When the Occupational Safety and Health Administration (OSHA) announced its final rule on respirable crystalline silica in March, it drew much contempt from the many construction trades, including those representing the C&D recycling and demolition segments of the industry. While it certainly means an increase in the monitoring of dust and mitigation efforts for those in these industries, many, including William Turley, the executive director of the Construction and Demolition Recycling Association (CDRA), say it could have been a lot worse.
The proposed rule in its initial form would have been much more difficult, if not impossible for the construction industry to abide by. When this proposed rule came out a few years ago, the construction industry trade groups were very smart about how they addressed their concerns. They formed the Construction Industry Safety Coalition (CISC), made up of 25 trade associations that represent all sectors of the construction industry, including commercial building, heavy industrial production, home building, road repair, specialty trade contractors and material suppliers. The CISC submitted hundreds of pages of comments in response to OSHA’s proposal, and while the 1,700-plus page final rule didn’t address all the industry’s concerns, it did accomplish something major. It shows what can get accomplished when an industry groups with similar interests band together to show solidarity for an issue that matters to them.
Earlier versions of the proposed rule would have increased compliance costs by billions of dollars and put what many agreed were not achievable part-per-million requirements in place for the construction industry. It appears now that following certain already widely used practices will keep contractors and recyclers in compliance without having to greatly alter their operations.
The final rule may still be a far cry from what some construction industry groups were hoping for, many of whom claim none of these changes were necessary to keep workers safe. While the construction industry groups will continue to challenge the final rule, I would consider the efforts of the CISC far from a failure. Certainly OSHA did take some of their recommendations under consideration as is reflected by the final rule. And as the rule goes into implementation or the courts decide it won’t, the industry should be proud of its efforts which were not ignored. By consolidating efforts and joining forces into one voice, the industry had a better chance of being heard.
This is a model that could help with other issues that will inevitably come down the pipeline threaten the viability of the industry. As we head into election season, perhaps this can be a lesson for us all that we can affect change. By showing solidarity and banding with like-minded individuals who share the same interests, those in positions of power will be more likely to listen.