These comments are submitted on behalf of the Coalition for Workplace Safety (“CWS”) and the 74 undersigned organizations (“the Commenters”), pursuant to the Occupational Safety and Health Administration’s Notice of Proposed Rulemaking regarding the Worker Walkaround Representative Designation Process under the OSH Act, 88 Fed. Reg. 59825 (Aug. 30, 2023) (“Proposed Rule”). For the reasons outlined below, the Commenters urge OSHA to withdraw the proposed rule entirely.

The National Stone, Stand & Gravel Association (NSSGA) submits these comments on the Department of Labor’s (DOL or the Department) proposal to raise the salary threshold for the executive, administrative, professional, outside sales, and computer employee exemptions from the overtime requirements of the Fair Labor Standards Act (FLSA). NSSGA represents the aggregates and industrial sand industry, with over 9,000 facilities and more than 100,000 employees in high-paying jobs. As a signatory, NSSGA strongly supports the comments filed by the Partnership to Protect Workplace Opportunity (P

National Stone, Sand & Gravel Association (NSSGA) submits these comments in response to the Surface Transportation Board’s (STB or the Board) Notice of Proposed Rulemaking (NPRM) in “Reciprocal Switching for Inadequate Service,” which focuses on providing rail customers with access to reciprocal switching as a remedy for poor service, based around three measures of carrier success or failure, namely: (1) service reliability; (2) service consistency; and, (3) adequacy of local service. NSSGA is the leading voice and advocate for the aggregates industry. NSSGA members use freight rail to

The undersigned associations urge you to ensure the Environmental Protection Agency maintains existing National Ambient Air Quality Standards for fine particulate matter (PM2.5). A proposed discretionary revision to this standard, which is under review by the Office of Information and Regulatory Affairs, could put nearly 40% of the U.S. population in areas of nonattainment. Doing so would risk jobs and livelihoods by making it even more difficult to obtain permits for new factories, facilities and infrastructure to power economic growth.

The National Stone, Sand and Gravel Association (NSSGA) would like to take this opportunity to provide comments in response to the Financial Accounting Standards Board’s (FASB) Exposure Draft, Proposed Accounting Standards Update: Income Statement – Reporting Comprehensive Income-Expense Disaggregation Disclosures (Subtopic 220-40) – Disaggregation of Income Statement Expenses. NSSGA members consist of stone, sand and gravel producers; industrial sand suppliers; and the equipment manufacturers and service providers who support them. 

The National Stone, Sand and Gravel Association (NSSGA) would like to take this opportunity to provide comment in response to the Council of Environmental Quality’s (CEQ) National Environmental Policy Act (NEPA) Implementing Regulations Revisions Phase 2 proposed rule (“Proposed Rule”).

The undersigned associations (collectively, the “Coalition”) offer the following comments in response to the Council on Environmental Quality’s (“CEQ’s”) proposed National Environmental Policy Act (“NEPA”) Implementing Regulations Revisions Phase 2 (“Proposed Rule”). Our organizations represent a diverse set of economic sectors that form the backbone of the American economy – agriculture, energy, construction, mining, forestry, manufacturing, transportation, and other sectors.

The Partnership to Protect Workplace Opportunity (PPWO) and the 107 undersigned organizations write to you to request a 60-day extension to the comment period on the agency’s above-referenced notice of proposed rulemaking in order to provide the regulated community with sufficient time to analyze and respond to the Wage and Hour Division’s (WHD) proposed changes to the overtime pay exemptions for executive, administrative, professional, outside sales, and computer employees.

The National Stone, Sand and Gravel Association (NSSGA) would like to take this opportunity to provide comments in response to the Office of Management and Budget’s (“OMB”) Aug. 2, 2023, “Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis” (Draft Guidance). Our industry is heavily regulated from federal, state, and local entities. These regulations are ever changing, and many times are contradictory, causing significant delay and expense for approving projects.

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.