The Non-Ferrous Founders’ Society (NFFS) has officially submitted comments to OSHA regarding its proposed Heat Injury and Illness Prevention rule. Over the past two months, the NFFS Government Affairs Committee has met weekly to review the proposal, identify potential impacts on non-ferrous foundries, and develop comprehensive comments that reflect the industry’s unique operational challenges.
In its submission, NFFS emphasized concerns with the overly prescriptive nature of the proposed rule, which could impose significant administrative burdens on foundries without proportionate safety benefits. Key issues highlighted include the impracticality of requiring site-specific heat plans, the use of heat metrics ill-suited to foundry environments, and rigid acclimatization protocols that conflict with operational realities. Instead, NFFS advocated for a performance-based approach that allows employers to tailor safety measures to their specific processes while maintaining worker safety.
Members are encouraged to review the complete text of NFFS’s submitted comments to better understand the Society’s positions on this critical issue. A copy of the final comments is available HERE.
NFFS files comments on OSHA's proposed heat rule
The Non-Ferrous Founders’ Society (NFFS) has officially submitted comments to OSHA regarding its proposed Heat Injury and Illness Prevention rule. Over the past two months, the NFFS Government Affairs Committee has met weekly to review the proposal, identify potential impacts on non-ferrous foundries, and develop comprehensive comments that reflect the industry’s unique operational challenges.
In its submission, NFFS emphasized concerns with the overly prescriptive nature of the proposed rule, which could impose significant administrative burdens on foundries without proportionate safety benefits. Key issues highlighted include the impracticality of requiring site-specific heat plans, the use of heat metrics ill-suited to foundry environments, and rigid acclimatization protocols that conflict with operational realities. Instead, NFFS advocated for a performance-based approach that allows employers to tailor safety measures to their specific processes while maintaining worker safety.
Members are encouraged to review the complete text of NFFS’s submitted comments to better understand the Society’s positions on this critical issue. A copy of the final comments is available HERE.
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