Last year, in recognition of our abilities on regulatory matters, SWACCA was honored with membership in the Construction Industry Safety Coalition (CISC). CISC is a construction industry-wide health and safety consortium that spans the entire construction industry—union and non-union—that works on health and safety matters of common concern across the industry. For the last several months, SWACCA has worked with CISC on a joint comment letter on the Occupational Safety and Health Administration’s proposed rule regarding Heat Injury and Illness in Outdoor and Indoor Work Settings, on which SWACCA has been engaged since our submission of joint comments with the Association of the Wall and Ceiling Industry (AWCI) on OSHA’s advance notice of proposed rulemaking in January 2022.
The joint comment letter urges OSHA to develop a construction-specific standard instead of the one-size-fits-all approach of its proposed rule. The letter also details the types of job tasks, the work performed, and even the environmental conditions in which construction industry employees work that warrant a construction-specific standard as OSHA has done on other health and safety issues.
The letter also highlights significant issues with the proposed rule, including: (1) the rule’s unworkable proposed heat triggers; (2) the overly prescriptive requirements of the proposed rule; (3) the need for greater flexibility in the acclimatization procedures for new and returning workers; and (4) the need to simplify the proposal’s training requirements.
The comment letter is available here. SWACCA is already engaged with transition team for the incoming Trump Administration over our concerns about this proposed rule.