The ABC-led Construction Industry Safety Coalition (CISC) testified in front of OSHA March 24 on a proposed rule that would drastically lower the permissible exposure limit of respirable crystalline silica for the construction industry.

CISC reiterated many points from their February 11 comments, stating that the agency has not met its burden of demonstrating that the proposal is technologically and economically feasible. The coalition noted from a technological feasibility standpoint that OSHA’s proposal failed to factor in that construction work sites often experience less-than-ideal conditions, including wind, rain and cold. By not taking this into account, CISC argued many of the provisions in the rulemaking simply will not work in the “real world” of construction.

In addition, CISC stated OSHA has underestimated the cost of the proposed rule on the construction industry. The coalition pointed out that the agency has omitted a number of workers that will be affected by the proposed rule. OSHA’s estimate fails to account for 1.5 million construction workers that deal with silica-generating tasks, as well as 2.5 million self-employed construction workers who would also likely have to meet the standards, even though they are not under OSHA’s jurisdiction.

CISC and ABC reiterated their written comment requests that OSHA withdraw the burdensome proposal until it can demonstrate a rule of this kind is necessary and workable for the construction industry.