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Comments #7
Gilbane
7 Jackson Way
Providence, RI 02903

Telephone 401-456-5458
Facsimile 401-456-5516

December 1,1998

Mr. Felipe G. Devora
Fretz Construction Company
6301 Long Drive
Houston, Texas 77207-6784

Re: OSHA Multi-Employer policy

Dear Felipe:

When we were at the ACCSH meeting discussing the draft policy on multi-employer you had suggested that proposed wording representing the Construction Manager viewpoint be provided to you. Well here it is.

All of us agree that if we expose employees to violations that we should be cited. We all agree that if we cause the hazard or have the contractual right to correct the hazard, we should be cited. Where the difference exists is when there is no contractual relationship between the Construction Manager and the contractor employers.

Please consider this for the next deliberations of the ACCSH workgroup. I will not be able to attend due to the AGC meeting in Atlanta. Thank you for your consideration.

Yours truly,


[Signature]
John P. O'Donovan
Corporate Safety Director

Enclosure: Response to draft OSHA multi-employer policy
cc: Robert Wilson, CMA; C. Heinlein, AGC

An Equal Opportunity-Affirmative
Action Employer


[Stamp indicating this document was received by the Fretz Construction Company on Dec - 4 1998]