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Shaping Smarter Regulations

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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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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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40 CFR 211.206 requires testing to out of date ANSI standard.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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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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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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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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Perm Reform

Re: Retrospective Review and Regulatory Flexibility, published at 80 Fed. Reg. 5715-5716 (February 3, 2015); Docket Number DOL_FRDOC_0001-0392

Intel Corporation (Intel) appreciates the opportunity to submit these comments about PERM modernization. Intel participates in the Council for Global Immigration (CFGI) and also supports the comments it is providing about PERM and other topics.

Intel is a cornerstone of America’s... more »

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29 CFR 1904 interpretations regarding antibiotics

Recommend that the interpretation regarding the administration of prophylactic antibiotics following tick bites be changed, so that it is consistent with the interpretation regarding tetanus vaccinations. Administration of prophylactic antibiotics following tick bites is currently interpreted to be medical treatment. This interpretation may discourage the administration of post-bite antibiotics and thereby possibly... 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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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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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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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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Updating the methods for estimating adequacy of HP attenuation

Individual fit-test methods are a potential tool for education, training, and measuring/documentation of individual hearing protector attenuation ratings; however, more studies are required to support specific recommendations on the use of fit-test systems. The US Air Force representatives of the ANSI WG 11 request the allowance of the methods described in ANSI S12.68 for use in estimating the adequacy of hearing protector... more »

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Prohibit Lifting Loads Over Employees

Change 1910.179(n)(3)(vi) "The employer shall require that the operator avoid carrying loads over people." to read "The employer shall prohibit the operator from carrying loads over people." As it stands it is only a suggestion since it reads "avoid” acting as a should and not a shall. Workers have been seriously injured including fatal injuries when loads have broke free dropping on them. All of which could have been... more »

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Revision of 1910.212

29CFR 1910.212 is the general guarding clause that applies to all machinery. We now have a solid ANSI standard which should be applied - ANSI B11.0 "Risk Assessment and Reduction for Machinery." This would require that a risk assessment be performed by the manufacturer and user of the machine, that APPROPRIATE safeguarding means be used based upon the intended use, and any RESIDUAL RISK be properly communicated to the... more »

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