Regulations.gov #:  05-11149
Comment #:          EREG-4
Submitted:          
Author:             Bogdan, Kenneth
Organization:       ASSE New Jersey
City:               
State:              
Country:            
Docket:             H023
 
COMMENT:            
Having worked for many years for as a safety director for a demolition contractor I found that the standard relies to heavily on the use of respiratory protection. I believe contractors would benefit from better guidance on the use of feasible engineering controls such as the use of vacuums or ventilation systems. 

The process of issuing respirators, providing medical surveillance and training to employees in construction can be difficult for contractors because many of these employees work for them on a short term basis. Most contractors simply will not invest the time.


Kenneth Bogdan, CSP
ASSE/NJ Construction Chairperson


 
