In August, OSHA released an RFI regarding possible revisions to the construction silica dust standard looking to get feedback from the industry. The deadline for submittal was a little over a week ago, but one construction industry group filled us in on the comments they have submitted.
The Construction Industry Safety Coalition (CISC), who was critical of OSHA when it updated the silica standard in 2016, has submitted a 22-page response to OSHA’s request. As a quick refresher, OSHA’s goal was to learn more about additional dust control methods and to explore adding additional equipment or tasks to the silica Table 1 in 29 CFR 1926.1153.
CISC, which is made up of 26 trade associations including ABC and AGC, was pleased with OSHA for submitting the RFI. They had this to say in their response:
“The CISC applauds the Agency for issuing this RFI and has been pushing the Agency to do so for over two years. Expanding Table 1 and otherwise improving compliance with the rule is of paramount importance to CISC member associations and contractors across the country. Based upon the feedback the CISC has received from contractors – both large and small – compliance with the rule remains challenging. The CISC encourages OSHA to move quickly with rulemaking to permit contractors additional compliance options and tools.”
The group had 5 main requests and comments regarding OSHA’s Table 1:
Exclude mortar mixing and drywall installation/finishing from the table due to low exposure rates
Expand Table 1 to include an “under one hour” of exposure section, add dry cutting with vacuum attachments for stationary masonry saws and handheld power saws, allow the use of standard shop vacuums, and explore the use of fans and air scrubbers for dust control
Explore changes that would ease compliance in specific circumstances, such as allowing respiratory protection only for tasks under 30 minutes or exceptions to the rules where engineering controls may prove to be hazardous, such as work on a roof, among others.
Standardization of a process to quickly and efficiently update Table 1 based upon technological improvements
Included a discussion on the overall cost reduction these changes would cause.
There is a lot more background information included on their response letter, as well, so I encourage you to read that for more details.
What do you think about the CISC’s response? Tell us in the comments below!
Full story: Response to OSHA’s Respirable Crystalline Silica Request for Information (PDF) | CISC
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