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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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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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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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Hearing Conservation - Medical Surveilance

Change 1910.95 (g) from "...making audiometric testing available to all employees ..." to requiring audiometric testing to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels.
Some employers may encourage employees to opt out of medical surveillance as a means of deferring cost. It seems rational that an employee would want to have their hearing testing where they are overexposed,... more »

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Geographic Preference & Pre-existing Conditions

Do away with the geographic preference and aggravation of pre-existing conditions. When a 60 year old with arthritic, degenerative disks in her back and a bad knee has an injury from doing nothing, it should not be a work related injury. I know OSHA says recordable injuries do not equate to fault, but unfortunately, corporate America loves to view them this way and assign fault which creates its own problems.

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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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Clarify- Single Valve is Not an Isolation Device in 1910.147

Add notation to 1910.147, Lockout/Tagout, Energy Isolation device definition such as, A single valve does not meet the requirements of an isolating device since it cannot prevent the transmission of hazardous energy. In addition, the device must achieve positive isolation including, but not limited to double block and bleed, blank or blind, or misalign or remove sections of pipe. The confined space standard makes it... more »

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Require Reclassification Certificates be Maintained 1 year

Add requirement to maintain written certification of reclassification for one year consistent with requirements for confined space entry permits. The permit space standard requires that you document the basis of reclassification, but does not require that you maintain the record. When assessing compliance with this requirement, there is no means of confirming the written documentation, if it is immediately destroyed.... 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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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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OSHA HazCom 2012 & Small Container Labeling

One of the most difficult issues for fragrance companies like mine, and for a number of other industries, is the treatment of small or sample sized products under the Hazard Communication Standard. While other jurisdictions like Canada and the European Union allowed for special accommodation for small bottles, OSHA has not allowed for an exemption. The result is a new, arduous, costly and incredibly burdensome process... more »

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Earplug Fit Testing and 1926.101 (b)

The practices of in-ear dosimetry and individual hearing protection fit testing should be considered an appropriate alternative as an individualized fitting and hearing protector effectiveness per CFR 1926.101, the Construction Safety Standard. Specifically, individual hearing protection fit testing meets the requirement on 1926.101(b) “Ear protective devices inserted in the ear shall be fitted or determined individually... 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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