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MSHA Should Change Its Single I.D. Number Policy

The Mine Safety and Health Administration (MSHA) policy of assigning single independent contractor identification (ID) numbers to commercial explosives companies who conduct blasting and other services at multiple mine sites has an unfair and inequitable impact on those companies.
Under current MSHA policy, if a parent corporation had ten subsidiaries separately formed and organized as LLCs operating in different regions... 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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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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Define "Suitable Facilites" for Emergency Eye/ Body Wash

Add notation that “suitable facilities” shall meet the requirements for emergency showers and eye/face wash equipment in accordance with ANSI Z 358.1. Also, that a “personal eye wash” does not meet the requirements of a quick drenching eye or body wash, but may be used while moving an individual to a suitable facility. Too often an eye wash bottle (personal eye wash) or standalone eye wash station not meeting the requirements... 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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Add Clarification to Reclassification of Permit Space

Add a sentence to clarify reclassification of a permit-required confined space to paragraph (c)(7) of 1910.146. A notation like, A permit-required space that has been reclassified using the procedures below becomes a permit-required space again once the hazards are reintroduced to the permit space. As it written, so many employers interpret this to be a one-time change which is permanent. That is that once the permit... more »

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Require Adm./Eng. Controls - Double Hearing Protectors- 100dBA

OSHA should mandate the use of administrative and engineering controls where technically and economically feasible at 100 dBA. In addition, where not feasible, OSHA should mandate the use of double hearing protection at 100 dBA. At this point, the OSHA Field Operation Manual directs officers to enforce administrative and engineering controls where noise exposures border 100 decibels . However, there is no parallel... more »

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Lower Action Limit for Occupational Noise from 85 to 80 dBA

OSHA should lower the action limit for occupational noise exposure from 85 dBA to 80 dBA. The European Union Noise Directive mandates 80 dBA as an action limit. Workers will still lose hearing exposed at 85 dBA and Hearing protectors are optional until levels reach 90 decibels. NIOSH notes that 1 in 12 workers will develop hearing loss exposed to 85 decibels and the risk does not approach zero until you get to 80 decibels.... more »

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Dialogue on the need for and right to use paid sick leave

Employees fortunate enough to have paid sick days sometimes report that management penalizes them for using the sick days to which they are entitled. During flu season each year, OSHA should use online communications and social media to remind employers that when sick workers use paid sick time to stay home and recover, it’s good for everyone’s health.

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Monetary penalties for workplace H&S violations

In 2012, OSHA made modest revisions to its policy for calculating proposed monetary penalties. OSHA has not required, however, the OSHA State Plan States to adopt this policy. There is wide disparity among the States on proposed penalties for serious, repeat and willful violations. For example, in 2013 the average proposed penalty in Maryland (a State Plan OSHA) for a serious violation was $685, compared to $1,916 in... more »

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OSHA's response to amputations and hospitalizations

Beginning January 1, 2015, employers operating in States under federal OSHA jurisdiction are required to report to OSHA, within 24 hours, all work-related inpatient hospitalizations, all amputations, and all losses of an eye. On a case-by-case basis, OSHA will determine whether to investigate such incidents. To facilitate accountability to the public and transparency, when OSHA decides not to investigate one of these... more »

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Threats to worker injury and illness reporting and data

DOL should issue a regulation prohibiting employer policies, practices, and programs that discourage the reporting of job injuries and illnesses. Employers, workers, governments, and the public need accurate data on work-related injuries and illnesses in order to identify their causes, implement controls, and assess their effectiveness. OSHA and MSHA should each issue a regulation that (1) requires employers to inform... more »

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Protect fracking workers from volatile hydrocarbons

OSHA should adopt a regulation to protect fracking workers who are exposed to volatile hydrocarbons and other toxic substances during flowback operations. OSHA’s existing standards are ineffective at protecting oil and gas extraction workers from this hazard. OSHA should issue a regulation based on NIOSH's recommendations for fracking operations. The regulation should include requirements for employers to develop alternative... more »

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