initiate. With this agreement, OSHA formally supports these worker protection efforts and helps to continue the tradition of cooperative agreements between industry and the regulatory community.

5/4/2022 – PSP 2022 (pdf) 5/4/2022 – Letter from OSHA to HTIW Coalition (pdf) 5/4/2022 – Letter from HTIW Coalition to OSHA

4/1/2022 – PSP 2017 5-Year Report to OSHA, April 2022 (pdf) 2/1/2019 – PSP Compliance Principles (pdf) 10/24/2017 – PSP 2017 (pdf) 10/24/2017 – Letter from OSHA to HTIW Coalition (pdf) 10/24/2017 – Letter from HTIW Coalition to OSHA (pdf) 10/20/2015 – Letter from OSHA to Unifrax (pdf) 8/19/2014 – Letter to Deputy Director, Enforcement Program U.S. Department of Labor (pdf) 8/19/2014 – Memo from Everest Consulting Associates, Inc. concerning use of N95 respirators (pdf) 6/19/2014 – Letter from Deputy Director, Enforcement Program U.S. Department of Labor (pdf) 7/1/2014 – Letter to Deputy Director, Enforcement Program U.S. Department of Labor (pdf) 7/31/2012 – Letter from OSHA to the President of HTIW Coalition (pdf) 6/21/2012 – HTIW Coalition letter to OSHA (pdf) 4/16/2012 – PSP 2012 (pdf) 5/23/2007 – RCFC Letter to Assistant Secretary of Labor, OSHA (pdf) 5/23/2007 – Letter from Assistant Secretary of Labor, OSHA, to the President of RCFC (pdf) 10/4/2006 – Letter from RCFC to Assistant Secretary for Occupational Safety and Health (pdf) 9/1/2006 – Letter from OSHA to the President of RCFC (pdf) 8/3/2004 – Letter from OSHA to the President of RCFC (pdf)