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:
- Worksite Conditions
- Environmental Hazards
- Safe Work Practices
- Multi-Employer Issues
- Fall Protection
- Support Equipment Requirements
- Structural Requirements
- 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
- Small Business Advocacy Review Panel (SBAR Panel) Final Report and associated materials can be accessed at www.regulations.gov (Docket # OSHA-2014-0018-0073)
- Telecommunications Towers Preliminary Initial Regulatory Flexibility Analysis (PIRFA): Provides information on the issues to be addressed with participating SERs. (Docket # OSHA-2014-0018-0071)
- SER Issues Document: Contains a brief discussion of each topic and questions for participating SERs. (Docket # OSHA-2014-0018-0072)
- OSHA Communication Towers RFI (Docket #OSHA-2014-0018) - Corresponding full docket with comments, etc.
- OSHA's Communication Towers Safety Page
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:
- Joel Batchelor (SBREFA Coordinator), email@example.com or (202) 693-1873.
- Anissa Harmon (SBREFA Coordinator), firstname.lastname@example.org or (202) 693-1713.
- Charles McCormick, McCormick.Charles@dol.gov or (202) 693-1740.
Contact SBA's Office of Advocacy for questions:
- Bruce Lundegren (office represents the views of small entities in the SBREFA process), Bruce.Lundegren@sba.gov 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, www.regulations.gov. 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.
- How the SBREFA Panel process works.
- OSHA's Small Business web site.
- OSHA's Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) web page.
- Small Business Administration Office of Advocacy.