NSSGA Comments on MSHA's Proposed Silica Rule
On July 13, 2023, The Mine Safety and Health Administration (MSHA) published a proposed rule, “Lowering Miners' Exposure to Respirable Crystalline Silica and Improving Respiratory Protection.” The National Stone, Sand and Gravel Association (NSSGA) and our member companies have carefully reviewed and analyzed the proposed standard. We respectfully submit the following comments, which include issues, recommendations, and most importantly, rationale backed by research and data. NSSGA represents the nation’s crushed stone, sand and gravel (aggregates) companies, industrial sand companies and the manufacturing and services providers who support the industry. NSSGA has over 450 member companies and represents over 9,000 operations with over 100,000 employees. Furthermore, according to MSHA data, in 2022 there were roughly 12,500 mines in the US and over 75% are aggregate or industrial sand facilities, meaning aggregates make up three quarters of MSHA’s entire portfolio.