On June 18, NRCA provided testimony at the Occupational Safety and Health Administration’s informal public hearing regarding the agency’s proposed heat injury and illness prevention standard. Along with many other stakeholders in the construction industry, NRCA voiced strong concerns about the feasibility and real-world implications of the proposed rule, particularly for small and mid-sized businesses.
The testimony, delivered by NRCA Vice President of Enterprise Risk Management Cheryl Ambrose, emphasized the unique nature of roofing work and the need for a flexible, risk-based approach to heat safety.
“While we share OSHA’s goal of protecting employees from heat illness, the proposed rule contains numerous overly prescriptive compliance requirements, severely underestimates regulatory costs, and fails to provide the flexibility that small employers need to effectively comply with the standard,” stated the testimony. “Based on our members’ collective experience, no one set of policies or procedures fits all.”
NRCA highlighted several key issues with the proposed rule, including the need for maximum flexibility and a performance-based standard; the onerous full-time monitoring responsibilities; and initial and high heat trigger temperatures that are too low and do not account for local environmental conditions. According to NRCA, many of these requirements would be unworkable and could divert resources away from other critical safety initiatives.
Instead, NRCA urged OSHA to adopt a performance-based standard that allows employers to tailor heat safety protocols to the conditions and hazards faced by their workforce. The association cited successful industry practices—such as voluntary heat stress training, rest and hydration breaks, and job-site-specific hazard analysis—as more effective and realistic than prescriptive regulatory mandates.
The roofing industry has long recognized the risks of heat exposure and continues to invest in education, prevention and best practices. By participating in the hearing, NRCA reaffirmed its commitment to working with OSHA, and NRCA urges the agency “to revise the proposed rule and adopt a reasonably tailored, flexible, performance-oriented standard for managing heat hazards in the construction industry.”
NRCA will provide post-hearing comments to OSHA, which are due Sept. 30, to address specific questions posed by OSHA during the testimony and reaffirm our positions. As OSHA moves forward with the rulemaking process, NRCA will continue to advocate on behalf of its members and promote workable solutions that safeguard workers while supporting the essential work of the roofing industry.
You can access NRCA’s June 18 testimony and all past and upcoming testimony regarding OSHA’s proposed heat rulemaking at www.osha.gov/heat-exposure/rulemaking.
