Coalition Comments Opposing OSHA’s Walkaround Rule

ARTBA and its allies in the Construction Industry Safety Coalition sent a letter to the Assistant Secretary Occupational Safety and Health Administration (OSHA) at the U.S. Department of Labor regarding the Notice of Proposed Rulemaking (“NPRM” or the “proposed rule”) concerning the Worker Walkaround Representative Designation Process. The letter expressed the following concerns:

• The NPRM creates unique risks for multi-employer construction jobsites.
• The proposed rule is unnecessary because current regulations already provide for employee participation.
• The proposed rule conflicts with longstanding agency guidance and the purposes of the OSH Act.
• The NPRM conflicts with the NLRA.
• The NPRM is unconstitutionally vague.
• The NPRM offers no clarity on what authority or access third parties allowed into inspections have.