In the letter CISC stated “Construction employers across all trades are finding compliance extremely difficult if not impossible for many job tasks.” The letter goes onto to say that Table 1 is not a workable compliance option for many employers in the industry, which means employers have to follow the traditional method of measuring exposure and implementing the hierarchy of controls. CISC states, “This is almost impossible, however, considering the myriad of exposure environments involved in construction and that laboratories may not be in compliance with the analytical requirements of the standard until 2018.”
The current compliance deadline for the construction industry is June 23, 2017, except for requirements for laboratory evaluation of exposure samples, which begin on June 23, 2018.
ABC along with several national construction organizations are challenging the rule in the U.S. Court of Appeals for the D.C. Circuit. ABC will continue to update members on any developments regarding the legal challenge through Newsline.
For more information on the Silica Final Rule: