Coalition Comments on MSHA Silica Proposal

As part of the Construction Industry Safety Coalition (CISC), ARTBA and its allies sent a letter to the Assistant Secretary of Labor at the Mine Safety and Health Administration (MSHA) regarding its proposed rule titled, “Lowering Miners’ Exposure to Respirable Crystalline Silica and Improving Respiratory Protection.” The coalition offered the following comments:

• Compliance requirements must be bifurcated between underground and above-ground mines.
• Surface mining activities should follow OSHA’s existing silica standard.
• OSHA’s Table 1 controls are sufficient to provide protection from crystalline silica.
• Construction performed at mine sites should fall under the OSHA silica standard.
• The proposed rule must adequately address the use of portable crushing equipment, typical of small business surface quarrying operations.