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, HTIW Coalition renewed this agreement.

This new five year program, called PSP 2012, continues and builds upon the earlier programs. PSP 2012 is a highly acclaimed, multi-faceted strategic risk management initiative designed specifically to reduce workplace exposures to refractory ceramic fiber (RCF). PSP 2012 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 continues to report its progress on the implementation of PSP 2012 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 2012.

The provisions of PSP 2012 are consistent with the 2006 NIOSH Criteria Document for RCF in that OSHA endorses the 0.5 fibers per cubic centimeter NIOSH REL, which is the same as the HTIW Coalition recommended exposure guideline.

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 2012 letter to HTIW Coalition, Assistant Secretary of Labor for Occupational Safety and Health David Michaels 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 HTIW 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 worker protection effort."

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.

PSP stewardship

Shown seated from left to right: Dell Hadden, Thermal Ceramics, Vice President of Operations; David Brooks, Unifrax Corporation, President and CEO, Edwin Foulke, Assistant Secretary of Labor for Occupational Safety and Health; Dean Venturin, President, RCFC.


PSP 2012 Documentation


8/3/2004 - Letter from OSHA to the President of RCFC (pdf)

9/1/2006 - Letter from OSHA to the President of RCFC (pdf)

10/4/2006 - Letter from RCFC to Assistant Secretary for Occupational Safety and Health (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)

4/16/2012 - PSP 2012 (pdf)

6/21/2012 - HTIW Coalition letter to OSHA (pdf)

7/31/2012 - Letter from OSHA to the President of HTIW Coalition (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)

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)

5/13/2015 - PSP Compliance Principles (pdf)

10/20/2015 - Letter from OSHA to Unifrax (pdf)

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