NARI, as part of the Construction Industry Safety Coalition (CISC), has requested the Occupational Safety and Health Administration (OSHA) withdraw its proposed rule to drastically lower the permissible exposure limit (PEL) of crystalline silica for the construction industry.
The reasons for this request include:
• OSHA‘s proposed crystalline silica rule is potentially the most far-reaching regulatory initiative proposed by OSHA for the construction industry.
• OSHA has not met its burden of demonstrating that the proposal is technologically and economically feasible.
• OSHA’s proposed rule is simply unworkable for the construction industry.
o OSHA has not shown that the proposed PEL can be met by the construction industry in most operations most of the time.
• OSHA has underestimated the cost of the proposed rule by a factor of at least 4. We now estimate a cost to the industry of $2.2 billion per year, but this figure will probably increase in the coming weeks as the coalition fixes more of OSHA's errors in understanding how construction work is done.
The Construction Industry Safety Coalition is made up of 25 trade associations. The coalition represents associations from all sectors of the construction industry, including commercial building, heavy industrial production, home building, road repair, specialty trade contractors and material suppliers. Workplace safety and health is a priority for all members of the coalition, and each is committed to helping create safer construction jobsites for workers.
American Road and Transportation Builders Association
American Society of Concrete Contractors
American Subcontractors Association
Associated Builders and Contractors
Associated General Contractors
Association of the Wall and Ceiling Industry
Building Stone Institute
Concrete Sawing & Drilling Association
Construction & Demolition Recycling Association
Distribution Contractors Association
Interlocking Concrete Pavement Institute
International Council of Employers of Bricklayers and Allied Craftworkers
Leading Builders of America
Marble Institute of America
Mason Contractors Association of America
Mechanical Contractors Association of America
National Association of Home Builders
National Association of the Remodeling Industry
National Demolition Association
National Electrical Contractors Association
National Roofing Contractors Association
National Utility Contractors Association
Natural Stone Council
The Association of Union Constructors
Tile Roofing Institute
CISC is asking OSHA to withdraw its proposed rule until it can put forth a proposal that addresses the concerns set forth in the coalition’s comments. The coalition welcomes the opportunity to sit down with OSHA to discuss the appropriate approach in dealing with the hazards of crystalline silica on construction worksites.