The Association of Union Constructors Urges OSHA to Withdraw Silica Rule

February 12 2014

The Association of Union Constructors (TAUC), as part of the Construction Industry Safety Coalition (CISC), submitted comments requesting the Occupational Safety and Health Administration (OSHA) withdraw its proposed rule in its current form to drastically lower the permissible exposure limit (PEL) of crystalline silica for the construction industry.

Click here to view the comments.

TAUC contractors hold employee safety and health as a core value in their businesses; however, the crystalline silica rule as currently proposed by OSHA reveals several shortcomings in the rule that the agency has failed to adequately address.

For the industrial maintenance and construction industry, the proposed rule significantly reduces the current Permissible Exposure Limit (PEL) and creates a new Action Level (AL) that OSHA has not shown to be technologically or economically feasible to attain for most construction operations, the majority of the time.

Preliminary estimates by the CISC show that OSHA has underestimated the cost of the proposed rule by a factor of at least four (4). One reason OSHA underestimates the costs is because the Agency has omitted 1.5 million workers in the construction industry who routinely perform a variety tasks not considered by the Agency in their assessment of the affected workforce.

With the many contradictions between the rule and the realities faced in the construction and industrial maintenance industry we are urging the administration to withdraw this proposed rule and work with industry stakeholders to develop a silica measure that best addresses the complexities faced in the construction and industrial maintenance industry.

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