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Shaping Smarter Regulations

Clothes Cleaning Booth Technology - Compressed Air

The Department of Labor (DOL), specifically the Mine Safety and Health Administration (MSHA), should modify, streamline, expand or repeal 30 CFR § 56.13020 Use of compressed air, which currently prohibits the introduction and utilization of technology designed and developed by the National Institute for Occupational Safety and Health (NIOSH) to safely clean dust-soiled work clothes. Contaminated worker clothing has... more »

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Substantive Correction of 29 C.F.R. § 785.36

The opening sentence of Section 785.36 currently says, "There may be instances when travel from home to work is OVERTIME [emphasis added]." I submit that the sentence should conclude with the word "worktime", as it did for many years.

My research has not disclosed why or exactly when the change from "worktime" to "overtime" occurred. So far as I have been able to determine, "worktime" was used in and before 1971, but... more »

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Additional Testing for Black Lung

DCMWC currently only uses spirometry testing in Black Lung claims. These tests only show expiratory lung deficits. Lung volumes and diffusions need added to testing to adequately determine a miner's disability. Is there any reason these tests are not included? The regulations desperately need updated.

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Better DOL Wage and Hour Investigator Training

Recently there has been A few Davis Bacon Act investigation cases from out of the Norfolk W&H Division office. One reached a ridiculous conclusion. It involved an electrical contractor and a new school project. From start to finish it had 8 electricians which comprised of 3 electricians and 5 were classified as laborers. The investigators ruling of no violations was absurd. I realize this lady does not know anything about... 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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Uniform Guidelines on Employee Selection Procedures (1978)

The regulations at 41 CFR 60-3, Uniform Guidelines on Employee Selection Procedures (1978), need to be updated. Numerous improvements advancements in Industrial/Organizational Psychology, and the associated statistical analysis tools have been made since the regulations were last updated four decades ago. Another factor is that employers have introduced new technology into the selection process which is not explicitly... 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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