On March 26, the Construction Industry Safety Coalition distributed a press release (“New Study Finds that OSHA Officials Underestimated the Cost of Silica Rule for Construction Industry by $4.5 Billion a Year Adding to Growing List of Concerns about the Flawed Rule”). The press release in its entirety is posted below.
NRCA takes strong exception to the costs of compliance OSHA suggests in the proposed rule. A majority of roofing contractors in the U.S. employ 20 workers or fewer. In the notice and in its guidance documents for employers, OSHA states “the cost to a firm with fewer than 20 employees would average about $550 a year” to implement the provisions of the proposal. NRCA believes the cost is vastly understated, especially with regard to roofing operations involving the use of gas-powered hand-held masonry saws used to cut roofing tiles.
Setting aside the issue of dust-collection effectiveness, retrofit vacuum attachments for those saws cost approximately $160 for the lowest-cost equipment (Saw Muzzle, made by Dust Collection Products, San Diego, Calif., has a suggested retail price of $159.95), and new portable saws with integrated dust collection capability range from about $800 to $2,000.
Specialized vacuums equipped with HEPA filters generally cost in excess of $300, and HEPA filters alone can cost more than $100 each. Other accessories may be required to implement rooftop dust collection, for example, auxiliary hoses and connectors. The basic equipment needed to outfit just one roofing crew for the dust collection equipment alone, would far exceed OSHA’s estimate of total compliance costs for the company.
And still to be included are costs for air monitoring, medical surveillance, recordkeeping and respirators if those are required. This wide disparity between the costs projected by the agency and actual equipment costs in this narrow category brings into question the value of the entire data set provided by OSHA in its Preliminary Economic Analysis used as a foundation for the rulemaking.