We can take some comfort, I suppose, in the fact it could have been a lot worse.
The Occupational Safety and Health Administration (OSHA) has been working on a rule to regulate worker exposure to silica for a long time, and it became clear OSHA head David Michaels wanted to see the rule completed before his term expires at the end of this year. He did it, and it will be his legacy. OSHA's final rule was issued March 25; it goes into effect June 23; and it will be enforced beginning June 23, 2017.
As is usually the case, we learned a lot of lessons through the rulemaking process—some good, some less than good and many reminding us how frustrating the process can be.
As is required in all federal rulemakings, the public was invited to comment and testify at OSHA hearings. NRCA did both, and we take some satisfaction in knowing we were heard. For example, the rule's preamble discusses the impracticality of using wet saws on roofs (though the final rule, in effect, requires them).