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.
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