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MACOSH EXECUTIVE SUMMARY
Houston, TX
February 29 - March 1, 2000
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The fourteenth meeting of the OSHA Maritime Advisory
Committee for Occupational Safety and Health (MACOSH) was
called to order at 9:00 a.m. on February 29, 2000 in
Houston, TX. An electronic transcript of the full meeting
(February 29, March 1, 2000) was sent separately to
members of the previously chartered committee for their
review and record. With one minor addition recommended by
Larry Reed, the Executive Summary and the transcript on
the November 1999 meeting were approved unanimously. Larry
Reed and Larry Liberatore began the meeting and reviewed
the agenda for the current meeting.
Ms. Barbara Bielaski, who is the Acting Deputy Director
of Safety Standards, gave an update on the OSHA safety and
health standards program. The update included some
background, the issues at hand, the reason for the
standard and relevant dates. Prior to the update, Ms.
Bielaski explained that the ergonomics rule was larger and
more complex than originally anticipated, and a large
majority of OSHA staff had been put onto this project.
1. Recordkeeping. Reasons for this standard are to
get better data, simplify paper work and to increase
compliance. Plans include going to OMB in early March,
and publish a final rule sometime in the summer. This
will also include extensive outreach, and will go into
effect January 1, 2001.
2. PPE Payment. Who will pay for PPE. OSHA is
currently reviewing the record and a final rule is
expected in the Spring of 2000.
3. Tuberculosis. The issue is whether a standard is
needed with the recent decrease in TB cases. A final
rule is scheduled for publication in Summer 2000.
4. Ergonomics. Reason for this standard is to reduce
the number of illnesses and injuries relating from MSDs.
A final publication is expected end of 2000.
5. Exit routes. This will be a plain language version
and a final rule is expected Summer 2000.
6. Steel erection. Final rule this summer.
7. Safety and Health Programs. Currently is in an
internal review with all dates being held up due to the
Ergonomics rule.
8. Process Safety Management. Issues include whether
OSHA should add approximately 100 lower reactive
chemicals to the appendix A list, and how OSHA should
clarify the exemption of flammable liquids stored in
atmospheric tanks. This is an ANPR to be published April
2000, seeking comments, recommendations, data and
information.
Chap Pierce, Acting Director of Office of Maritime
Standards, commented on standards projects that are
currently being worked on in the Office of Maritime
Standards. The first project is the shipyard fire
protection negotiated rulemaking (commonly referred to as
"neg reg") that is being redone to be updated
and put into plain language. Another draft has been
completed and turned in for internal review. Once this
draft gets through to the Solicitors Office, we are hoping
that the neg reg committee will continue the process with
a meeting to be held in late April or May. The second
project involves a workgroup formed within MACOSH that was
to look at the SESAC recommendations and prioritize the
subpart as to which needed revision first. The final
project was the longshoring Correction Notice. An
extensive review revealed numerous errors, many of which
dealt with references that were incorrect, and the
conversion of metric units. Due to the number of errors,
the smaller correction notice has been changed, and now
will be a correction notice that will include all
necessary corrections. This should be wrapped up in two to
three months. This project directly correlates with the
blue book publication, which will be delayed as well.
Thomas Galassi, Deputy Director of Compliance Programs,
gave an update on the OSHA compliance program. Mr. Galassi
explained that since the work at home policy was in the
headlines, a great deal of OSHA’s attention has been
directed to the dissemination of information and
extensively reviewing this process. Each Directorate has
been charged to look at how we do policy, and to look at
every document on the OSHA home page and identify any
problem documents. On February 3, the site specific
targeting plan for the year 2000 was completed. The
inspection targeting is to begin February 2000 and will go
to January 31, 2001. A multi-employer directive was
issued, and is entitled "Multi-Employer Citation
Policy, CPL 2-0.124. This breaks down how OSHA looks at
multi-employer work sites by giving numerous examples. Mr.
Galassi requested examples from the MACOSH committee that
would assist with the maritime industry in the directive.
Mr. Galassi also discussed the Powered Industrial Trucks
Training Directive, the PITS settlement, Tagout Issues
with the U.S. Navy, the shipbreaking MOA, CSHO Training,
and the longshoring directive. Mr. Galassi stated that the
Shipyard Tool Bag concept is in a draft directive. During
the discussion on the revision to STD.2, Mr. Galassi
stated that OSHA would like input from MACOSH on which new
standards would apply to the shipyard industry, from a
potential workgroup.
A discussion was held about maritime industry workers
and the ergonomics proposal. As the standard states in its
proposed format, workers in the maritime SIC code are
excluded from this rule, including office workers and the
such, since NIOSH is performing an ergonomic study in this
industry. [Note: On March 1, the full committee finalized
and faxed a letter to the OSHA docket office clarifying
MACOSH’s support of this exclusion.]
Larry Liberatore gave an update on what the training
and outreach workgroup had discussed during their meeting
held in San Francisco on January 5, 2000. Since OSHA
compliance officers are generalists, the workgroup felt
that they needed more specific training in the maritime
industry. NMSA has been contracted to help revamp the
current OTI Maritime course, which is currently split
between longshoring and shipyards, with one day on diving.
A two week course is being developed at Kings Point that
will train compliance officers in the terminology, process
and dynamics of the shipyard. Once this training module
has been developed and put into action, the same process
will take place for longshoring. In addition, this
workgroup discussed the training and outreach of longshore
and shipyard workers. MACOSH would partner with various
groups involved and the OSHA area office and hold
roundtable discussions on the top injury in that
particular shipyard. This workgroup will identify three or
four locations and injuries for both longshoring and
shipyards, and Larry will discuss this with the Regional
Administrators, and from this, a few roundtable
discussions will be held. Several members of the committee
shared their recent experience with the roundtable
discussion, and felt that it was very positive.
The committee then split into breakout groups to
discuss the noted agenda items and to discuss the letter
that they would submit to the ergo docket supporting the
exclusion of the maritime industry. The longshore group
discussion included vertical tandem lifting, the use of
under deck cones, and the blue book. It was agreed that
this group would send examples of anticipated problems
from the industry with proposed solutions to Tom Galassi
for the multi-employer citation policy. This group also
discussed the PITS settlement and training, fall
protection from pedestal areas and containerships, and
developing smaller workgroups for purposes of the training
and outreach program. These workgroups would include OSHA,
labor and the employer and would identify the target
injury, and develop a plan to reduce the frequency. The
shipyard breakout produced a list of three issues that
they would like MACOSH and OSHA to work on. The first was
the lockout/tagout issue, especially as it pertains to
Navy vessels. Maritech will charter a subcommittee during
the rechartering of MACOSH, and will bring some
recommendations to the next meeting. Larry Reed will be
contacting the chairman on the Construction Advisory
Committee and find out what is happening in the
construction arena, and report back at the next MACOSH
meeting. The third issue was blasting in shipbuilding
operations, especially in confined areas. False readings
of lead and cadmium are being produced. NIOSH has been
asked to review the current sampling protocol to determine
if it can be redesigned to fit this situation. In
addition, a discussion was held on the original SESAC
recommendations and the need for updating several of these
recommendations, including the electrical standard. Chuck
Rupy gave a presentation on the Maritech program, and this
group will also produce a list of four hazard areas that
they would like to see in the training and outreach
program.
The full committee reconvened on March 1, 2000 at 8:30
a.m. and began with a presentation from Captain Chris
McMahon, Director of Global Maritime and Transportation
School at the U.S. Merchant Marine Academy at Kings Point.
Captain McMahon explained that in the past five years, the
Academy has undergone a reinvention, and is now the
largest maritime and transportation professional education
program in the country with over 150 new courses. The
courses are taught by the King’s Point faculty, members
of the industry, military and government. The academy has
developed a series of partnerships with the industry that
are currently underway. Education and training programs
are provided to professionals in developing countries.
Capt. McMahon explained that the academy can customize
programs and training specific to the customer, whether it
be military, government or private industry.
Following Capt. McMahon’s presentation, the committee
heard an update on the ergonomic intervention project by
Dr. Hudock (NIOSH ergonomist) and Karl Siegfried
(ergonomic consultant). Steve reported that they had three
of seven of the pre-intervention walk-through surveys.
Karl described several of the successful proposed
interventions to date. In October 1999, NMSA gave its
management approval for longshoring to be a part of the
NIOSH ergonomics study. [Note: Labor had previously given
its consent.] The longshoring part of the maritime
ergonomics study should begin in late summer 2000.
Two items were raised and voted on following this
presentation. The first was that the project officers for
the ergonomics study conduct injury and illness reviews
for the entire work force in the maritime industries and
that the recommendations provide information on
interventions for the work force, including administrative
and office workers. The second issue was a letter that was
being submitted to the ergonomics docket from the MACOSH
committee. This letter was a written request to OSHA to
clarify that the maritime industry is excluded from the
ergonomic program proposal, and when the NIOSH study is
completed, that OSHA develop an ergonomics program the
proposals for entire maritime industry (one for shipyards
and one for longshoring) based on the recommendations of
the study. [Note: after full committee review, this letter
was finalized and faxed to the ergo docket office on March
1, 2000 for inclusion in the official docket.]
Mr. Joe Dubois, Office of Statistics, gave a
presentation on the data initiative for scheduling
compliance investigations. It was explained that OSHA uses
the BLS data from the OSHA 200 log. 80,000 employers in a
certain group of industries were sent a letter requesting
their OSHA 200 log information. The lost work day rate was
calculated from these logs, and lists were produced for
each area office comprised of the companies with rates of
14 or greater to be targeted for inspection. The companies
who had rates between 8 and 14 were sent a letter
identifying their rate, and recommending that they reduce
that number. Currently, OSHA is trying to improve the
quality of the data, and whether or not employers know how
to use the OSHA 200 log correctly.
Capt. McMahon gave a presentation on the proposed
shipyard course that would be held at the U.S. Merchant
Marine Academy in May or June of this year. This course
would familiarize OSHA inspectors on the industry,
terminology and what happens in a shipyard, but it would
not focus on safety. There would be several field trips
for extensive hands-on training. Ms. Jennifer Miller, from
the OSHA Training Institute (OTI), explained that this
course would precede the current Maritime OTI course.
Students would attend the two week course at King’s
Point to get an understanding of the shipyard process,
product, terminology, vessel and how the shipyard
operates. Then, they would attend the OTI course to focus
on the hazards of those processes, the standards and OSHA
policies that relate to the application of those standards
to the hazards. Mr. Tom Pope, Area Director, explained
that following these two training modules, the inspectors
would then perform inspections in their area office with
Senior Compliance Officers who had experience in the
maritime industry. The first course will be audited by
several people in the industry, and any additions,
subtractions or changes would be made prior to the second
course scheduled for the end of the summer. This same
process will take place for the longshoring industry after
the shipyard courses are underway.
The full committee then discussed plans for the next
meeting to be held preferably in King’s Point, NY for
either July 12-13 or July 19-20, 2000. [Note: The latter
date was selected for this meeting.] The second meeting of
the recharted committee is tentatively scheduled in
conjunction with the National Safety Council meeting in
Orlando October 18 -19, 2000.
After the meeting adjourned, Steve Butler, Office of
Maritime Compliance, showed a very effective video that
was made for outreach and training for the Association of
Contractors on fatalities among divers. The suggestion was
made that a similar video could be made by MACOSH to
support the training initiatives.
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