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Start enforcing noise regulations

The OSHA regs on noise control dictate that engineering controls be applied to reduce noise levels, as feasible, when exposures exceed 100% - but too many employers fail to realize how the costs of noise remediation can be less than the administration of a hearing conservation program for several years. The other thing is that the use of hearing protection deprives the worker of one of his senses, thus creating a hazard... more »

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Testing Grounding Systems

The Industrial Minerals Association – North America (IMA-NA) would like to see MSHA’s regulations at 30 CFR 56/57.12028, regarding annual verification testing for electrical grounding systems, revised. The rule provides:

Continuity and resistance of grounding systems shall be tested immediately after installation, repair, and modification; and annually thereafter. A record of the resistance measured during the most... more »

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Revision of 1910.212

29CFR 1910.212 is the general guarding clause that applies to all machinery. We now have a solid ANSI standard which should be applied - ANSI B11.0 "Risk Assessment and Reduction for Machinery." This would require that a risk assessment be performed by the manufacturer and user of the machine, that APPROPRIATE safeguarding means be used based upon the intended use, and any RESIDUAL RISK be properly communicated to the... more »

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Remove "1965" and Instead Reference CGA P-1

Remove “1965” in the language “Compressed Gas Association – 1965” of paragraph (b) of 1910.101. Instead, have it state that it shall be installed and maintained in accordance with Compressed Gas Association P-1. It currently requires compliance with a consensus standard that is 50 years old.

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Prohibit Lifting Loads Over Employees

Change 1910.179(n)(3)(vi) "The employer shall require that the operator avoid carrying loads over people." to read "The employer shall prohibit the operator from carrying loads over people." As it stands it is only a suggestion since it reads "avoid” acting as a should and not a shall. Workers have been seriously injured including fatal injuries when loads have broke free dropping on them. All of which could have been... more »

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EEOICPA Notification to Claimants

• Consider requiring the OWCP to automatically and timely provided to the employee any written medical documentation, contemporaneous records, and other records or documents obtained or generated by the OWCP and not submitted by the employee or their representative that the OWCP has relied on to render a decision on medical benefits. This includes directed medical exam (medical second opinion) reports, district medical... more »

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Updating the methods for estimating adequacy of HP attenuation

Individual fit-test methods are a potential tool for education, training, and measuring/documentation of individual hearing protector attenuation ratings; however, more studies are required to support specific recommendations on the use of fit-test systems. The US Air Force representatives of the ANSI WG 11 request the allowance of the methods described in ANSI S12.68 for use in estimating the adequacy of hearing protector... more »

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DOL Should Update and Modernize PERM Regulations

There are a number of aspects of the PERM regulations (Program Electronic Review Management used in the Labor Certification process for permanent residency sponsorship by employers) that continue to require revision, so they are updated and modernized, none of which have been addressed since the 2011 regulatory review process:

20 CFR Part 656 currently has no agency timelines for adjudications, audits or appeals. When... more »

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Safety Belts and Lines

The Industrial Minerals Association - North America (IMA-NA) suggests that MSHA’s fall protection standard be updated to advise against the use of safety belts as an acceptable form of personal protection against falls. OSHA long-ago made this change as evidenced in 1926.502(d): "Personal fall arrest systems." Personal fall arrest systems and their use shall comply with the provisions set forth below. Effective January... more »

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OSHA Should Abandon Its Opposition to Incentive Programs

In a memo to field staff on March 12, 2012, OSHA established a new policy that incentive programs wouild constitute a violation of the whistleblower protections under Section 11(c) of the OSH Act. The agency provided no data, no studies, no reports to support this position--only its belief that these programs suppress employees from coming forward with injuries or hazards. If OSHA believes this, the agency must conduct... more »

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29 CFR 1904 interpretations regarding antibiotics

Recommend that the interpretation regarding the administration of prophylactic antibiotics following tick bites be changed, so that it is consistent with the interpretation regarding tetanus vaccinations. Administration of prophylactic antibiotics following tick bites is currently interpreted to be medical treatment. This interpretation may discourage the administration of post-bite antibiotics and thereby possibly... more »

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Update Standard for Storage of Ammonium Nitrate

The Institute of Makers of Explosives (IME) supports the existing ammonium nitrate (AN) standard at 29 CFR 1910.109(i), but recommends that it be modified to include; (i) a prohibition on the use of wooden storage bins, (ii) an instruction that fires involving AN should not be fought (our recommendation against fighting AN fires is aimed at offsite first responders, not to trained, in-house fire brigades that respond... more »

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Require Paystubs for All workers

There is currently no federal requirement that employers give workers paystubs. As many as 20 million U.S. workers do not receive documentation that outlines how their pay is calculated or what deductions were taken from their wages. It is often the case that those who do not receive paystubs are the ones most likely to be victims of wage theft.

The U.S. Department of Labor already requires employers to keep records... more »

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OFCCP Should Withdraw Its Proposed Employee Compensation report

The Office of Federal Contract Compliance Programs has published an NPRM which would require federal subcontractors to submit to the federal government employee summary compensation data collected in an “Equal Pay Report” (EPR). (Though the rule is not yet final, we include it in this submission because the comment period has closed (as of January 5, 2015) and the RFI only prohibits review of “DOL rulemakings currently... more »

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