On Oct. 9, the ABC-led Construction Industry Safety Coalition submitted comments in response to the Occupational Safety and Health Administration’s (OSHA) Request for Information (RFI) on Chemical Management and Permissible Exposure Limits (PELs). The RFI asked stakeholders how the agency should consider approaching health standard rulemaking, such as managing chemical exposures in workplaces.

CISC’s comments highlight the need for the Agency to go through the proper rulemaking process and allow the public to comment on all the analytical issues and approaches OSHA takes to regulate hazardous chemicals. When OSHA tries to regulate a health hazard the agency needs to show that the standard as a whole is technologically and economically feasible.  CISC points to their recent comments on the respirable crystalline silica proposal, which demonstrated that the agency failed to understand how the construction industry works.  

The CISC reiterated that the agency must continue to consider construction separately from general industry and maritime given the unique and variable conditions on construction worksites.