NRCA Testifies about OSHA’s Proposed Crystalline Silica Rule

The National Roofing Contractors Association (NRCA) provided testimony on the Occupational Safety and Health Administration’s (OSHA) proposed rule to amend its existing standards for occupational exposure to respirable crystalline silica. The testimony was part of a three-week public hearing process held by OSHA.

“In roofing, as OSHA understands very well, our overriding safety concern is falls. The best safety practices in the industry include keeping roofing workers away from the edge of the roof, protecting them from tripping on the roof, and minimizing their trips up and down ladders,” said NRCA Executive Vice President William Good, who testified on behalf of the association. “Unfortunately, we fear the new rule will dramatically increase the risk of falls, because of the nature of roofing work.”

Good explained that in the roofing industry, silica exposures are limited to operations where tile roofs are being installed because the tiles need to be cut to fit in place on the roof. The proposed rule’s engineering controls would require roofing workers to either use wetting or vacuuming, both of which could introduce new tripping hazards because they involve placing hoses on rooftops. In addition, wetting would result in slippery tiles, which is particularly dangerous on steep-slope roofs.

Visuals of a typical tile roofing job site were presented during Good’s testimony to illustrate NRCA’s concern.

“Ours is a unique industry with unique hazards, and a one-size-fits-all approach to reducing silica exposures not only won’t work for us but will likely, in fact, create other hazards that are more immediate and life threatening,” Good continued.

OSHA’s public hearing on the new crystalline silica rule is scheduled to conclude April 4.

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