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PSM - Mechanical Integrity

Add an additional section to 1910.119 (j)(1) as “vii – Any equipment critical to the integrity of the process and/or safety and health of employees.” As it stands now the applicability of mechanical integrity only covers six types of equipment listed with no catch-all for equipment that may be used to control, minimize, or mitigate the unwanted release of highly hazardous materials. For instance, water spray may be commonly... 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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Information Collection - Voluntary Survey Burdens

One of the questions posed as part of the Shaping Smarter Regulations campaign is concerned with information collection. While BLS collections are not mandatory, the Agency is required to include the estimated paperwork burdens of its various programs within the overall DOL paperwork budget. Unfortunately, the calculations presented in the BLS' ICR filings with OMB/OIRA do not address burden distribution. For example,... more »

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Fit Check Science technology validates & corrects HPD's

Urgent necessity of vast improvements are needed at least in the form of "Hearing Fit Check" science to the Appendix B of CFR 29, 19.10.95 Fit Check testing for hearing is as important as respiratory fit check testing is Law.
This past year I used a field fit check system(technology won the "Anwar-Bullard" science award for innovation). meeting ANSI ambient sound standards level at 1000 hz and above in the field(forestry),... 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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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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Introduce Current FMLA Reporting to Technology

Often, FMLA practices are not appropriately administered. Many of you might even have heard the term "Friday Monday Leave Act," instead of the real purpose of that acronym, being Family Medical Leave Act. Definitely, this could be handled differently at any given facility, and even within each facility. Employers will often save D.O.L. templates and re-use them without verifying if there have been any updates within the... 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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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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president/ceo

This is the 21st. century, isn't time that OSHA establish a hand cart safety measure for the thousands of employees that work with in the beverage industry? Keg Caddy is by far the safest means of transporting keg and case beverages. Ergonomically designed handle system will help to reduce stress on the back, shoulder, groin and wrist area. It also features a patented locking device which will prevent a keg from shifting... 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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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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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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DOL Regulations

As an HR professional for over 35 years, my biggest frustration is each sub-department/committee (OFCCP vs EEOC vs DOL overall) in the DOL has their own requirements for eligibility; in particular the number of employees (full-time vs part-time) and duration for records retention. Could the DOL review eligibility requirements and try to standardize just to make it easier to understand?

 

Thanks.

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