About the proposed rule

The rule would lower worker exposure to crystalline silica – a substance that causes cancer, silicosis, chronic obstructive pulmonary disease and kidney disease in those who are exposed to it.

The rule includes two separate standards—one for general industry and maritime employment, and one for construction. The amount of silica exposure allowed for general industry and maritime workers would be cut in half. The change in exposure limits for the construction industry would be even more drastic: an 80 percent decrease.

The agency predicts that the new rule will save 700 lives and prevent 1600 new cases of silicosis each year.

OSHA’s proposal to safeguard workers by reducing silica exposures disregards “the unique nature of roofing work” and may actually making roofers’ jobs more dangerous, according to the National Roofing Contractors Association (NRCA).

Roofing work unique

“These new regulations may present far greater hazards to the safety and health of our nation’s roofing workers,” according to NRCA executive vice president William Good. “The paramount concern for worker safety in the roofing industry as always will be the prevention of falls, which continue to be the leading occupational cause of death for roofing workers. In this regard NRCA strongly believes OSHA’s proposal is dangerously deficient with respect to the roofing industry’s workforce and ignores the unique nature of roofing work.”

Good said that most roofing workers will not be exposed to silica dust created by roofing operations.

“In some instances however, during the installation of concrete or clay tiles, or concrete pavers, powered cutting of that material may result in exposures. While protecting workers exposed to silica during those operations is of paramount importance to NRCA, it must be achieved while taking the risk of falls into consideration.

Competing for space

In contrast to other trades performing “selected construction operations” as described by OSHA, roofing workers who cut concrete or clay tiles most often perform these tasks on an elevated, steep-sloped roof surface. Material staging on a typical concrete or clay roofing project results in limited space on the roof for additional equipment that competes with fall protection equipment– in particular lifelines – required for worker safety.”

Good said his organization believes that OSHA “has narrowly viewed feasible engineering controls only with regard to the silica-producing task and has ignored the nature of the surrounding workplace and the hazards it may present that are more dangerous and immediate than the silica exposure.”

The NRCA is urging OSHA to withdraw the current proposal and work with the roofing industry to develop silica control measures that address fall protection and other safety risks that are unique to roofing.