Advisory Committee on Construction Safety and Health (ACCSH)

January 8, 2021 Loren Sweatt Principal Deputy Assistant Secretary Occupational Safety and Health Administration U.S. Department of Labor 200 Constitution Avenue, NW Washington, DC 20210 RE: Docket No. OSHA–2020–0003; Request for nominations for membership on the Advisory Committee on Construction Safety and Health (ACCSH) Dear Principal Deputy Assistant Secretary Sweatt: On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), I appreciate the opportunity to offer you a candidate for appointment as an "Employer Representative" to the Occupational Safety and Health Administration's (OSHA) Advisory Committee on Construction Safety and Health (ACCSH). As an organization that represents front line workers who are engaged in the construction safety issues addressed by the ACCSH on a daily basis, NAHB believes it is vital that the home building industry has representation on this influential advisory committee. NAHB's membership includes builders and remodelers of single-family homes, apartments, condominiums, and those engaged in other aspects of residential and light commercial construction. Over 80 percent of NAHB's members are classified as "small businesses" and our builder members construct about 80 percent of the new housing units, making housing one of the largest engines of economic growth in the country. Housing is central to American family life and critical to a thriving economy. In 2021 and beyond, NAHB expects that nearly 1 million single family homes will be constructed. Importantly, the residential construction industry collectively employs and is responsible for the safety of more than 4 million people nationwide, accounting for 40 percent of the entire construction workforce. Due to the breadth of issues addressed by ACCSH and the distinct and substantial differences between home building and heavy commercial construction and the other construction sectors regulated by OSHA, coupled with the number of regulatory activities frequently considered by OSHA that impact our industry and housing affordability, having a residential construction representative on ACCSH is critical. Appointing an NAHB member will guarantee that home builders' have a voice and better ensure that the viewpoints and opinions of the residential sector are considered prior to OSHA issuing any construction safety regulations. NAHB submits the following nominee for appointment to OSHA's ACCSH committee as an Employer Representative: Jerry D. Passman Owner and Corporate Secretary Passman Homes 4011 O'Neal Lane Baton Rouge, LA 70816 225-751-3727 jerrypassman@hotmail.com NAHB is an association of employers and Mr. Passman is well qualified to represent the viewpoints of employers in the home building industry and, as a builder, can properly advise OSHA on residential construction safety issues. ACCSH has not had representation of this critical industry sector since 2014 – an oversight that NAHB believes resulted in lost opportunities for both OSHA and the industry. Jobsite safety benefits from a collaborative and partnership approach between OSHA and its regulated entities and providing home builders a seat at the ACCSH table would ensure construction standards and agency policies will have the desired effect of improving the safety and health of all construction workers. Therefore, we urge OSHA to appoint NAHB's member candidate, Mr. Passman, to the ACCSH. If for any reason OSHA believes that Mr. Passman does not meet the criteria for appointment to ACCSH, NAHB would be happy to offer additional nominees for consideration for appointment as an Employer Representative. If you have any questions about this recommendation or need any further information on NAHB's nominated candidate, please do not hesitate to contact Robert Matuga, NAHB's Assistant Vice President of Labor, Safety and Health at 202-266-8507. Thank you in advance for your attention to this matter and your continued support…