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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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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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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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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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Individual fit-testing & in-ear dosimetry for App. B of 1910.95

The practices of in-ear dosimetry and individual hearing protection fit-testing should be considered an appropriate alternative as an individualized safety factor for the purposes of evaluating hearing protector effectiveness per Appendix B of 29CFR 1910.95.
At the time that 1910.95 was promulgated, in-ear dosimetry and individual fit testing of hearing protection in the field were not feasible. However, now several... more »

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Safe Patient Handling

OSHA needs to do a safe patient handling regulation. Healthcare workers are injured at a very high rate when manually lifting and repositioning patients. This is the single biggest cause of injury in one of the largest industrial sectors and the agency should act. NPR just did a 4 part series on the problem and several states already have their own regulations. This problem will only get worse with an aging workforce,... more »

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Personal Attenuation Rating

3M requests allowance of the Personal Attenuation Rating (PAR) as a viable and potentially more protective alternative to use of the NRR in order to comply with the following:
- CFR 1910.95(g)(8)(ii)(B): determine appropriate attenuation for workers who experience Standard Threshold Shift
- CFR 1910.95(i)(3): identify a variety of suitable hearing protectors with appropriate attenuation
- CFR 1910.95(i)(5): ensure proper... more »

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Work environment for meatpacking and poultry processing workers

OSHA’s existing standards are ineffective at protecting meatpacking and poultry processing workers from developing carpal tunnel, tendonitis, and other work-related musculoskeletal disorders. The pace, repetition, and design of work on production lines in most meatpacking and poultry plants are the key risk factors for worker injuries. In September 2013, the Southern Poverty Law Center and a coalition of civil rights... more »

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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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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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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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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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Emergency Action Plan scope

Revise the scope of 1910.38(a) to include all businesses with 10 or more employees. The current scope is limited to only where another standard demands it. However, the hazards associated with fire and other emergencies effect more than this standard covers.

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Worker exposure to well-recognized health and safety hazards

OSHA has insufficient (or non-existent) regulations to address workers’ exposure to well-recognized hazards. OSHA should issue a final regulation to protect workers from respirable crystalline silica before the end of the Obama Administration. OSHA should publish proposed regulations on beryllium, combustible dust, communication towers, diesel exhaust, heat stress, fatigue, infectious diseases, and workplace injury and... more »

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Hearing protector attenuation testing best practices 40 CFR 211

40 CFR 211.206 requires testing to out of date ANSI standard. The burden of testing to establish real ear attenuation performance must remain, however updating to allow current standard methodologies to be used will allow for the possibility of one data set to be used for international requirements.
Expand allowable real ear testing at threshold attenuation data to be obtained by the latest version of the applicable... more »

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