To: Carl Heinlein
Fax #: 202-347-4004
Re: OSHA Draft Multi-Employer Language
Date: October 22, 1998
Pages: 6, including this cover sheet
I appreciate the opportunity to comment on the OSHA multi-employer language. I hope you can read my scribble on the draft document.
I believe OSHA's heart is compatible with AGC's on this important policy. While basically an improvement, concerns primarily still exist with "the controlling employer" wording as follows:
- CSHO's are still give broad interpretation which will still created inconsistencies in enforcement which is a major problem at present
- I wish they would say definitely that when the CM or GC hires a "specialty contractor" that inspections of their work as it relates to their specialty is not required. Example would be that the GC does not have the knowledge or expertise to inspect electrical work performed by a licensed reputable contractor. The HC should be able to monitor electrical safety compliance through the electrical sub without having to become an electrical expert.
Thanks in advance for the opportunity to respond. The AGC is definitely responding to members' concerns and our efforts are paying dividends.
Thanks for all that Carolyn and you do to promote the AGC and safety on a daily basis
From the desk of...
T.A. LOVING COMPANY
400 Paletown Road
Goldeboro, NC 27530