On July 13, 2023, The Mine Safety and Health Administration (MSHA) published a proposed rule, “Lowering Miners' Exposure to Respirable Crystalline Silica and Improving Respiratory Protection.” The National Stone, Sand and Gravel Association (NSSGA) and our member companies have carefully reviewed and analyzed the proposed standard. We respectfully submit the following comments, which include issues, recommendations, and most importantly, rationale backed by research and data.

On July 13, 2023, The Mine Safety Health Administration (MSHA) published a proposed rule, “Lowering Miners' Exposure to Respirable Crystalline Silica and Improving Respiratory Protection.” (Silica Standard). The Silica Standard provides for a public comment period of 45-days, which expires at midnight eastern time on August 28, 2023. The National Stone Sand & Gravel Association (NSSGA) requests an extension of the public comment period for an additional 60-days and proposes that the public comment period be extended until midnight eastern time on October 27, 2023.

ALEXANDRIA, VA – The National Stone Sand & Gravel Association (NSSGA) organized a day-long tour for the Mine Safety & Health Administration’s (MSHA) Assistant Secretary, Chris Williamson along with seven other Department of Labor/MSHA staff at Luck Stone’s Bull Run facility in Virginia. This was the Assistant Secretary’s first tour of an aggregates quarry and his first mine tour since starting at MSHA. This was followed by the first NSSGA-MSHA Alliance working meeting.

The Coalition for Workplace Safety (“CWS”) submits these comments in response to the Occupational Safety and Health Administration’s (“OSHA”) Proposed Rule, Improve Tracking of Workplace Injuries and Illnesses (87 Fed. Reg. 18528, March 30, 2022). The CWS is comprised of associations and employers who believe in improving workplace safety through cooperation, assistance, transparency, clarity, and accountability. The CWS believes that workplace safety is everyone’s concern.

The Partnership to Protect Workplace Opportunity (PPWO or Partnership) and the 93 undersigned organizations urge the Department of Labor’s (DOL or Department) Wage and Hour Division to abandon or at least postpone issuance of its announced proposed rulemaking altering the overtime regulations under the Fair Labor Standards Act (FLSA). Due to significant concerns with supply chain disruptions, workforce shortages, inflationary pressures, and the shifting dynamics of the American workforce following the COVID-19 pandemic, any rule change now would be ill-advised.

The 110 undersigned organizations, which represent a wide range of employers from private industry, states, municipalities, universities, colleges, k-12 schools and non-profits, write to request the U.S. Department of Labor (“DOL”) hold stakeholder meetings prior to the development and issuance of its anticipated Notice of Proposed Rulemaking (“NPRM”) on the “exemption of bona fide executive, administrative, and professional employees from the Fair Labor Standards Act’s minimum wage and overtime requirements” (also known as the “white-collar” exemptions).

The Coalition for Workplace Safety (“CWS”) respectfully requests an extension to the comment period on the Occupational Safety and Health Administration’s (“OSHA”) Advanced Notice of Proposed Rulemaking (“ANPRM”), Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings, which was published in the Federal Register on October 27, 2021. CWS and many of its member associations intend to comment on the ANPRM. OSHA’s current comment period, however, poses challenges for stakeholders seeking to provide thoughtful, accurate responses to the numerous questions posed in the ANPRM.

On behalf of the National Stone, Sand & Gravel Association (NSSGA), I write to request an extension to the extremely short comment period for the Occupational Safety and Health Administration’s COVID-19 Vaccination and Testing Emergency Temporary Standard. The agency has only provided the public with 30 days to submit input. This is an extensive rulemaking, and stakeholders need more time to provide the agency with comprehensive comments. Additional time will allow the employer community to find issues or points of concern as they attempt to implement the ETS.

ALEXANDRIA, VA – The National Stone, Sand & Gravel Association (NSSGA) Vice President of Government and Regulatory Affairs Michele Stanley issued the following statement regarding the Occupational Safety and Health Administration (OSHA) announcement of an Emergency Temporary Standard (ETS) that phases in a vaccine mandate for companies with over 100 employees.

As the House Committee on Education and Labor Subcommittees on Workforce Protections and Civil Rights and Human Services examine vaccine mandates in the workplace, I am writing to share our concerns regarding the obligations of the executive order requiring vaccinations or COVID-19 testing through an Emergency Temporary Standard (ETS) at the Occupational Safety and Health Administration (OSHA) or the Mine Safety and Health Administration (MSHA). Since the start of the COVID-19 pandemic, aggregates operators have taken aggressive actions to protect workers, as they continue to produce Americ