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OSHARulemakingOSHA-2010-0034

Occupational Exposure to Crystalline Silica

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National Association of Home Builders filings
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National Association of Home Builders filed 7 comments on this docket between Nov 26, 2013 and Oct 16, 2019. 306 other organizations filed here. The comment window closed 2478d ago.

What National Association of Home Builders filed (7)

Oct 16, 2019· Comment from Matuga, Robert; National Association of Home Builders (NAHB)· OSHA-2010-0034-4336

October 15, 2019 The Honorable Loren Sweatt Principal Deputy Assistant Secretary of Labor Occupational Safety and Health U.S. Department of Labor 200 Constitution Avenue, N.W. Washington, D.C. 20210 RE: Docket No. OSHA-2010-0034, Occupational Exposure to Respirable Crystalline Silica-Specified Exposure Control Methods - Request for Information: Request for Comments Dear Ms. Sweatt: On behalf of the more than 140,000 members of the National Association of Home Builders of the United States (NAHB), I am pleased to submit comments on the Department of Labors (DOL) Occupational Safety and Health Administrations (OSHA) Request for Information (RFI) on Occupational Exposure to Respirable Crystalline Silica-Specified Exposure Control Methods on August 15, 2019 (Silica RFI). NAHB appreciates OSHA publishing the RFI and seeking ways to improve compliance with the respirable crystalline silica standard for construction. NAHB is a Washington, D.C.-based trade association that represents members who are involved in home building, remodeling, multifamily construction, property management, subcontracting, design, housing finance, building product manufacturing and other aspects of residential and light commercial construction. NAHB is affiliated with more than 700 state and local home builders associations around the country. NAHB's builder members construct about 80 percent of the new housing units each year, making housing a large engine of economic growth nationally. As an interested stakeholder in this request for information, NAHB supports OSHAs initiative to review and revise Table 1 (Specified Exposure Control Methods When Working With Materials Containing Crystalline Silica) in the respirable crystalline silica standard for construction to include additional jobs/tasks and silica dust control measures. NAHB has submitted comments on a variety of OSHA rulemaking initiatives and has been particularly active throughout OSHAs silica rulemaking process, submitting extensive comments in response to OSHAs first proposal to issue a comprehensive respirable crystalline silica standard for construction. With the Silica RFI, OSHA is requesting information to primarily gather additional data and information on engineering and work practice control methods that should be added to Table 1, as well as other equipment/tasks that might be included. OSHAs efforts to consider revisions to the respirable crystalline silica standard for construction is vitally important to the residential construction industry. NAHB believes that updating and expanding Table 1 will provide more cost effective and workable solutions for the on-site conditions encountered on residential job sites, which will result in improved compliance throughout the residential construction industry and enhanced worker safety. In addition, NAHB is a member of the Construction Industry Safety Coalition (CISC). The CISC represents tens of thousands of employers and hundreds of thousands of workers in all facets of constructionfrom home building, to commercial and road construction, to heavy industrial production, to specialty trade contractors and material suppliers. The coalition was formed so the construction industry could respond to a wide variety of OSHA proposed construction safety rules with one voice. A core mission of the coalition is to promote healthy and safe jobsites in the construction industry. The CISC has also responded to OSHAs Silica RFI and in addition to these comments, NAHB adopts and incorporates by reference the substantive CISC comments requesting OSHA seriously consider the coalitions recommendations included in its response, along with the data and information it provided. Finally, NAHB submitted a request to OSHA to extend the Silica RFI comment period because we believe the Silica RFI did not provide the residential construction industry adequate time to gather, analyze, and provide the types of information the Agency is seeking. Unfortunately, OSHA…

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Sep 18, 2019· Comment from Matuga, Robert; National Association of Home Builders (NAHB)· OSHA-2010-0034-4267

September 18, 2019 The Honorable Loren Sweatt Principal Deputy Assistant Secretary of Labor Occupational Safety and Health U.S. Department of Labor 200 Constitution Avenue, N.W. Washington, D.C. 20210 RE: Docket No. OSHA-2010-0034, Occupational Exposure to Respirable Crystalline Silica-Specified Exposure Control Methods - Request for Information: Request for Extension of Comment Period Dear Ms. Sweatt: On behalf of its more than 140,000 members, the National Association of Home Builders (NAHB) respectfully requests a sixty (60) day extension of the current deadline for submitting written comments in response to the Occupational Safety and Health Administrations (OSHA) Request for Information (RFI) on Occupational Exposure to Respirable Crystalline Silica-Specified Exposure Control Methods on August 15, 2019 (84 Fed. Reg. 41667-41670). NAHB supports OSHAs initiative to review and revise Table 1 to include additional jobs/tasks and silica dust control measures. However, NAHB believes that providing only 60 days to submit comments to the RFI does not provide the residential construction industry adequate time to gather, analyze, and provide the types of information OSHA is seeking. Extending the comment period by 60 days will help ensure that OSHA has the best data available to it to assess whether and how to improve Table 1. NAHB is a Washington, D.C.-based trade association whose members are involved in home building, remodeling, multifamily construction, property management, subcontracting, design, housing finance, building product manufacturing and other aspects of residential and light commercial construction. NAHB's builder members construct about 80 percent of the new housing units each year, making housing a large engine of economic growth nationally. NAHB has submitted comments on a variety of OSHA rulemaking initiatives and has been particularly active throughout OSHAs silica rulemaking process, submitting extensive comments in response to OSHAs first proposal to issue a comprehensive respirable crystalline silica standard for construction. As an interested stakeholder in this regulatory activity, NAHB is willing and eager to provide data and information that will assist OSHA in determining what revisions to the silica in construction standard are needed and appropriate. NAHB believes that additional time is necessary to respond to the Occupational Exposure to Respirable Crystalline Silica-Specified Exposure Control Methods RFI for the following reasons: OSHA has asked thirty-one (31) separate detailed questions, which requires careful review and discussion by home builders and specialty trade contractors in order to understand the possible ramifications and their application, and to identify, prepare and submit the requested data and information. The RFI requires thoughtful analysis on wide-ranging topics from construction equipment and tasks, to engineering and work practice controls, to sampling and analytical procedures and to detailed economic impacts. Each of these topics must be considered and input obtained from NAHBs diverse membership, which cannot be completed in a short, 60-day comment period. Historically, OSHA's RFI is primarily used to gather information to help the Agency decide on what steps to take next in the rulemaking process. An extension of the comment period does not create a hardship for the Agency as there is no apparent, compelling reason for the current deadlineit does not respond to either a Congressional mandate, or an unprotected hazard. For these reasons, we believe an extension of time of 60 additional days for submitting comments is necessary and appropriate. Offering meaningful comments on this RFI is extremely important to NAHBs members. Accordingly, NAHB urges OSHA to grant all interested stakeholders this extension. Thank you, in advance, for your consideration in this request. Please call me at (202) 266-8590 if you have any questions or require any additional information…

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Jun 2, 2014· Post Hearing Comment from Matuga, Robert; National Association of Home Builders (NAHB)· OSHA-2010-0034-3750

The National Association of Home Builders (NAHB) filed a Notice of Intention to Appear at the Informal Public Hearing on the Occupational Safety and Health Administration's (OSHA) Proposed Rule for Occupational Exposure to Respirable Crystalline Silica (Docket No. OSHA-2010-0034). In accordance with the amended hearing procedures set by OSHA, parties who filed a notice of intention to appear at the hearings may submit additional information and data relevant to the proceeding through June 3, 2014 (i.e., within 60 days of the close of the hearing), with any final briefs, arguments, and summations submitted by July 18, 2014 (i.e., 105 days after the close of the hearing). Therefore, NAHB submits the following information and data relevant to the proceeding (see attachment).

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Feb 21, 2014· Testimony from Emrath, Paul; National Association of Home Builders (NAHB)· OSHA-2010-0034-2324

See attached document (uploaded PDF file). Testimony of Paul Emrath, Ph.D. on Behalf of the National Association of Home Builders during the Informal Public Hearing On the Occupational Exposure to Respirable Crystalline Silica; Proposed Rule [Docket No. OSHA–2010–0034] March 18, 2014 in Washington, DC.

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Feb 21, 2014· Testimony from Zimbelman, Tony; National Association of Home Builders (NAHB)· OSHA-2010-0034-2334

See attached document (uploaded PDF file). Testimony of Tony Zimbelman on Behalf of the National Association of Home Builders during the Informal Public Hearing On the Occupational Exposure to Respirable Crystalline Silica; Proposed Rule [Docket No. OSHA–2010–0034] March 18, 2014 in Washington, DC.

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Feb 20, 2014· Comment from Howard, Gerald; National Association of Home Builders (NAHB)· OSHA-2010-0034-2296

See attached comments (uploaded PDF file). On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), I am pleased to submit the attached comments on the Occupational Safety and Health Administration's (OSHA) Notice of Proposed Rulemaking (NPRM) on Occupational Exposure to Respirable Crystalline Silica that was published in the Federal Register on September 12, 2013 (78 Fed. Reg. 56274-56504) (Silica NPRM). As an interested stakeholder in this regulatory activity, NAHB is concerned that OSHA's proposed changes to the crystalline silica standard for construction will have a substantial adverse impact on regulated employers and small businesses, including home builders and specialty trade contractors. NAHB is a Washington, D.C.-based trade association that represents more than 140,000 members who are involved in home building, remodeling, multifamily construction, property management, subcontracting, design, housing finance, building product manufacturing and other aspects of residential and light commercial construction. NAHB has also joined with twenty-five other trade associations in forming the Construction Industry Safety Coalition (CISC) with the purpose of providing OSHA with thoughtful, workable and data-driven feedback. In addition to its own comments, NAHB adopts and incorporates by reference the CISC's comments. NAHB appreciates the considerable time and resources OSHA has devoted to the Silica rulemaking. However NAHB is concerned that OSHA's proposed standard for Crystalline Silica in Construction is not cost effective, reasonable or workable for the on-site conditions encountered on residential job sites. In addition, NAHB is concerned that the rule does not provide clear direction for the construction industry to follow when implementing compliance and safety-related procedures. Further, the text of the proposed rule contains inconsistencies and lacks supporting data for the construction industry, leading us to conclude that OSHA has a fundamental misunderstanding of the entire construction industry, and specifically residential construction and home building. Moreover, NAHB remains concerned about its ability to thoroughly respond to OSHA's Silica NPRM due to the short comment period. The issues surrounding the hazards and risks associated with exposure to respirable crystalline silica on residential construction sites are complex and require extensive analysis and consideration. NAHB requested a 90 day extension to ensure it had adequate time to review the over 1,700 documents (and counting) in the record, obtain input from its members on aspects of the proposed rule that were of interest or concern, and prepare a reasoned response to assist OSHA in developing its final rule.1 Unfortunately, OSHA provided an extension of only 47 days for public comment and extended the period to submit notices of intent to appear at the public hearing; OSHA extended dates for the public hearing by 2 weeks.2 NAHB maintains that a minimum of 180 days is reasonable to submit comments on such an important and far-reaching proposal and believes such an extension would not create an undue burden for OSHA. Although OSHA further extended the filing deadline to February 11, 2014, this eleventh-hour extension did not allow Industry any meaningful opportunity to improve submissions. Because OSHA has provided insufficient time to fully review the proposal and supporting documents, NAHB's response to the Silica NPRM is preliminary and the Association intends to supplement the record with oral testimony and NAHB's post-hearing comment brief. In summary, due to the many problems associated with the proposal, NAHB respectfully requests that OSHA withdraw the Silica NPRM and instead, treat the current silica proposal as an Advance Notice of Proposed Rule Making (ANPRM). This way, OSHA can collect better data and gain a better understanding of how the construction industry operates so that it can address…

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Nov 26, 2013· Comment from Watson, Felicia ; National Association of Home Builders (NAHB)· OSHA-2010-0034-1813

(see attached letter) On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), we applaud the Occupational Safety and Health Administration (OSHA) for extending the time allowed for responding to the Notice of Proposed Rulemaking on Occupational Exposure to Respirable Crystalline Silica by 47 days; however, NAHB respectfully renews its request for more time and urges OSHA to grant an additional 45 days to respond to OSHA's Silica NPRM.

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Abstract

Occupational Exposure to Crystalline Silica

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