NCGA, Tiller says, is closely monitoring a number of air quality issues, ranging from the current implementation of EPA regulations to legislation related to climate change.

“Four years ago, our industry decided to develop a plan to obtain accurate measurements of emissions from gins across the cotton belt. Derek Whitelock, lead scientist for the project, reported at the Beltwide Cotton Conferences that sampling of gins has been done in California, New Mexico, Texas, Missouri, and North Carolina.

“The release of the PM 2.5 fine particulate matter factor from this study is targeted for the first quarter of this year. The Cotton Foundation and the Southern Cotton Ginners Association contributed financially to this project, and it is noteworthy that no other industry has gone to this extent to determine the correct factors for emissions.”

Although Environmental Protection Agency Director Lisa Jackson has indicated she will not propose any changes to the current standard for PM 10, Tiller says, “and while we are thankful for this, the EPA continues to review and implement regulations that have an impact on the ginning industry.

“Questions remain about the Cross State Air Pollution Rule and changes and levels of PM 2.5. We’re considering a new standard that would decrease the current coarse particulate matter threshold by roughly one-half. If the standard had been adopted, it could have placed more regions of the cotton belt into a non-attainment status, which would have caused gins to install more costly pollution controls.

“The possibility of expensive pollution control requirements remains a major concern for our industry.”

There is “no doubt,” Tiller says, that “activism by federal agencies such as OSHA and the Department of Labor will require gins to be more diligent in adhering to all requirements.

“Last year, a proposal included a change in the term ‘feasible’ as pertains to noise control and hearing conservation, and while OSHA has reversed its decision to continue its definition as in the past, hearing conservation remains a top priority for the agency.

“Another proposal we’re monitoring closely is the Illness Injury Protection Program and its potential impact on our industry. After years of discussion, there was a recent announcement in the Federal Register that a panel will be seated to review this program, which has been described as ‘a dream come true’ for unions and labor.’

“Combustible dust became a concern for gins in 2009, when an OSHA notice of proposed rulemaking erroneously listed a cotton gin as having had a dust explosion. We know that the explosion was, in fact, a flash fire that occurred when a door was opened on a battery condenser. But even without that incident, it was feared that gins could be included in the final rule.

“Tests at Texas A&M have shown that gin dust is impossible to combust, even at levels as high as 1,000 grams per cubic meter. Gin dust simply has too much inorganic dirt in it to combust under normal circumstances.

The Texas A&M data were included in the NCGA comments, Tiller says, along with a request to correct the record of the incident in the notice of proposed rulemaking.

“In the past few weeks, OSHA has indicated that combustible dust will be a ‘long term action item.’”