Constructive Critique of OSHA’s Crystalline Silica Proposal

by Susan E. Dudley, Director

December 09, 2013

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In a public comment filed on the Occupational Safety and Health Administration’s (OSHA’s) proposed standards for occupational exposure to respirable crystalline silica, Professor Andrew Morriss and I recognize that OSHA faces multiple challenges in devising a regulatory approach that will meet its statutory goal of reducing significant risk. However, we find that the greatest challenge to reducing risks associated with silica exposure is not lack of will (on the part of employers or employees) but rather lack of information. Our analysis concludes that OSHA’s proposed rule will contribute little in the way of new information, and indeed, may stifle the generation of knowledge by precluding flexibility for experimentation and learning.