U.S. Chemical Safety Board 

1750 Pennsylvania Avenue, NW Suite 910 

Washington, DC 20006 


Re: CSB Releases Call to Action on Combustible Dust Hazards (https://www.csb.gov/csb-releases-call-to-action-on-combustible-dust-hazards, October 24, 2018) 

To whom it may concern: 

The Society of Chemical Manufacturers and Affiliates (SOCMA) is pleased to submit the following comments on the U.S. Chemical Safety Board’s “Call to Action: Combustible Dust”. 

 SOCMA is the only U.S.-based trade association solely dedicated to the specialty and fine chemical industry. Our members play an indispensable role in the global chemical supply chain, providing specialty chemicals to companies in markets ranging from aerospace and electronics to pharmaceuticals and agriculture. 

CSB’s initiative on combustible dust seeks information from entities involved in the management and control of combustible dust hazards. SOCMA members have a significant interest and vast experience with combustible dust hazards and appreciate the opportunity to submit comments. 

The comments and recommendations on the pages that follow were developed in 2010 in response to an advance notice of proposed rulemaking by the U.S. Occupational Safety and Health Administration on combustible dust.1 SOCMA believes this information, gathered from the collective input of SOCMA’s membership, continues to have strong relevance for the purposes of CSB’s current initiative on combustible dust. As such, these comments have been provided in the full state in which they were originally submitted to OSHA. If you have any questions regarding these comments, please do not hesitate to contact me at (571) 348-5122 or at rothsteinj@socma.com. 

Respectfully submitted, 

Jared Rothstein 

Senior Manager, Regulatory Affairs 

Society of Chemical Manufacturers & Affiliates (SOCMA) 

1400 Crystal Drive, Suite 630 

Arlington, VA 22202 

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