The composite panel industry has maintained a long-standing commitment to workplace health and safety. For decades, CPA has sponsored the collection of U.S. and Canadian industry safety related performance data and has recognized facility-specific safety accomplishments and workplace safety innovations. This safety data tells the story of an industry that is fully committed to the well-being of its workforce.
CPA also places a high priority on ensuring that there are appropriate regulations in place to protect the safety of employees in the industry. CPA continues to play a lead role in working with the U.S. Environmental Protection Agency (EPA) on clean air emissions regulations, both inside and outside the plants. The association has also engaged at the federal and state levels, as well as in Canadian provinces, on setting responsible occupational levels for regulated substances, such as wood dust and formaldehyde.
COMMITMENT TO SAFETY
The North American composite panel industry maintains an incredibly dedicated commitment to workplace health and safety. This commitment to safety is working. According to 2017 BLS data, composite wood manufacturing had an average recordable incident rate of 2.3, below the national average of 3.1 and well below comparable industries like wood container and pallet manufacturing (8.3) and sawmills (5.9).
Never satisfied, North American mills remain committed to continuous improvement by sharing data and best practices through CPA.
Monthly Safety Data Collection
CPA publishes a monthly safety report detailing the monthly and year-to-date recordable incident rate among participating mills, allowing plants more real-time data on safety trends in the industry than what is provided by government regulatory bodies. The monthly report also tracks details on reported incidents such as day of the week, shift, and location in the mill where injuries take place, allowing safety managers to identify when and where injuries are most likely to take place and prioritize resources and training accordingly.
Workplace Safety Awards
Data collected for the monthly report is also used as the basis for CPA’s annual safety awards, which are highly prized by CPA member plants and are awarded during CPA’s annual meeting. Since 1968, CPA has recognized mills with exemplary safety records.
Most recently, CPA has administered a safety innovation award to highlight inventive safety policies, practices, or technology specific to composite panel manufacturing. The winner each year is asked to present the innovative workplace safety approach at CPA’s next annual meeting.
Legislative and Regulatory Activity
CPA is proud to represent an industry that places such high value on workplace safety and will continue to be a resource to its members on safety information and improvements. This commitment to safety carries over into CPA’s approach to advocating on legislative and regulatory issues impacting the industry. CPA is actively engaged on issues related to plant air emissions and setting appropriate occupational exposure limits (OELs).
EPA Clean Air Act
Composite wood panel plants are required under the Clean Air Act to meet strict emission limits for “hazardous air pollutants” for both inside and outside the plant. The CPA has worked closely with other wood trade groups and EPA to provide the technical expertise needed to inform these requirements and ensure they are reasonable and effective.
Under the 1990 Clean Air Act amendments, EPA is required to set maximum achievable control technology (MACT) standards for various industries. In 2004, EPA promulgated MACT standards for the wood products industry under the Plywood and Composite Wood Panel (PCWP) MACT. Amended in 2006, the PCWP MACT requires plywood and composite wood manufacturers to undertake certain measures to control emissions of hazardous air pollutants (HAPs) from a list of identified sources. These sources, or “process units,” include for example dryers, refiners, board presses and coolers. Manufacturers generally have flexibility to choose how to meet the requirements, through production-based compliance options, add-on controls or emissions averaging (existing sources only). Certain process units do, however, require specific control or workplace practices, as prescribed in the PCWP MACT Rule.
EPA is required to conduct a residual risk and technology review (RTR) for each MACT eight years after promulgation. EPA initiated this process in September 2016 by publishing in the Federal Register a proposed Information Collection Request (ICR). Following public comment, the final ICR was published in August 2017, and composite panel manufacturers in the U.S. have completed the survey. EPA has targeted June 2019 to issue the proposed rule, taking into account the information provided in the ICRs, with the goal of meeting a court-ordered deadline for the final rule of June 30, 2020.
Formaldehyde Occupational Exposure Limits (OELs)
Composite wood panel plants must meet formaldehyde occupational exposure limits (OELs), and these are regulated by the Occupational Safety and Health Administration in the U.S. and by provincial workplace regulatory agencies in Canada. OSHA has established a “permissible exposure limit” (PEL) for formaldehyde exposures of 0.75 ppm of air measured as an 8-hour time weighted average. There is also a short-term exposure limit of 2 ppm, which is the maximum allowed during a 15-minute period. The standard also includes an action level, or the trigger for increased monitoring and medial surveillance - of 0.5 ppm on an 8-hour time-weighted average.
In Canada, each province varies in how it has approached setting OELs. Recently, the Ontario Ministry of Labor initiated a comment process for updating its formaldehyde OEL, and CPA has been working closely with the provincial government to provide constructive input.
Letter to Ministry of Labor on Proposed OEL [LINK]
OSHA has issued over the years several directives, letters of interpretation and other guidance related to controlling wood dust exposures. States have also acted to control workplace wood dust exposures, including most recently California. California’s Division of Occupational Safety and Health (Cal/OSHA) published a revised final rule in July 2017 establishing a PEL of 2 mg/m3 for all wood except western red cedar, which has a PEL of 0.5 mg/m3. Additionally, the short-term exposure limit is 5 mg/m3 total particulate mass. The TWA is measured as total particulate mass; not inhalable dust.