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The minutes found in the body of this document have not been officially approved by the full committee.
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
U.S. DEPARTMENT OF LABOR
Frances Perkins Building, Rooms N3437 - BC&D
The meeting was called to order by the Chairman, Mr. Timothy Nichols, at approximately
9:15am. He welcomed the committee members and the public and pointed out that Mr. Swanson
would be the designated Federal Official for ACCSH. A listing of ACCSH members and OSHA
contact personnel is appended to the end of these minutes. After announcing that time
would be made available for public comment in the afternoon session, Mr. Nichols
introduced the Assistant Secretary of Labor, Mr. Charles Jeffress. A list of members
attending this meeting is at the end of this document.
Mr. Jeffress thanked the committee members for undertaking the service inherent
in their participation and stressed the importance of the advisory committee in providing
input in the formulation of policy. He highlighted the importance of implementing the OSHA
Strategic Plan, especially the goal of reducing workplace injury by 15% by 2002, and the
changes in our way of doing business inherent in the increased emphasis on measurement. In
addition, he pointed out that, while construction fatalities have fallen below the
manufacturing fatality rate, he has set a goal of reducing construction fatalities by 15%
by 2002. Mr. Jeffress also stated that he wants to push ahead on construction standards
and to put special emphasis on addressing demonstrated problems with a variety of
innovative solutions. He discussed how the issue of ergonomics affects the construction
industry but pointed out that there are differences in how ergonomics should be addressed
in the construction industry, in contrast with the manufacturing industry.
Mr. Jeffress brought up the issue of clarifying the Personnel Protective Equipment
(PPE) standard in light of the Review Commission's "Union Tank" decision
vacating a citation for not providing PPE. The legal arguments in this case hinge on the
interpretation of the meaning of the word "provide" in section 1910.132(a).
Specifically the question is whether "provide" means "pay for." [The
18 October 1994, "Stanley memorandum" gave guidance attempting to clarify when
employers are required to pay for "worker-provided" PPE. While specifying that
employers are required to pay for PPE, an exception was constructed such that "where
equipment is very personal in nature and is usable by workers off the job, the matter of
payment may be left to labor management negotiations." Examples of this were given,
including "non-specialty safety glasses, safety shoes, and cold weather outerwear of
the type worn by construction workers" in cases where contamination does not render
the equipment unsafe for off-site use. The "Stanley memorandum" further stated,
"Failure of the employer to pay for PPE that is not personal and not used away from
the job is a violation and shall be cited." Although referring to the "Stanley
memorandum" and a 1995 OSHA instruction (STD 1-6.6) among other documents, the
Commission did not agree that adequate foundations had been articulated for "the
change in interpretation," and thus vacated the citation.] Since the Review
Commission decision renders the "Stanley memo" unenforceable, rulemaking is
necessary to resolve the issue. Mr. Jeffress announced that a proposed standard regarding
employer responsibility to pay for PPE would be briefed by John Martonik immediately after
his remarks and that the new rule would, in essence, formalize the guidelines enunciated
in the "Stanley memorandum." He further stated that he was requesting an
immediate response from ACCSH.
Mr. Jeffress went on to ask ACCSH for advice and recommendations on how to recognize
excellence in construction safety and health, particularly for small contractors and short
term jobs of less than one year's duration, stating that the Star Program is not well
suited to the construction industry. He indicated that ACCSH would be briefed on a
demonstration program the second day of the meeting.
Mr. Jeffress also requested that ACCSH formulate a strategy to enhance the
effectiveness of the inspection program by investigating targeting methodologies to
identify high risk sites for attention and assistance in compliance.
In response to a call for questions/comments by Mr. Jeffress, Mr. Cooper stated
that the problem of how to best identify construction sites for prioritized inspection has
not been resolved and that perhaps ACCSH should investigate how using site specific data
and employer specific data could help.
Mr. Smith pointed out that carpenters and painters appeared to have the
potential for Musculo-Skeletal Disorders because of the repetitive nature of much of the
work they do, even though problems in this area may not have shown up in the data yet.
Mr. Burkhammer stated that an excellence program had been developed some years
ago but that he had indications that OSHA did not think that it would work. He asked why.
He also pointed out that volumes of data on Musculo-Skeletal Disorders have been collected
by ACCSH and that some of that had been presented at Stakeholder meetings.
Mr. Cloutier stated that labor, management and OSHA have been negotiating a
proposed standard for steel erection (Subpart R) for three years and asked about the
status. Mr. Jeffress stated that the regulatory steps are complete, and that Federal
Register announcement should be made this summer on the proposed rule. Mr. Cloutier also
suggested that a way to reduce accidents would be to educate our children early. A method
to instill safety consciousness in our children might be made more effective if safety
awareness programs could be included in our educational systems at an early age, and that
an outreach program at the elementary/middle school level might be appropriate. He brought
up the fact that recycling education programs for children have had a measurable effect
and that following that template should be an option.
Mr. Martonik then briefed the group on the proposed standard on payment for PPE.
He discussed the background of the Union Tank decision and the fact that the court had
found what it felt were inconsistencies in OSHA's policies. He said that the standard
would make it clear that employers are obligated to pay for all PPE except safety shoes,
prescription safety eyeglasses, and cold weather outerwear. He further stated that all
health and safety standards and regulations promulgated since 1978 emphasize that
employers must pay for measures needed to protect employees against injury. In addition,
he elucidated a general philosophy on which the standard is based. First, since most
employers already pay for PPE, they are put at a competitive disadvantage if other
employers allowed not to pay. Second, the word "provide" means "make
available without cost." Third, PPE can be considered a control measure, and all
other control measures are paid for by the employer (e.g., guardrails). Fourth, PPE is
inherently uncomfortable, and employees are more likely to use PPE if it is provided at no
cost to the employee. He also pointed out that several states enforce a standard saying
that employers must pay for PPE (e.g., California, Washington, North Carolina, and
Minnesota). In these states, the exceptions, where they exist, are for safety shoes and
prescription safety glasses. Mr. Martonik stated that in cases where PPE becomes
contaminated, the employer is responsible for paying for replacement even if the item is
among the group that is "excepted." In addition, he said that he did not expect
a major cost impact in complying with this proposed rule. He expected that the proposed
rule will be published in June 1998, and hearings would ensue the following September. He
specifically invited general comments and questions about the proposed rule and questions
specifically concerning: its applicability to the construction industry; whether more
exceptions should be proposed; what exceptions would be appropriate; specific text where
appropriate to accommodate the construction industry; its use and pay patterns.
The question was asked whether prescription spectacles specifically modified for use
inside full face respirators were covered under the exception. That issue was recorded as
one to consider.
Mr. Cooper proposed a MOTION to modify 1926.95 to require all PPE to be paid for
by the employers, with no exceptions.
A discussion ensued which included: concerns about consistency within the construction
industry in the safety glasses area; whether ADA might have an impact (the staff solicitor
pointed out that this is argued on a case by case basis for a qualified person); the cost
impact on employees and employers, and the fact that many employers currently pay for all
PPE; whether this issue effects Worker's Compensation; the impact on seasonal workers who
are required to buy PPE (especially when a differentiation is made between the
acceptability of steel toes versus plastic toes on the safety shoes). ACCSH voted on the
motion with the following result: Ayes - 6; Nays - 7. The MOTION failed.
Mr. Rhoten pointed out that the language will affect negotiated contracts all
over the U.S. Specifically, the language could be used to wipe out requirements which have
been negotiated. Mr. Jeffress stated that the department had no desire to change current
practices in the industry.
Mr. Burkhammer proposed a MOTION to leave the language in 1926.95 as currently
A discussion followed during which issues concerning the reliability of data about PPE
use, the requirement by some small contractors for workers to purchase a broad range or
PPE, and a desire to see more cost analysis were aired. ACCSH voted on the motion with the
following result: Ayes - 6; Nays - 2. The MOTION passed.
Camille Villanova next briefed the committee on the recent history of training
activities and the Safety and Health Management Standard and Training Workgroups,
including a brief summary of the prior ACCSH work group developmental work and
recommendations to OSHA. A copy of the March 14, 1997, ACCSH recommendations on a safety
and health management standard proposed to be incorporated into the existing 1926 Subpart
C standards was distributed. Mr. Nichols stated that new work groups would be appointed on
4/9/98 and outstanding issues could be addressed when the workgroups met.
Mr. Rhoten discussed a pre-training issue that was still out for debate. It was again
pointed out that Workgroups would be appointed on Thursday and that the training Workgroup
would then be able to address outstanding issues.
Ellen Roznowski briefed the committee on recent issues and initiatives
concerning Women in Construction, highlighting the work done to produce a report
"Women in the Construction Workplace; Providing Equitable Safety and Health
Protection," which will be useful in alerting everyone concerned about the special
health and safety problems faced by women in the construction industry. She elicited input
and assistance from ACCSH in developing a dissemination plan for this information.
Bob Biersner discussed his review of the confined space standard submitted by
the ACCSH Workgroup. In general, he concluded that the proposed ACCSH language provided
less protection to employees and imposed more burdens on employers than the existing
General Industry standard. He did not recommend reinstating the General Industry standard
because of the unique needs of the construction industry. For example, sewer projects and
the associated hazards are not appropriately addressed in the General Industry standard.
Mr. Biersner indicated that a new project officer will proceed with developing a new
standard, with a goal of having it available in six months. Mr. Cloutier stated that he
had worked on the draft standard and that he disagreed with Mr. Biersner's assessment,
feeling that it cleared up problems with the General Industry standard and provided
additional protection to construction contractors.
Ellen Roznowski briefed the committee on Sanitation and Decontamination and
Washing Facilities issues. Among the issues she addressed was the need for chain of
custody requirements for contaminated equipment because of the frequency of movement of
the equipment used by construction sites. She pointed out that deficiencies in 1926.51
which had been identified have not been fully addressed, including hand washing
facilities, and soap and water availability. Ms. Roznowski also indicated that the issue
of sex-segregated toilets with locking capability needs to be addressed, in addition to
the cleanliness and sanitation of the facilities and the availability of toilet paper in
Steve Stock briefed the committee on Scaffolding, with special emphasis on the
draft Appendix B to Subpart L developed in May 1997. An additional remaining issue is the
need to reopen the standard to address several remaining matters, such as of tying off
safety lines to scaffolds. Input from the Scaffold Institute is pending, and NIOSH is
conducting a study.
The meeting was adjourned at approximately 11:45, and reconvened at 13:00.
Noah Connell briefed the committee on the progress of current rulemaking,
including Construction Safety and Health Programs, Subpart R (Steel Erection), Subpart M
(Fall Protection), Respiratory Protection, and Certification. He emphasized that a major
goal for all standards is a reduction in paperwork and the use of plain language. He also
announced that Lee Smith will be the new team leader for Safety and Health Programs in
Construction and for Confined Spaces. Steel Erection has been signed off by the solicitor
and requires two more sign offs and OMB approval. The proposed standard is scheduled to be
published in July. He indicated that issues involving the definition of "Residential
construction," and alternate fall protection procedures as well as towers/tanks would
be raised through the rulemaking process relating to Fall Protection. The issue of the
impact of the Paperwork Reduction act was also addressed as it pertains to the burden of
information collection, especially the fact that the total hours to comply with the
underlying requirement must be taken into account, not just the time taken to sign off. It
was pointed out that DOL is attempting to reduce the paperwork burden by approximately 25%
and that, although revoking some certification requirements due to the burden hours is an
option, it is an unattractive one, and this issue is still unresolved.
Ellen Roznowski on the Respiratory Standard. It was pointed out that the
respiratory standard was presented to ACCSH in early 1997, the ACCSH comments were
incorporated in the preamble, and the standard published in January 1998, replacing a 1971
standard. Some aspects of the new standard are: requirements were updated to reflect new
technology; a written program is required; new measures for fit, use maintenance,
cleaning, inspection and repair of equipment were incorporated; a program administrator is
required; a hazard evaluation must be conducted; and medical evaluations of employees must
be conducted with a questionnaire evaluated by a licensed health care professional;
training is specified as an annual requirement. It was stated that the incremental cost
per employee to comply with the new standard was calculated as $22.
In response to a question from the council, it was stated that a cost benefit analysis
for use of the new standard in terms of lives saved and injuries prevented was conducted,
with the benefits exceeding the cost. Mr. Swanson pointed out that OSHA could provide more
cost data if required but that the new standard is set to go into effect. Mr. Edginton
pointed out that the "health care professional" is normally a physician but can
be some other licensed professional if the rules of the state where the site is located
Mr. Nichols proceeded to read the assignments to the ACCSH Standing Committees
and Workgroups and stated that a written list would be provided on Thursday morning. His
motion to accept the assignments was seconded.
A free flowing discussion ensued concerning administrative details in support of the
Standing Committee and Workgroup meetings. Highlights include: OSHA will pay for ACCSH
members to travel to meetings; the location for sub-committee meetings is to be decided by
the chairman of the sub-committee; workgroup meetings will be open to the public but not
announced via the Federal Register; all parties desiring to attend sub-committee meetings
should contact the chairman of the sub-committee and ask to be notified as to the location
of meetings; OSHA will support holding meetings via teleconference; OSHA will post
sub-committee schedules on the OSHA web page if requested (Mr. Swanson will coordinate
notification of all workgroup meetings); OSHA will make administrative support available
at headquarters or in field offices if requested (coordinated through Mr. Swanson).
Mr. Burkhammer made a request that a Fall Protection workgroup be formed, and
Mr. Masterson and Mr. Devora volunteered to co-chair the workgroup. Mr. Nichols made a
MOTION to form the workgroup, and it was seconded and approved by the committee. Mr.
Nichols made a MOTION to form a Data Collection workgroup with Ms. Sweeney and Mr. Buchet
as co-chairs, and it was seconded and approved. Mr. Nichols made a MOTION to form a
Subpart M workgroup with Mr. Edginton and Mr. Cooper as co-chairs, and it was seconded and
The afternoon session concluded with further discussions concerning the proposed PPE
standard. Some of the employee representatives expressed uncertainty as to whether the
proposed new rule detracts from protection of employees. There was some frustration with
OSHA's lack of clarification on the content of the "five interpretations" cited
by the commissioners in the Union Tank decision. One member asked whether it would be
feasible to make a motion to reconsider the current draft of the PPE draft standard
pending review by the members. The solicitor representative (Ms. Shortall) stated that the
issue of the "five interpretations" was moot because OSHA has decided to proceed
to a rule. It was pointed out by OSHA representatives that the Assistant Secretary had
definitely heard how the committee felt about the proposal and would give "due
consideration" to that position, perhaps by changing language in the preamble.
Further public comment was solicited, and when no one from the gallery responded, the
meeting was adjourned at approximately 14:30 to allow for workgroup discussions.
The meeting re-convened Thursday morning at approximately 0900 with Assistant
Secretary Jeffress providing an introduction for the topic of Special Recognition Programs
for Construction. He reported that OSHA is going ahead with a pilot program to
recognize excellence and that the program will be limited to 4 employers to ensure that
control of the program is maintained. He described the Voluntary Protection Program (VPP)
as OSHA's premier recognition program for management leadership and said that one of his
goals was to develop these programs to the point that the programs function as sounding
boards and laboratories for new programs and policies as they function in the real world.
Mr. Jeffress described the construction industry as a more dynamic environment than
general industry. He pointed out that over 350 sites involving almost 200,000 employees
were currently in the Federal VPP programs and that, on average, lost work day incident
rates at VPP sites are 60 percent below the national averages.
Cathy Oliver provided more information for the committee on Special Recognition
Programs for Construction. She went into additional detail about the demonstration
program, stating that one company has been selected and will be limited to four sites. The
program will run for three years. She went on to discuss various other aspects of the VPP,
including: the application process; the weekly jobsite safety analysis; the PPE program;
safety and health rules; the involvement of both employers and employees in properly
accomplishing training; the commitment from company executives; the one year minimum for
site applications; implementation of other programs; abbreviated applications; and the
importance of joint labor-management committees.
Mr. Cloutier stated that the one year minimum for sites is very restrictive for
the construction industry because the average site in this industry is not active for more
than one year. He also asked why the selection process could not be streamlined by
screening for companies with low accident rates and cutting out some of the other steps.
He gave the example that, if a company is recognized by the Business Roundtable, the
excellence of that company's program as represented by that achievement should be
appreciated. It was agreed that a workgroup would examine this issue.
Mr. Edginton indicated that a perception exists in the labor community that the
VPP Association is getting more control over the VPP process than OSHA itself. They feel
that OSHA affords special treatment to VPP participants when an accident occurs. Ms.
Oliver responded that enforcement procedures go into effect regardless of the VPP status
of a given company.
Ms. Marie Haring Sweeney pointed out that 80 % of construction firms have less
than 10 employees and that there appears to be a need to identify some small contractors
with excellent safety records to use as an example.
Mr. Bagdy asked the workgroup to keep him apprised of their deliberations.
Mr. Swanson briefed the committee on issues of importance to the Directorate of
Construction, including Special Emphasis Programs, Partnership, Statistics, and
Residential Construction Grants. He cited an increase in serious violations in the
last year, along with increases in the number of accidents and fatalities in more recent
years, to contrast with the stated goals of the Assistant Secretary to achieve a 15 %
reduction in overall injuries, and a 15 % reduction in fatalities the end of 2002. Mr.
Swanson pointed out that these goals just cannot be achieved doing things the same way we
always have. In the area of Special Emphasis, he discussed targeting mechanisms and
re-invention, saying that these have been successful, but not sufficiently so. He also
discussed outreach and partnership programs and solicited input from the committee in
developing programs to improve safety. After a short briefing on the status of Residential
Construction Grants, Mr. Swanson discussed data development and how to coordinate
collection of data with BLS and other institutions in addition to how the workgroups might
assist in integrating these activities with targeting and the scheduling of enforcement.
Mr. Nichols announced that at future committee meetings, chart boards would be
prominently posted addressing workgroup functions and time lines to assist everyone in
following the discussions and status of activities. A question was raised concerning
whether a part of the increase noted in serious deficiencies might stem from a double
counting effect which happens when a sub-contractor is cited, because in these cases the
prime contractor is cited as well. Mr. Swanson stated that he had not data in hand to
respond to that question. Ms. Sweeney asked whether effectiveness is evaluated for the
grants, and Mr. Swanson replied that there is an evaluation component in each grant.
Ms. Marie Haring Sweeney gave the committee a briefing on Construction Programs at
the National Institute for Occupation Safety and Health (NIOSH), including background
information about NIOSH, and how to order the new NIOSH Construction Package (ask for
NIOSH Publication number 97152 at phone number 1-800-35N-IOSH ), and descriptions of
several of the surveillance programs. She described how these surveillance programs
collect a wide range of useful data, from mortality rates in the construction trades to
discovering that there has been a surge recently in eye injuries to plumbers. Ms. Sweeney
discussed other related topics including: etiological research; methods development
research; interventions; communications and information dissemination; technical
documents; the Construction Resource Center; and the NIOSH Internet site. She concluded by
stating that in the construction arena NIOSH is currently giving priority attention to
issues involving: information and data collection; small businesses and independent
contractors; non-union sites; and residential construction.
Public comment was solicited: Richard Pfau, a safety director for a local
construction company brought up the issue of multi-employer work sites and the fact that,
if a subcontractor is cited, the prime is also cited. He pointed out that in Fairfax
County, Virginia, a single serious citation can eliminate a contractor's ability to bid on
county jobs, and asked ACCSH to address OSHA's multi-employer citation policy. Mr. Nichols
stated that anyone desiring to participate in such a workgroup should give their name and
address to one of the co-chairs.
George Kennedy, representing a contractor group, stated that OSHA would spend
too much money auditing four big companies for VPP and would do better to spend the money
on programs that would benefit small construction companies.
Marc Freedman, representing another contractor group, stated that OSHA needs to
direct more assistance (like information publications) to small employers.
Claudia Harris, representing another contractor group stated that OSHA needs to
mail information packages or place all information related to the upcoming meetings at an
Internet site so these materials could be read by all interested parties prior to the
meeting and that OSHA should have enough hand-outs available at the meetings.
After some discussion, Mr. Swanson announced that as much information as possible
concerning ACCSH would be posted on the OSHA Internet site, including the minutes of the
meetings. Some of the other specific requests such as incorporating a search capability
and posting executive summaries were taken under advisement. He also stated that a
government liaison representative would be assigned to each subcommittee. In addition, Mr.
Swanson stated that the exact date for the next ACCSH had not been scheduled, but that it
should occur in July. The meeting was adjourned at approximately 1130.
The following members of ACCSH were in attendance.
Timothy L. Nichols
Director of External Relations
Building and Construction Trades Dept.
1155 15th St., N.W., Fourth Floor
Washington D.C. 20005
Stephen D. Cooper,
International Association of Bridge, Structural & Ornamental Iron Workers
1750 New York Avenue, N.W.
Washington D.C. 20006
Larry A. Edginton
Director of Safety and Health
International Union of Operating Engineers
1125 17th St., N.W.
Washington D.C. 20036
Training Coordinator/Assistant Director
International Union of Operating Engineers
EEO Officer, Local 138
137 Gazza Boulevard
Farmingdale, NY 11735
William C. Rhoten
Director of Safety & Health Dept.
United Assoc. of Journeymen & Apprentices
Plumbing & Pipe Fitting Industry of the U.S. and Canada
901 Massachusetts Ave., N.W.
Washington D.C. 20001
Vice President & Mgr. Of Safety and Health Services
9801 Washingtonian Blvd.
Gaithersburg, MD 20878
Safety/Loss Prevention Manager
J.A. Jones Construction
J.A. Jones Drive
Charlotte NC 28287
Fretz Construction Company
P.O. Box 266784
Houston TX 77207-6784
Manager, Safety and Loss Control
The Ryland Group
11000 Broken Land Parkway
Columbia MD 21044-3562
Anzalone & Associates
12700 Foothill Blvd.
Sylmar CA 91342
Chief Administrative Officer
OSH Enforcement Division of Industrial Relations
Nevada Dept. Of Business and Industry
400 West King St. 89703
Carson City NV 89703
Jane F. Williams
Safety & Health Consultant
4901 E. Kathleen Road
Scottsdale AZ 85254
Construction Division Manager
National Safety Council
1121 Spring Lake Drive
Itasca IL 60143-3201
(W) 630-285-1121 Ext. 2531
Marie Haring Sweeney, Ph.D.
4676 Columbia Parkway
Cincinnati, OH 45226
Directorate of Construction
Department of Labor
(W) 202-219-8136 Ext. 143
(W) 202-219-8644 Ext. 206
Luz Dela Cruz
(W) 202-219-8136 Ext. 146
(W) 202-219-8615 Ext. 106
|ACCSH WORKGROUP ASSIGNMENTS
||CHAIRS and Assigned Directorate of
Construction (DOC) Staff
|Safety and Health Program Standard
||Steve Cloutier & Bill Rhoten
DOC Staff - Camille Villanova, Jim Boom
||Steve Cloutier & Bill Rhoten
DOC Staff - Camille Villanova, Jim Boom
||Steve Cloutier & Bill Rhoten
DOC Staff - Mark Hagemann
||Steve Cooper & Jane Williams
DOC Staff - Ellen Roznowski
||Owen Smith & Michael Buchet
DOC Staff - Bill Burke
|Safety Excellence Recognition
||Stew Burkhammer & Larry Edginton
DOC Staff - Dave Morgan
||Robert Masterson & Gladys Harrington
DOC Staff - Camille Villanova, John Franklin
||Robert Masterson & Felipe Devora
DOC Staff - Jule Jones
||Marie Haring Sweeney & Michael Buchet
DOC Staff - Camille Villanova, John Franklin
||Larry Edginton & Steve Cooper
DOC Staff - Tony Brown
||Stew Burkhammer & Marie Haring Sweeney
DOC Staff - Doug Ray
|ADVISORY COMMITTEE ON CONSTRUCTION SAFETY AND HEALTH (ACCSH)
OSHA National Office Operations
To monitor and offer advice and assistance on agency administrative issues (e.g., budget,
staffing) as those activities pertain to construction.
Co-chairs - Steve Cooper, Robert Masterson
Members - Michael Buchet, Danny Evans, Harry Payne
DOC Staff Assigned - Berrien Zettler
OSHA Field Operations
To monitor the agency's field operations and offer advice and assistance in policy
development in the areas of enforcement (to include emphasis programs, settlement
agreements) and other activities such as CSHO training, compliance assistance, Partnership
Programs and other cooperative programs, as these activities relate to construction.
Co-chairs - Larry Edginton, Stewart Burkhammer
Members - Robert Masterson, Owen Smith, Jane Williams
DOC Staff Assigned - Dave Morgan
To monitor and offer advice and assistance on the agency's standards promulgation,
interpretations, and directives development as these activities relate to the construction
Co-chairs - Stephen Cloutier, Bill Rhoten
Members - Gladys Harrington, Felipe Devora, Marie Haring Sweeney
DOC Staff Assigned - Noah Connell