NDA Submits Comments to OSHA on Crystalline Silica RFI

Yesterday, NDA submitted comments to the Occupational Safety and Health Administration (OSHA) in response to their Request for Information (RFI) regarding the final rule on Occupational Exposure to Respirable Crystalline Silica (81 FR 16286). 

OSHA was requesting information on the effectiveness of engineering and work practice control methods not currently included for the tasks and equipment listed on Table 1 of the Respirable Crystalline Silica standard for construction. The agency was also requesting information on tasks and equipment involving exposure to respirable crystalline silica that are not currently listed on Table 1, along with information on the effectiveness of engineering and work practice control methods in limiting worker exposure to respirable crystalline silica when performing those tasks.

NDA reiterated to OSHA that demolition is a unique activity within the construction industry and that Table 1 facilitates compliance challenges for the demolition industry.  NDA believes OSHA should expand Table 1 to reflect a wider range of tasks and enable more contractors to comply with the rule.  For a copy of NDA’s letter, click here.

NDA made the following recommendations to OSHA as they explore revisions to Table 1:

• OSHA should publish information pertaining to the latency period for silicosis and smoking.
• OSHA should more specifically define work in freezing conditions.
• OSHA should relax the “integrated” water supply requirement. Older machines are not necessarily equipped with “integrated” water supplies.
• OSHA should consider allowing for the retrofit of machinery to enable the delivery of a water
  suppression system, provided any aftermarket parts do not interfere with the safe operation of this machinery.
• OSHA should provide more types of equipment in Table 1 as companies and industries report their findings from field testing.
• OSHA should look at the action level and permissible exposure level (PEL) given the drastic
  reduction from what was deemed acceptable for the last 40 years.
• OSHA should put more emphasis on ensuring that all trades on a construction site are complying
  with the silica rule.

In addition to NDA’s comments, NDA members can visit the Grassroots Action Center and weigh in by clicking here.  For questions, contact Kevin McKenney at kmckenney@demolitionassociation.com. 

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