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On Jan. 26, ABC, as a steering committee member of the Construction Industry Safety Coalition, submitted comments on the U.S. Department of Labor’s Occupational Safety and Health Administration’s Advance Notice of Proposed Rulemaking on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. CISC members feel strongly that a regulatory approach—if adopted—must be simple and should integrate the key concepts of “Water, Rest, Shade.”

“While the CISC appreciates OSHA’s rulemaking in this area and the hazards associated with working in extreme heat, the CISC has significant concerns with any regulatory approach that imposes complicated requirements on contractors and requirements that are triggered by threshold temperatures that are common in wide swaths of the country for much of the year,” CISC wrote to OSHA. “Because the construction environment is ever-changing and fluid, any regulatory approach must be simple and adaptable. For the same reasons, the CISC encourages OSHA to consider a separate regulatory approach for the industry, as OSHA has done in other rulemakings, such as for Respirable Crystalline Silica.”

Areas of discussion in CISC’s comments include:

• The construction industry has taken proactive measures to protect workers from heat injury and illness.
• OSHA must actively engage with the Advisory Committee for Construction Safety and Health on any rulemaking and conduct a Small Business Regulatory Enforcement Fairness Act panel.
•   Existing state standards are cumbersome, confusing and ineffective.
•  An 80-degree trigger is impractical.
•  Acclimatization must also be considered for any trigger.
•   Any regulatory approach must be simple, incorporating the concepts of “Water, Rest, Shade.”

CISC looks forward to working with OSHA on this important issue in the future.