By Nick Goldstein, vice president of regulatory and legal issues, ARTBA
ARTBA, as a member of the Construction Industry Safety Coalition, has answered the Occupational Safety and Health Administration’s (OSHA) request to the regulated community to help clarify aspects of the crystalline silica rule.
OSHA is attempting to clarify Table 1 of the rule, which details the compliance requirements for 18 construction industry tasks that generate silica exposure. OSHA is determining whether to clarify any of the listed tasks and controls, or possibility expand Table 1.
The coalition’s Oct. 15 comments explained: “While well-intentioned, Table 1 as currently constituted does not provide contractors a viable compliance option. The allowed controls included in the table are too limiting and the tasks included do not represent the wide range of activities that are commonplace on construction worksites. Expanding Table 1 will result in improved compliance throughout the construction industry.”
Table 1 is beneficial for the transportation construction industry because when activities are carried out as described there, compliance with other elements of the standard is greatly simplified.