Telecommunication Towers Small Business Advocacy Review (SBAR) Panel


In the summer of 2018, OSHA is initiating a Small Business Advocacy Review (SBAR) Panel, also known as a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel, to get feedback on a potential new standard covering work activities performed on telecommunication towers. The provisions to be included in a potential standard that OSHA is considering are based on industry best practices, site visits and interviews, stakeholder comments received in response to OSHA's 2015 Request for Information, and lessons learned from accidents involving telecommunication towers.

Topics in the potential regulatory framework to be considered by the SBAR Panel include:

  • Training
  • Worksite Conditions
  • Environmental Hazards
  • Safe Work Practices
  • Multi-Employer Issues
  • Fall Protection
  • Support Equipment Requirements
  • Structural Requirements

What is a Small Business Advocacy Review (SBAR) Panel

When: OSHA anticipates formally convening the SBAR Panel in summer 2018

What is the telecommunication towers standard?

  • August 15 – Convene SBREFA Panel
  • Teleconferences with SERs:
    • August 28, 9:30-12:00
    • August 29, 1:30-4:00
    • August 30, 9:30-12:00
  • September 7 – Written comments from SERs due.

Small Entity Representative Materials for SBREFA

Further Information

Small organizations include small businesses as defined by the SBA Table of Size Standards, not-for-profit organizations that are independently owned and operated and not dominant in their field, and small governmental jurisdictions with a population less than 50,000.

SBAR Panel Small Entity Representatives (SERs), as of 8/27/18:

  • Shama Ray, Above All Tower, LLC
  • Charlie Garthe, AMF Electrical Contractors, Inc.
  • Robert Mickey, A.R. Wireless Inc.
  • John E. Barrett, Barrett Outdoor Communications, Inc.
  • Ron Beck, Central Lincoln Public Utility District
  • Patricia Cipov, Cipov Enterprises, Inc.
  • Loren Stearns, CTI Towers
  • Rhett Westerman, Deep South Communications, LLC
  • John Hughes, Douglas County Public Utility District
  • Diek Brunscheen, Finish Tower
  • Victor Drouin, Green Mountain Communications, Inc.
  • Jim Tracy, Legacy Telecommunications, Inc.
  • Brian Worthen, Mammoth Networks
  • James "Jimmy" Miller, MillerCo Inc.
  • John Greene, New Lisbon Telephone Company
  • Karen Kyman, Precision Communications, Inc.
  • Roger Scott, Site Resources LLC
  • Nick Vespa, Southeastern Towers LLC
  • Jeff Tinio, Teltronic Towers
  • Christopher Mallon, TowerMRL, Inc.
  • Joe Fieldsted, Valley Electric Association, Inc.
  • Dave Hall, Velex

Contact OSH for questions:

Contact SBA's Office of Advocacy for questions:

  • Bruce Lundegren (office represents the views of small entities in the SBREFA process), or (202) 205-6144.
  • Teleconference Public Access Information: To access the teleconference as a listener, call 888-946-7602 and at the prompts, enter the listener passcode: 8972783.
  • All teleconferences will be open to the public via telephone, but only SERs and SBAR Panel members can participate in the discussions. The public is also invited to attend in person (capacity may be limited). The teleconferences will be held in the Department of Labor Building at 200 Constitution Ave NW in Washington DC.
  • Any interested party may submit comments, even those who are not participating as SERs, and OSHA will include those comments in the public docket. While OSHA has no legal obligation to consider or to respond to non-SER comments, the Agency will consider them in its discretion as resources allow. All such comments can be submitted to OSHA docket OSHA-2014-0018 via the government's e-regulatory portal, The comment period will last until two weeks after the SBAR Panel report is completed. It is expected to close on or about October 15, 2018.