NSSGA was recently invited to participate in a Congressional roundtable discussion on the U.S. Occupational Safety and Health Administration’s proposed crystalline silica rule.  NSSGA used the opportunity to voice its concerns about the agency’s unrealistic schedule for public comments and its proposal to reduce the permissible exposure limit by half (with an action level at half the proposed PEL) – particularly given the difficulties of accurately and consistently measuring silica exposures at those levels.

The roundtable is one of a series of continuing NSSGA efforts to educate policymakers and respond to issues and questions raised by the complex and lengthy proposal, which includes 232 pages of triple-column Federal Register fine print and thousands of pages of supporting technical documents.

In addition to NSSGA’s ongoing work with the American Chemistry Council’s Crystalline Silica Panel– whose members include 15 other trade associations and companies affected by OSHA’s proposal – NSSGA also provided verbal comments to OSHA during a meeting with the U.S. Small Business Administration’s Office of Advocacy, and met with two other federal agencies to discuss concerns about measuring silica exposures at the proposed new exposure limit and action level.

NSSGA also recently convened a group of aggregates experts to begin reviewing the potential compliance costs should the U.S. Mine Safety and Health Administration adopt a similar silica standard.  MSHA stated earlier this year that it would follow OSHA’s lead on silica rulemaking, indicating that the mining regulatory agency could issue its own notice of proposed rulemaking as early as the end of 2013.

NSSGA urges its members to petition OSHA for the additional time to comment and ask their elected representatives to do likewise. For help with reaching out to your elected representatives, please contact NSSGA Government Affairs staff.

For further technical information about the OSHA proposal, please contact Dale T. Drysdale at ddrysdale@nssga.org.

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