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NSSGA Submits Comments to OSHA


The National Stone, Sand and Gravel Association (NSSGA) filed formal comments with the U.S. Occupational Safety and Health Administration (OSHA) on the agency’s proposed rule on occupational exposure to respirable crystalline silica.

OSHA’s proposal is important to aggregates producers because the U.S. Mine Safety and Health Administration aims to propose a silica standard for the mining industry later this year. NSSGA is preparing to respond to MSHA’s proposal at that time.

OSHA intends to reduce the workplace limit for airborne silica by half. NSSGA noted in its comments that OSHA's proposal will not improve worker health. Instead, it will cost employers billions of dollars each year and lead to further workforce reductions in some industries. The best scientific evidence indicates that the current exposure limit protects workers from silica-related disease when it is universally complied with and universally enforced. Since the current limit took effect in 1971, silicosis-related deaths in the U.S. have dropped by more than 93 percent.

NSSGA members are committed to providing a safe and healthful work environment for their employees, whose daily efforts in today’s economy provides vital support to their families and the communities in which they live. “NSSGA years ago adopted a comprehensive Occupational Health Program for its members that is focused on measuring and reducing workplace silica exposures,” said NSSGA President and CEO Michael Johnson. “The elements of this program have been used successfully for decades to reduce silica exposures in the aggregates industry.”

NSSGA’s comments also highlight a difficult practical issue facing thousands of employers who will have to measure or re-measure workplace silica levels and who will entrust their silica samples to one of a few dozen commercial labs for analysis. It appears that many labs may not be able to provide the consistently accurate data that employers need to determine compliance. OSHA acknowledges this conundrum by providing labs with a two-year period to improve. But, as NSSGA points out, during those two years, OSHA can still fine employers if workplace exposures exceed the new lower limit.