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U.S. DEPARTMENT OF LABOR

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION


ADVISORY COMMITTEE ON CONSTRUCTION SAFETY AND HEALTH

(ACCSH)


Friday, November 30, 2012


Frances Perkins Building

200 Constitution Avenue, N.W.

Washington, D.C.

Diversified Reporting Services, Inc.

(202) 467 9200

COMMITTEE MEMBERS PRESENT:

EMPLOYEE REPRESENTATIVES:

Erich J. (Pete) Stafford, Chairman
Building and Construction Trades Department, AFL CIO

Roger Erickson
International Brotherhood of Boilermakers, Iron
Ship Builders, Blacksmiths, Forgers & Helpers
AFL-CIO, MOST Administrator

EMPLOYER REPRESENTATIVES:

Kristi Barber
Glenn C. Barber & Associates

Kevin R. Cannon
Associated General Contractors of America

Thomas Marrero
Zenith Systems, LLC

William E. Hering
SM Electric Company, Inc.

Donald L. Pratt
Construction Education and Consultation
Services of Michigan

STATE REPRESENTATIVES:

Charles Stribling
Kentucky Labor Cabinet, Department of Workplace Standards

Steven D. Hawkins (telephonic)
Tennessee Occupational Safety and Health Administration

PUBLIC REPRESENTATIVES:

Letitia K. Davis
Massachusetts Department of Public Health

Jeremy Bethancourt
Arizona Construction Training Alliance

FEDERAL REPRESENTATIVES:

Matt Gillen
Deputy Director, Office of Construction Safety
& Health, CDC/NIOSH, Office of the Director

DESIGNATED FEDERAL OFFICIALS:

Ben Bare
Deputy Director, DOL OSHA Directorate of Construction

COMMITTEE CONTACTS:

Damon S. Bonneau
OSHA, Directorate of Construction

COMMITTEE COUNSEL:

Sarah Shortall, DOL, Office of the Solicitor

AGENDA


PAGE

Opening Remarks/Agenda Overview ‑
  Chairman Stafford

5
RFI Update - Backing Operations - Paul Bolon and
  Meghan Smith, Directorate of Construction,
Office of Construction Standards and Guidance

8
OIS Update - Cecil Tipton and Gus Georgiades,
  Directorate of Administrative Services

24

SIP IV - Paul Bolon, Directorate of Construction,
  Office of Construction Standards and Guidance

69

RFI Update - Reinforced Concrete and Post
  Tensioning - Paul Bolon and Blake Skogland

76
Public Comments

82
Closing Comments

90
PROCEEDINGS

(8:05 a.m.)

OPENING REMARKS/AGENDA OVERVIEW

CHAIRMAN STAFFORD: I'll go ahead and call the meeting to order. Good morning, everyone.

This is a pretty small group here. I think those of you that I can see, that we can forego doing self introductions this morning.

I don't really have much to say by way of opening remarks. We have three things on the agenda this morning.

Cecil Tipton will actually be joining us from Idaho. It's 6:30 in the morning his time. Appreciate his efforts to do that. He will take the place of Joshua Moore who was going to give us an update on OIS. We look forward to that conversation.

Something we have been pushing here to talk more about, surveillance, and ultimately hopefully what we can do with surveillance and data information that we have to continue our talk that we had with Dr. Michaels yesterday about targeting in the construction industry.

We are also going to hear from -- I'm not sure who is going to be doing it. I guess it will be Paul, to tell us what OSHA is thinking about doing now that the RFI is closed, both on backing operations and post tensioning concrete, to see what the Agency has in mind in terms of moving forward with rulemaking one way or the other.

We will wrap up. I don't think anyone will be incredibly saddened if we don't go all the way to noon today. We will see how things go on the agenda.

With that, I'd like to open it up to any of the ACCSH members if there are any remarks or comments you would like to make based on what has happened the last three days.

MR. PRATT: I have one thing, not about what has happened in the last couple of days. If I'm out of order, let me know.

If we could possibly get materials ahead of time before these meetings. Maybe you always do that. Maybe I just didn't get it because I'm new, I don't know. Not having anything at all before we started -- the organization was great.

For someone who didn't go to the orientation, there was very little material that I saw come through. Maybe I missed it.

CHAIRMAN STAFFORD: I'm not so sure about that. I mean in terms of presentations, that type of thing?

MR. PRATT: Refresher on the minutes of the different groups. It would have been nice to have gotten up to speed before I got here.

CHAIRMAN STAFFORD: I see, minutes out from the previous meeting. I'll talk to Damon and staff about that. I'm sure that is something we could probably do.

MS. SHORTALL: They are also in the Docket. They will be in the Docket within a week or so here. You should be able to get to them.

Once again, the Docket number is OSHA-2012-0011.

MR. PRATT: Thank you.

MR. GILLEN: I'd like to ask if the OSHA Docket number could just automatically always be on the agenda, so it's always there. Sometimes it's in the Federal Register. I'm not sure we got the Federal Register this time. It's just an easy thing to do.

MS. SHORTALL: Damon says okay.

CHAIRMAN STAFFORD: Damon, you didn't have to move to the back on this conversation.

MS. DAVIS: I couldn't see the slide show. This is too small to be able to have an effective slide presentation. Just a technical issue.

CHAIRMAN STAFFORD: I didn't know if this was just in this particular instance, typically it's the big screen. I think Damon may have done that for me so I didn't have to stare into the light of the camera all day. Maybe we should go back to the other way, Damon.

Anything else? Good morning, Paul. Good morning, Meghan. I appreciate your flexibility. We are going to talk about where the Agency stands after the RFI on backing operations and post tension in concrete.

RFI UPDATE - BACKING OPERATIONS


MR. BOLON: We are going to talk about backing right now, and then I can also talk to you about SIP.

CHAIRMAN STAFFORD: That's fine.

MR. BOLON:
As you know, we published an RFI in March. The comment period stayed open until the end of July, I think, July 27. I am here with Meghan Smith. She can describe what the comments were like, and then we can go through the steps of what else we are doing in back over's.

Meghan, do you want to describe the record we got and what we learned from it?

MS. SMITH: Sure. We had 32 different commentors. Because of the way the RFI was set up with concrete and back over being in the same document, we had some people commenting in the wrong docket. We had some people who commented in one docket for both issues.

Currently, the Docket Office is making sure that all the comments relating to back over make it into the back over docket.

I was discussing that with them yesterday and they are in the process of doing that.

The comments came from small and large businesses, trade associations, Union groups, safety consultants, researchers, companies that manufacture backing safety equipment, state and local government, NIOSH, Region IV, and members of the public.

CHAIRMAN STAFFORD: Could you repeat that, please?

(Laughter.)

MS. SMITH: Basically, lots of comments. One or two comments from lots of different sectors of people. There was no one major group that sort of bombarded us with comments.

Because of that, the comments were quite varied. Some commentors, of course, said yes, please do new regulations, and some commentors said oh, please do not.

One commentor, a researcher named Kirs Well, gave the results of his study on the IMIS reports, mentioning back up alarms. Of 152 backing incidents, he found that 25 vehicles had no alarms, 42 had alarms installed that weren't functioning, and 65 had properly working alarms.

Eight of the commentors recommended better training. Five commentors acknowledged that new technology may help prevent backing incidents, although the vehicle equipment manufacturer, Terex, stated it is not desirable to add cameras or proximity detection systems to machines based solely on feasibility, since low technology solutions, such as mirrors, may sometimes offer the most effective solution.

Some commentors recommended spotters, but there was little argument that back-up alarms by themselves are effective.

It was very much across the board. We had 45 different questions. Some people made a valid attempt to answer every question that was applicable to them. We had a couple of comments that were just yes, cameras are cheap, why don't you make people put cameras on.

Comments ranged from two or three sentences to 20 pages. We had a wide variety of information.

Because the RFI dealt with both construction and general industry, we heard from a trucking association, we heard from a maritime group, we heard a lot from construction, various kinds of construction.

It was across the board and everybody had different interests.

MR. BOLON: We are continuing the information and we are still in the mode of collecting more information on back overs.

I think in the work group yesterday, Meghan presented the new BLS data on back overs. I think there are almost 80 fatalities a year. It is something that still very much has our interest.

In the steps that we are doing to continue to develop the information, we have done several site visits. We have attended meetings with equipment manufacturers.

The web page is up that Meghan developed. Jim Maddux announced yesterday, I think, that we are going to have several stakeholder meetings on back overs.

One is tentatively scheduled to be here in January, January 8. That is not an absolute final date. The Federal Register hasn't been published yet. We are looking at January 8 here at the Department of Labor. We are looking to have another group of stakeholder meetings in Dallas and Arlington.

CHAIRMAN STAFFORD: Are you thinking about potentially if you move forward, moving forward with a standard for all industries or are we talking just about moving forward on a construction standard?

MR. BOLON: All industries. That is where we are at. We are quite active. We are seeking site visits. If any of the members here or members of the audience would be interested in hosting us and talking to us about back overs, we would be glad to hear about it.

The site visits we have done so far is in construction, but we will be going to employers and others.

CHAIRMAN STAFFORD: Hypothetically, so we understand the process, if you go through this round of stakeholder meetings and it looks like all industries in this case are saying yes, we think something needs to be done, what would be the next step in the rulemaking process after that?

MR. BOLON: The key step is the OSHA managers have to make a clear decision to say yes, go ahead and do a rule.

The next step in terms of getting a proposal out, we would probably have a small business panel to review the rule, get some input, get some response.

The Agency has to make a decision, but probably a small business panel would be next.

I would like to do as many site visits as we have resources to do, so we can find out. It's not just for construction. It is for all industries. We will be reaching out to all the industries that potentially have a problem with back overs.

CHAIRMAN STAFFORD: Timing wise, a program standard gets cleared and goes through SBREFA, does OSHA have the resources to be working on both of these things at one time?

MR. BOLON: Both of?

CHAIRMAN STAFFORD:
The program standard, backing operations.

MR. BOLON:
There are other offices involved. I can't really speak for them. From our point of view, we have the resources in our office to do that. SBREFA brings in the economists and other things. I can't commit for them. As far as we are concerned, yes.

CHAIRMAN STAFFORD: Kevin?

MR. CANNON: You are saying the managers have to make a decision. What are they going to base their decision on? It seems like you have a mixed bag of comments, some yes, some no. How are you ultimately going to come to that decision?

MR. BOLON: Ultimately, it really hinges on is there a substantial amount of risk that we're addressing, have we been able to craft some regulatory approaches that will effectively address that risk, reduce fatalities, accidents and injuries.

What do the costs look like. Do we have information that supports a successful rulemaking. Do we have risks, do we address the risks. What do the costs look like and so forth.

Just the key criteria for rulemaking, I would say.

MR. CANNON: Would you take into consideration at all any of the work done, the web page? I guess it's hard to see how effective that could be or would be in a short period of time.

It seems like you are putting out information to help folks in lieu of a regulation.

MR. BOLON: The risk that we see is fatalities. It usually takes several years for some kind of intervention to begin to show up. We will take that into account.

Probably the timing of any effect from that wouldn't catch up to even the time of the rulemaking, which is a multi-year event.

MR. CANNON: The January 8 date seems a little tight, between now and then. You have done it in two locations, one of which is here. Would you consider extending that January date just in case some folks would like to come? Short term decisions on travel can be expensive.

MR. BOLON: We're going to have a hard time moving off that particular date. We are open to anybody talking to us at any time. It doesn't just have to be in a stakeholder meeting.

The stakeholder meeting is just a very active us reaching out and trying to get more people involved and hearing from them.

We are in listening mode and we are receptive to anybody who wants to give input. Like I said, if there are employers who would like to talk with us, we will go to them and do a site visit. They will get individual attention.

MR. CANNON: Thank you.

CHAIRMAN STAFFORD: Tish?

MS. DAVIS: We may have talked about this before but the BLS data that you presented on fatalities, this is for back over events?

MS. SMITH: They got it from multiple sources. The narrative text searches in our system is certainly one of them. They also go beyond, checking death certificates. They have a whole network.

MS. DAVIS: We maintain the CFOI database in Massachusetts. They use 15 different data sources. They enter 72 variables. We have a field, which is a narrative text, that describes the incident. Each event is coded according to nature of injury, body part, event and source.

I don't think there is a back over event code. I think they must have gotten that by searching the narrative text field.

MS. SMITH: I think they may have added it this year because this is the first year they have had this data. I know they made some change.

MS. DAVIS: I'm just wondering how they got it. They might have added back over this year.

MR. BOLON: That was my understanding, they were going to add something and it was going to allow them to really pull out much more specific data.

MS. DAVIS:
I'm just wondering. The SOII database also has a narrative field describing the nature, how the event occurred. It's not coded.

What is missing in the epidemiology is the non-fatal injuries. We don't have a lot of good information.

I'm wondering whether the narrative text field -- if someone is backed over, that would probably be in the narrative description.

I'm just wondering if there is any way of getting more data on the non-fatal injuries, just to substantiate your arguments about the extended risks.

MR. BOLON: There are ways. One of the best ways is to get information directly from employers, particularly large employers. Getting information from large employers is how we are trying to get the information about the accidents where there is an injury or even property damage.

MS. DAVIS: Are they providing that to you in the comments? Did you get more information?

MR. BOLON: Not in the comments. In contacts directly with employers, we are getting information.

CHAIRMAN STAFFORD: Matt?

MR. GILLEN: I just wanted to point out that January 8 is the meeting of the ANSI A-10 Committee. There are about 60 or 70 people who come together to develop consensus standards for construction.

That is a conflict for them, and if it was January 9, some of them might stay over and attend the meeting. I just wanted to point that out.

MR. BOLON: We will look at it.

CHAIRMAN STAFFORD: Has it already been announced in the Federal Register, the meeting?

MR. BOLON: It actually was just announced when Jim announced it to you. The meeting here, we can look at moving the date by a day or two, if you want to move it around the ANSI meeting.

CHAIRMAN STAFFORD: Chuck?

MR. STRIBLING: Two quick questions. Did you get any comments with regard to hand signals?

MS. SMITH: I don't think we asked a question about that, so I don't think we did.

MR. STRIBLING: On site visits, what are you looking for?

MS. SMITH: What people are doing. What we have found in the couple we have done is there are some interesting common sense basically no cost solutions that a couple of people are using to help.

When they have an entire program, there are a couple of interesting things we have seen that we aren't able to think about sitting in our offices here, because there are situations in the field that we don't know about until we get in the field.

We are learning about those approaches and what people are doing effectively and what they want to do better or what is really helpful.

MR. BOLON: We have gone to employers where they have worked very hard on this particular risk, and sometimes we go to employers where it hasn't been as important. Of course, it is across many industries.

We are looking for employers who are in all situations in terms of back overs.

MR. STRIBLING: You mentioned the rule is going to address general industry or all industries. Are you also looking for non-construction facilities?

MS. SMITH:
Yes.

CHAIRMAN STAFFORD: Any other questions or comments?

MS. SHORTALL: All industries, would it include maritime and agriculture?

MR. BOLON: Yes.

MS. SHORTALL: Are you considering a stakeholder meeting on a coast, so that maritime could participate?

MR. BOLON: Hadn't thought about that. We are in contact with the Maritime Office in DSG. We will be reaching out to them, long shore as well as the ship yards. I hadn't thought about that. I do expect we will be doing site visits to some marine terminals and/or ship yards, but I hadn't thought about a stakeholder meeting for that yet.

MS. SHORTALL: Agricultural areas like Florida or California.

MR. BOLON: Yes. I don't have a plan that is drawn out for agriculture yet. As you know, agriculture is always a little bit of a question mark for our ability to do things there because of budget writing considerations, and just the jurisdiction that we have and the risks they have.

As of right now, we will be looking at what is going on in agriculture. I believe there are some fatalities there.

MS. SHORTALL:
Large field operations that have more than ten employees, doing picking, have a lot of vehicles in the field.

CHAIRMAN STAFFORD: Paul, I think it was at the last meeting, and Chuck, you can correct me since it was your work group, we had the Virginia OSHA here talking about their standard. Two meetings ago.

Do we know or is it worth the exercise of trying to understand from stakeholders in the State of Virginia what they think about that standard, if it is effective, a burden? Is that something OSHA would typically try to do?

MR. BOLON: Very much so. We will be in touch with the State of Virginia and we will be doing site visits to employers in Virginia to get a response from them.

MS. SMITH:
We asked a question about that in the RFI. We were disappointed in the number of people who responded to that particular question.

I think there was only one group that wanted to talk about their experiences with the Virginia regulation.

CHAIRMAN STAFFORD: Were they positive or negative? Do you remember, Meghan?

MS. SMITH: Relatively neutral, actually.

CHAIRMAN STAFFORD: Okay. Any other questions on backing operations?

(No response.)

CHAIRMAN STAFFORD:
Thanks, Paul and Meghan.

Is Cecil ready to go?

MR. TIPTON: I'm here.

CHAIRMAN STAFFORD: Paul, do you want to come back and talk about SIP? Is that the game plan?

MR. BOLON:
Yes.

CHAIRMAN STAFFORD:
Cecil? This is Pete Stafford. I'm the Chair of ACCSH. We want to thank you very much for joining us. I understand you are in Idaho. I'm going to say, what is that, two hours behind us?

MR. TIPTON: Two hours behind you; yes. We have coffee.

CHAIRMAN STAFFORD: We appreciate you joining us at 6:30 a.m. Cecil is going to talk to us about IMIS has now been replaced by the new OIS, and we started this discussion on surveillance and what data is available to us.

We appreciate you joining us, Cecil, and describing the data to us. The floor is yours.

MR. BONNEAU: Cecil, I have the slides up on the screen. You just tell me "next slide," and I will next slide it for you.

MR. TIPTON:
All right.

OIS UPDATE

MR. TIPTON: We were one of the first offices here in Boise to get OIS. We have suffered through it the longest. It is getting better daily.

It is a very impressive database. I think a lot of people were expecting something that was absolutely perfect and complete when it rolled out, and that just wasn't the case. They had to run it through us and see how it was working while we were using it before they could actually build it exactly the way we needed it to be.

It's very hard to explain what we do to somebody who is programming a database.

I guess we can go to the next slide. What is OIS? OIS means OSHA information system. What we had before, we had for a very long time, put in place in the late 1980s. We were still using that system up until this rolled out, and we are still using that system because there are some old cases, contested cases, cases that we are still waiting for abatement on, that are being handled through that system.

We still have this giant thing in our file room taking up a lot of real estate. Eventually, we will be able to unplug it and turn it off and maybe put a filing cabinet in there or something. They are still around but we are working to get everything over to OIS.

The roll out schedule, they started in just a couple of area offices and started rolling out on a regular schedule, doing a couple of area offices a week, just to get them on board.

There were a lot of problems in the first days, because when they would make a change to it, it would change other things, so they stopped the roll out periodically, suspended it, so they could get everything back up to usable, and started rolling it out again.

At this point, all the Federal offices, the Federal OSHA offices, have been rolled out. The next part of this is to roll the state offices, at least being able to get data into OIS. A lot of the states in our region want to use their data systems that they have had in place and not wanted to use this.

That's fine as long as they are able to marry up and get the data to OIS. I guess the most important part here is the data gets filtered through OIS and is available on the public website, all the public information. That is now available.

It is a web based database. We are relying on connectivity here. It is somewhat real time. We will talk about that a little bit later.

It is a little bit of a change from what we were used to because we had a system here in the office that we entered data into and then all this data at a certain time would be married up to the national server, the host.

This would happen only periodically, I believe at the end of the week is when that happened. The data that was available to the national office was only updated weekly.

What this means is the OSHA family has access to all the case files. I can go into OIS and I can type in an employer name, inspection number, any sort of data, and I can find an inspection that was conducted across the country. At my fingertips, I have the ability to look at citations that were issued, warning's, that sort of thing.

That is not available on the public website, but it certainly has helped us be able to identify trends and possibly looking at repeat violations and that sort of thing.

Here you have a picture of what OIS looks like. On this page, it doesn't really look overwhelming, but let me explain a little bit about what you're looking at there.

Across the very top, you see several tabs. When it is highlighted right now, it says "Inspection." There is an Investigation tab, a Violation tab, a Citation tab, Formal Settlement Agreement, Petition for Modification of Abatement, Contested Case, and Safety and Health Assessment.

Just focusing on the Inspection tab, that is the one that is highlighted, if you look below the establishment name there, there are other tabs. On this particular tab, you are seeing about a third of that page.

Each one of these tabs has an enormous amount of data in it. This is where OIS is kind of excelling. It is a very powerful database, a lot of data points that are entered into this thing daily.

We are able to retrieve that data. They are developing new reports almost on a weekly basis, that we can go in and find all these metrics that can show us where we are seeing hazards, how effective are we being in our enforcement. Are we seeing repeat customers, that sort of thing.

MR. BONNEAU: Cecil, before we go to the next slide, I just wanted to make you aware of and introduce to the audience that we have from the OIS Office, Gus Georgiades, who has joined us to help participate in this presentation.

MR. TIPTON: Gus, anything you want to add on this page?

MR. GEORGIADES: No, Cecil. I think you're doing a good job on that. The compliance staff has this web based application and are able to go into a lot of areas. I think we are going to show some of the stuff you can see that comes out of this.

The one difference in OIS versus IMIS, is the NCR system captured particularly construction sites. We had a mailing address and a site address.

Essentially, every time we would go out there and do a construction inspection, because we already had a mailing address and a site address, you almost create more establishments.

OIS has added another address to this thing, and it is the business address. We have the business address, the mailing address and the site address.

For instance, if there is like ABC Plumbing, and their address is 3824 Main Street, Omaha, Nebraska -- hoping to be able to solve one of the problems we have of just having the site address.

MS. DAVIS: I didn't see site address up there.

MR. GEORGIADES:
The three addresses should be on there.

MR. TIPTON: I can tell you from an area office perspective, this has helped quite a bit, keeping things a little cleaner.

In the NCR, if you tried to look up a construction company, you would be overwhelmed. This way, you have one address and it's linked to all these other sites.

When you are looking at this, you see the same business address and you see all the different site addresses as well.

One of the things that is going to change, just for information purposes, at the very top there is going to be another tab added. This thing is evolving pretty much constantly, and eventually, I think, it will get to where it needs to be and everybody will be happy.

CHAIRMAN STAFFORD: Cecil, before we move to the next page, Tish?

MS. DAVIS: The establishment ID, is that the employer --

MR. GEORGIADES: That is something the system uses. It's not really important to the COSHO that is entering the data. They would look it up under the establishment. It is something that we do use in the background, but it is not real important for the COSHO entering information.

MR. TIPTON: When you put in a new establishment, it is assigned a number. One thing that the establishment ID would be handy for is if you knew the establishment ID for a particular company, you could type that in and it would pull it up.

You wouldn't have to worry about misspelling or anything like that. You can kind of misspell stuff and it will still pull it up.

MR. GEORGIADES:
What you are not seeing is there is an actual establishment area where you enter the establishment, and it actually pulls the establishment information into Inspection.

MR. TIPTON: As I said before, all the Federal offices have been rolled out and are using OIS. Again, the old NCR machines are not gone yet. There is some stuff in there that we are still using them for. We very infrequently use them. I can't remember how to log into it, it's been so long. There is still some stuff we are updating in it.

The newer offices that have been rolled out, they certainly have a lot more than we do. We have maybe a handful of cases that are still in there that we have to update.

I said we would talk a little bit about the real time. It is certainly more real time than NCR. The data is updated three times a day.

I'll show you an example of the sort of data that can be pulled up with OIS in the next slide.

Like I said before, the NCR was updated once a week, in fact, on Friday. After that, anything new, it wasn't available until the next week. It was stuck on our local machine here before it was uploaded.

This is a web based program, so it is immediately put into this database. Every time they update, it's already there. Three times a day, it becomes at your fingertips.

Some examples of the statistics we can pull out of OIS. Most of them are metrics that we use to make sure we are doing our job properly and that we are focusing our efforts in the right places.

Some of the examples are violations per inspection. These are all search fields that we can enter into OIS and pull this sort of stuff up.

Statistics for specific city names. You can type in a city name. Typically, what we do for identifying a specific area, you can search by nationwide, you can search by region, you can search by state. You can go down to the area office jurisdiction.

Sole proprietor versus corporation. That is one of the data fields that is in OIS. We can enter in a corporation. We can enter in a sole proprietor, Federal Government.

If you enter it in there, that data point is there. You can go in and mine that data by those fields.

This is just an example of some of the information we can pull up.

This is comparing Chicago to the national average, the average initial penalty for serious violations. Chicago is handling folks out there compared to the rest of us.

This is an example of where an area office can go in and see what they are doing and how it compares to the national average.

If there is a huge disparity there, it triggers the area directors and assistant area directors to go in and say why is this. It may be simply you are not seeing the degree of serious hazards that Chicago may be seeing or it may indicate there is a problem in enforcement. Maybe we aren't looking at things in enough detail.

Inspections with repeat violations. On the right column there, you have the national average. This is total inspections with repeat violations. This is 6.5 percent of all the inspections that Chicago had, fiscal year 2012 numbers, were repeat violations.

That is violations per inspection. It looks like Chicago and the national average were dead on there. In the data I've looked at, it's been pretty close to that, about two violations per inspection, 2.5/3.

This is another method we can use to determine if we are going in and finding the first serious thing and addressing it and turning around and leaving, if we are spending enough time in these places to actually affect safety and health.

Gus, do you have anything to add to that?

MR. GEORGIADES: No. Just different ways the staff has access to the data. Sometimes people are looking for employer size, as Cecil said. It allows them to pull it into sort of a spreadsheet format, sort of slice and dice it the way they want to look at it.

It uses what is called "business objects." The report comes out and you can save it in your computer. If you save it in a spreadsheet, you can take it and look at the data in different ways.

MS. DAVIS: For example, stratify by construction?

MR. GEORGIADES:
Yes, you could do it that way. It also allows them to really pull the data out and see what they are getting out of this. The report is sort of like a PDF version. It's a screen version.

The best way for staff to use it is they save it on their own desktop.

MR. TIPTON:
One of the other ways that we use the data here in the Boise Area Office is we look at the emphasis programs and how many inspections were done under those emphasis programs. I'm pretty sure they look at that in the national office as well pretty closely.

We have national emphasis programs, local emphasis programs, and strategic codes that we look at. We can go in and look at how many inspections we did where we looked at fall hazards or how many inspections we did where we looked at commercial construction or residential construction, highway, street and bridge construction, and so on.

All those different things, we can go in and see how many inspections we did, the ones we did for the year, how many did we actually spend on those specific areas.

There is a lot of data at the click of a mouse.

The website data, this is the stuff that is transferred from OIS to the OSHA website. This is stuff that you guys have access to and probably have looked at before.

A lot of the construction companies here in Idaho have looked at this, especially general contractors. They want to see if the subs they are awarding contracts to had issues with OSHA.

It's all public information once you are visited by us. Everything is entered and the citations are issued and it becomes public information. You can even go in and search for what citations were issued.

The inspections show up the day after they are final. The idea here is the Agency -- pretty much every area office now at this point, we have laptop computers with remote access to the network. The idea here is the compliance officer goes and does an inspection.

If you're on the road, you go back to the hotel and you are able to enter this information into the OIS. The next day, that information is available on the public website page.

In a lot of area offices, there is no overnight travel. We are the only office in Idaho. We travel and use our laptops a little more than other areas.

Citations may not be available on the website for five days. I don't think there is a rule of thumb on this. Some citations, you see the next day. Sometimes, it's five days.

When the citations are issued, they are there for you to view. All you are going to see is what standard was cited. If you are hiring a mason and you want to see if they have had any issues with respiratory protection, they have been addressing silica and that sort of thing, you can go in there and get an idea of what their history with OSHA is.

I am sure you guys have seen this before. This is our public web page, OSHA.gov. Again, it is set up with tabs across the top.

The data and statistics is where the OIS data is. It is also data that came from NCR. All the inspection data is here.

If you click on the Data and Statistics tab, this is what pops up here. There are a lot of statistics that you can look at, specific injury and illness data, BLS work related injury and illness data. You can search by the industrial code.

What we will focus on is the establishment search. This is the establishment search screen. This is where the public can search for information. You can isolate that to a certain state. The Fed and state, is that state under Federal or state jurisdiction.

The OSHA Office, you can search by an area office or all offices.

Case status, closed or open, the closed cases are the ones that have had citations issued and are final. Open cases may be in progress and may not have citations issued yet. There may be citations issued but they are awaiting an informal conference or they are in context, something of that sort.

Inspection date. If you know about the time the inspection was conducted or if you are only looking for a certain period of time the company was inspected, you can select that. You can filter it out.

If you are looking at their entire history, you can go all the way back to the beginning of OSHA enforcement.

Generally, when you are looking at this, you are looking at establishments.

This is what comes up when you do the search. The activity number on the left hand side there, that is the inspection number. That is a number that is assigned when you enter information in for an inspection that was conducted.

It looks like this was in Illinois. It gives you the establishment name over on the right, how many violations were issued for each one of those inspections and citations. You have the North American Industrial Classification System code there. You can go on the website and type that code in there and figure out what the industry code is for that company.

"SC" is the scope of the inspection. You can see if it was partial in scope. For example, GDO Masonry, Inc., it says "partial," a partial scope inspection. Probably because of the subcontractor and specific to what they were doing, not necessarily the entire job site.

The type of inspection, plan. Those would be the program planned inspections, the ones we have assignments for. We know they are going on. We go and do an inspection of that site.

Accident would be related to a fatality or catastrophe.

One inspection would be for a formal or informal complaint.

The opening date there is when the inspection was opened. "RID," that is just an identifier for the area office that conducted the inspection.

If you drill down into one of those inspections, this is the information you get. The note at the top says "The following inspection has not been indicated as closed." These things are not completed yet. There may be more citations coming. It's not a complete picture.

On this little note card at the top, you have the office that conducted the inspection, the establishment name and address, the NAIC code and description of what that code is, and then the mailing address.

In this case, you can look at the type of inspection, was it safety or health, if you are looking at safety issues or exposures to chemicals, which would make it health.

The emphasis program, it was a national emphasis program for drench and excavations.

The violation summary at the bottom, that shows you a summary of what the violations were. It will give you a number of serious, a number of willful, a number of repeat, other, and the initial penalty and current penalty.

The current penalty, that one may change. If a company comes in and has an informal conference where they negotiate the penalty or through settlement.

At the very bottom there you see the ID number. That is the citation ID number. The type of citation, and that's the standard.

In this case, it was 1926.652(a)(1). Anybody that is involved with drenching and excavation would recognize that one. The current and initial penalty for that citation.

The initial penalty, it may be larger than that. At the very bottom, it will break it down per citation.

Any questions on that?

(No response.)

MR. TIPTON:
One of the things you can see here, the initial penalty and the current penalty have changed. The current penalty is now less than what the initial penalty was, indicating there was a settlement.

MR. GEORGIADES: Excuse me, Cecil. One of the things we are trying to do, and I think the next couple of slides will probably show it, in the past, we have looked at inspections, and it is open, so if it is open because of penalties haven't been paid, abatement is still open, we are trying to indicate that in the future, particularly if abatement is still open. You want to know that.

The system as it is right now doesn't really give you a good indication why the case is open. The next couple of slides, you should be seeing these enhancements coming soon to the website.

MR. TIPTON:
That would be helpful certainly to the public, where we are just trying to do a quick search on the public page to find something. That's helpful.

I'm not sure what slide we are on right now. I'm to the slide that says "Public Website, Case Status Descriptions."

MR. BONNEAU:
We're there.

MR. TIPTON: These are the descriptions I pointed out on the slide before, where it is open or closed. Depending on the violation, violations under contest, pending penalty payment, penalty payment plan in place, all those things are not ready yet, I guess. I guess they are not there yet but will be there.

That will be helpful. You can go in and search these establishments and know what is actually going on with the case.

The last slide. I'll be happy to answer any questions you guys have.

CHAIRMAN STAFFORD: Tish?

MS. DAVIS: I have several questions. One is does this bridge to the old system so that if you want to look at the inspection history of a company back ten years, you can?

MR. TIPTON:
The public website has information from the old NCR further back than that. Information all the way back when enforcement began at OSHA to now is on the public website.

If an establishment name hasn't changed in all that time, you can go and search everything, all the OSHA dealings they have had since the beginning of OSHA.

MS. DAVIS:
Does the system, your internal system, have a case management function whereby all the communication and so forth related to the case is in the same web based system?

MR. TIPTON:
It has that capability. We can actually upload anything. We can upload pictures, although we don't do that. We do upload a lot of the case file documentation that we work with. It has that function. Right now, we still have paper case files.

MR. GEORGIADES: I'll give you a couple of examples. That is one of the issues we struggle with on that.

Think of a large chemical plant where we have walked out of there with boxes. If the case gets contested, you are citing the employer's training program, we ask them for their training manual. I'm not sure it benefits any of us to upload all that, and we have storage issues.

The one thing that OIS has that the other system didn't have is a lot of the text that goes into OIS stays in OIS.

What Cecil was alluding to earlier, any compliance staff who has access to OIS could go in and see what the actual person did on the inspections.

We still haven't figured what we want people to upload into the system. I would guess like in the future the signed settlement agreement, just to make sure everybody is looking at the same document at the same time.

As we go forward and the executives of OSHA start looking at it and start making some positive decisions, what is the minimum we want uploaded in there.

MR. TIPTON: That's been one of the challenges we have found, trying to figure new ways to keep track of cases. We are still dealing with an administrative paperwork directive that is very dated and does not include a lot of the electronic resources that we have at our disposal now.

That's probably in the works. It's probably being updated. That is still what we are working with. Until that gets updated, we are still going to do what we have always done, we just have a better tool to kind of get that accomplished now.

We still have paper case files. That probably will not go away because of what he described. If we are looking at a chemical processing plant, we are going to come back with a lot of paper. Scanning all that into a PDF would take up a lot of room.

MR. GEORGIADES:
A lot of that stuff was asked for and built into the system. It's just as we go forward, what is the best way to use it, what is the best use of resources, and storage capacity as we go forward.

CHAIRMAN STAFFORD: Don, Roger, and then Ben.

MR. PRATT: What happens when there is an error found in data input? I'm not sure even how this would be found. Let's say an employer went in on the public site, because that's what he has available to him, and he finds an error.

What's the procedure to correct that error?

MR. TIPTON:
Some errors in input are found. We have regional IT people that kind of audit this stuff, the reports. If something is not matching up with the report and what should be in the system, they find that.

If it's an error you would see on the public website, I'm not sure there is a procedure, but if you called the area office that's responsible for that file, which is listed on the website, I'm sure they could go in and fix whatever it is.

A lot of times that error may be they spelled the street address wrong or something like that.

MR. PRATT: I'm looking at something more egregious than that, like there is a violation and they put in the wrong site or they have the wrong employer. I'm fearful that with a system like this, employers are not protected in a way that if there is false information put into the system, garbage in, garbage out.

MR. TIPTON: That's true. If that false information was put into the OIS, then that citation would have been sent to the wrong person, and it would be found a lot sooner than somebody finding it on the public website.

All this stuff is tied into what we do for enforcement. If there are citations issued and it has the wrong employer, that is going to be found out a lot sooner than finding it on the public website.

Anything that goes through the office, through the review process, it is going to go through the compliance officer's supervisor to make sure it's the right standard, it's a prima facie case, and it's going through the area director for final review and actual issuance of the citation.

There are post-citation procedures, informal or formal settlements and that sort of thing.

If it gets through all those cracks, then it's possible the bad information will end up being here on the public website. It's not very likely something that egregious would be on the public website.

It's possible the wrong NAIC is listed. With a smaller employer, it's possible we did an inspection and issued citations where we shouldn't have.

Beyond that, that should be caught during the review as well. All those things should be caught at the area office level and at the different review levels going on from the initial inspection, it would catch something that egregious, I'm pretty confident.

MR. ERICKSON: Just a question, and I might have missed this, in regard to your real time data and how we are going to update three times a day.

Is that also on the public site or is that just your internal site?

MR. TIPTON: The OIS itself gathers up data, the information we have to report, that is updated three times a day. I would assume the public website would be once a day.

MR. GEORGIADES: Yes, it's basically done overnight for the public website. What they are looking at is in OIS, there is an application, and it is a reporting database, so the screen shot you saw with the person enters the data, that is real time with the compliance staff.

If I entered right now, everybody within the compliance staff could look at it right now. If I want to run a report on that data, that is updated three times a day. For the compliance staff to run a report on the data, that is what is updated three times a day.

The stuff that goes onto the public website is usually done overnight as it changes.

MR. ERICKSON: Thank you.

MR. BARE: Gus, what I've seen demonstrated is use of the information to a Dashboard, something like that. Is that just internal or is it going out to the public at some time?

MR. GEORGIADES: Most of that is internal. We are working with the Department of Labor. I think in the future there will be some more visualizations. I think they are working on some of that stuff.

As we go forward, we are going to try to do some internal visualizations for staff. I know as we get further and further along on this thing, putting more fatality data into a MAP, those kinds of things.

MR. BARE: If that comes to completion or as you get close to that, I think maybe ACCSH would be interested in hearing about that, and a demonstration.

MR. GEORGIADES:
Sure.

CHAIRMAN STAFFORD:
Matt?

MR. GILLEN: Is it inspections that resulted in citations only or is it all inspections? Somebody put in a complaint for methyl chloride and OSHA comes out and samples, but there is no over exposures, is that an inspection?

MR. GEORGIADES: The inspection will be in there. We talked about the inspection being put in final. You will be able to search for companies that have had inspections but no citations. Just remember what you are looking for, like if it's a closed case, is a moment in time.

If an inspection is up there but the case is not closed, that doesn't mean necessarily that there are no citations. They may be pending.

MR. GILLEN: Thank you.

CHAIRMAN STAFFORD: Any other questions or comments from the committee?

MS. DAVIS:
I'm sorry. I spend my life doing these kinds of databases. For your complaints and referrals, do you differentiate by injury initiated investigations?

Is it able to go in and do that, or are they managed just planned inspections, fatality inspections?

MR. GEORGIADES: What we term as investigations, usually it's a fatality or catastrophe. We will put more data in. You don't necessarily link injuries with inspections that easily. We don't go out and inspect every case of hazard injury.

MS. DAVIS: I was just wondering about differentiating inspections that have been prompted by injuries. We make a lot of referrals to OSHA based on injuries.

If I wanted to go in and look at your injury initiated inspections?

MR. GEORGIADES: You won't necessarily know it has been prompted by an injury.

CHAIRMAN STAFFORD: Chris?

MS. TRAHAN:
[Inaudible.]

MR. GEORGIADES:
Obviously, if it is a fatality, we would assume it was initiated as a fatality.

MS. TRAHAN: The items that the compliance officers see had a tab for settlement agreements. I'm wondering if informal settlement agreements are being entered and used during investigations.

MR. GEORGIADES:
The informal settlement agreement process is entered into OIS. The informal settlement agreement information is put into OIS, for instance, if you were to look in OIS as a compliance officer, you would see that case change, so you could see the history of the event.

MS. TRAHAN: I understand that. The actual settlement agreement text, so that other compliance officers say in different cities could review the text of an informal settlement agreement reached with an employer say they are investigating the same employer in Denver.

MR. GEORGIADES:
I imagine that is one of the enhancements in the future.

MS. TRAHAN: It is not in there now?

MR. GEORGIADES:
Right now, it is not routinely done. I don't think so.

MS. TRAHAN: Cecil, is that done in your office?

MR. TIPTON: No. The informal settlement agreement, the information that is in that tab is basically when the informal settlement agreement or the informal conference took place, when the settlement agreement was signed, when it became final.

It also lists what changes were made to the citations as a result of that settlement agreement. It will show if a citation was deleted or a penalty was changed or abatement was changed, that sort of thing.

As far as the actual wording of the settlement agreement, for these changes, what we are asking the employer to do, that wouldn't be available on OIS.

MS. TRAHAN:
I think the committee has been thinking how they might help the Agency better target for enforcement, for programmed inspections.

Right now, you see in the data system if it is a programmed inspection if it is a national or local emphasis program, it is coded in a certain way.

Is there any coding if it's a programmed inspection that is unrelated to one of those programs, such as a Dodge selected site?

MR. TIPTON: Yes, the Dodge reports, that is coded in there now, and that is changing. It is becoming kind of a quasi-national emphasis program. That is in there.

Are you asking if we are able to code for a specific hazard?

MS. TRAHAN: No. I'm just trying to see if there is a way to look at data from enforcement activity that was initiated under a Dodge report inspection versus a local emphasis program versus a national emphasis program, or other types of programmed inspections that maybe I'm not aware of.

MR. TIPTON: Yes, you will be able to look at -- it will break them down into each one of those emphasis programs. I haven't done a search nationwide. It would take a long time for it to actually populate a summary for the entire country.

I did do the search for Idaho basically. That sort of information is broken out there. I can see how many programmed inspections were done, and from that number, I can see how many were related to a Dodge report, how many were related to a referral, an official referral. That would be an un-programmed inspection.

It would break it up that way and then you can look at what emphasis program it was focusing on or what strategic plan. If there was a programmed construction inspection, we could see if it was commercial construction, residential construction, or highway, street and bridge construction.

MS. TRAHAN: You can look at size of employer? I think that may be a data source for the committee to think about targeting.

Thank you.

MS. DAVIS: It is really being able to identify what initiated the inspection within the broader categories, in order to assess different methods of targeting.

MR. GEORGIADES: Internally, they see all that stuff. You could go to the actual inspection itself.

MR. BARE: Gus, just to clarify, what Cecil was talking about, is that available to the public or is that an internal report that you can identify why an inspection was initiated, off Dodge reports or whatever?

MR. GEORGIADES: It's not so much not being able to see it by individual inspections. It's being able to run the report that way. On the public website, you don't have that option being able to run the report that way. Internally, you can run the report any way you want.

The staff really does have the ability to see that stuff.

So, say I want to compare my program under the program that was done, my program that was done, let's say in Region 2, you can do that comparison internally.

MS. ABRAMS: Hi, Adele Abrams. The question I had, when you were talking about posting of citation data, you indicated that on the private side of the website, in other words, the Agency side, all of the information in a citation would be included, but that would not be available on the public side. It would simply list how the citation was classified and what standard was cited.

I just wanted to suggest that perhaps in the interest of transparency, that information could be available to the public.

I can see from a safety perspective there being some good reasons for that, one of which being it would allow corporate safety and health professionals to look at all their establishment inspections, and really see the data.

I deal with a lot of companies. Very often, stuff is handled at the local level and the corporate people don't necessarily get that real time information.

The second thing is for contractor and subcontractor pre-qualification. If you're looking at a company that is putting in a bid, you may see they had a HAZCOM violation, but you don't if it is because they left something off the chemical inventory list or did they not train their workers. It could be a little better to have that information.

Also, for general duty clause citations where it is not pinned to a particular standard. If you simply see the subcontractor has had general duty clause citations, you really don't know what is involved in those.

I think the data could be very important. There's fraud protection.

MR. TIPTON: The general duty clause citations, they actually do include that in there. You can click on the citation and it will pull up the general duty citation. It's hard to read sometimes because it's just words that are transferred over. That is there. The normal standard violations, they are not listed that way.

As HAZCOM goes, it would show you all the way down to the subparagraphs what was cited. If you are looking at a labeling violation, you don't know if it was water, if it was hydrochloric acid.

MS. ABRAMS: Exactly. If it is a trenching and excavation standard and it is for somebody being in an un-shored trench, you don't know whether that trench was 5.5 feet deep or 25 feet deep.

The egregiousness, I guess, of the citation is something that would be of interest, not only to the employee community, but I would think to the employer communities or the Unions to be able to mine that data.

I am doing a lot of work right now on contractor issues for an association. Pre-qualification really demands that you know exactly what the company has been accused of in the past as well as what the status of those inspections are.

It just seems since you are already doing the effort to put the data in, it would be easy to make that available on the public side of the website.

CHAIRMAN STAFFORD: Thank you. We should recruit you for our procurement checklist project.

Any other questions or comments? George?

MR. GEORGIADES: Thanks for that suggestion. Any time, please call the area office up, if you want a copy of the citations, we will be glad to send them to you.

MR. KENNEDY: My question is basically are these citations posted on the public side prior to them being finalized? If they are contesting it or if they are waiting for a hearing, are they being posted the next day?

MR. TIPTON: The citation would be on the public website when they are issued. That is what I was showing you before. If it is still open, it will indicate that. It's not a complete picture yet.

A citation, once they are issued, they show up there, if they are serious, and what the initial penalty will be, and then later, you would see a change to that following a settlement.

MR. KENNEDY: It seems like they are being posted before an employer has the right to his day in court.

MR. GEORGIADES: You are correct. If it changes, if they go to a full settlement agreement, it is updated.

MR. KENNEDY: Some of these could go on for six months and a contractor could be bidding jobs and losing jobs because there are citations that have been issued and maybe he doesn't agree with them, and let's face it, OSHA is not perfect either, we're not either, but that's a concern.

MR. STRIBLING:
Just so you know, every state that has a state grant has their own state statutes they have to meet with regard to public disclosure. When it goes out the door, it is public record. No if's, and's or but's.

CHAIRMAN STAFFORD:
I think Cecil said this, on how the system captures state plans, state information, how often is that put into the system?

MR. GEORGIADES:
The public website shows you, these are put in the same way.

MR. STRIBLING: We still use the NCR. In case some of the new members may not know, "NCR" stands for National Cash Register."

(Laughter.)

MR. STRIBLING: That is how old the system is. We still interface through NCR and then to IMIS, but none of that is available from the states. None of this. We don't know when it will be. You don't realize the mountains they had to move to get to the point of where they are at. It's incredible the amount of work they have done.

I think it's fair to say it has not been a pain free process.

MR. GEORGIADES:
We are seeing all that stuff.

MR. STRIBLING:
Some states are going to be going to OIS and some aren't. There are going to be limitations with the OIS system. OSHA is one system. They use all the same forms.

You have 27 different states. We don't all use the same forms and letters and policies and procedures. The states are still working with OSHA. To their credit, they have involved the states almost from day one, depending on who was working on it. It's been going on that long.

The state information is always going to be going into the system. It may not be going in via OIS.

CHAIRMAN STAFFORD: If I wanted to see what was going on in Kentucky and I wanted to look into this system, would I see that today?

MR. STRIBLING: You will still see it at OSHA.gov, but the Commonwealth of Kentucky is not going to be using OIS. I know there are presently two other states who are not going to be using OIS.

MR. GEORGIADES: There are some states who actually will use the application. Some states -- this has been done in the past -- because they report up to their state, there is a lot of data that goes to their state, they may use their own system.

We can take that data and put it into the OIS system and another main frame computer puts it up on the public website.

MR. STRIBLING: The big advantage for the states is by using our own program, we can customize it for our particular needs. It allows us to build in many, many features, primarily because of funding, that we had the money to spend to put in checks and things, reminders, all kinds of things that we can do.

It allows us to keep our data and mine it in a way that OIS wouldn't do based upon other features we built in.

Bottom line, we are going to interface with OSHA, so when you go to look at the data, you are going to see all the states as well.

CHAIRMAN STAFFORD: Tish and then Ben.

MS. DAVIS: It's probably a question for Ben or others here. What has been the response of the COSHOs to the new functions? I know it's always difficult to get people to change, but are they finding the new kind of report functions useful? Do you have any sense of that yet?

MR. GEORGIADES:
I'll answer. It is more computer based, there is that learning curve. The NCR system is sort of a real blue screen. It is a learning curve.

What is your feeling from a COSHO perspective?

CHAIRMAN STAFFORD: Are you still there, Cecil?

MR. TIPTON:
I am. I'm hearing some music.

CHAIRMAN STAFFORD: We thought that was coming from you.

MR. TIPTON: No.

CHAIRMAN STAFFORD: Damon, you're the technician.

MR. BONNEAU:
Speak loud.

(Laughter.)

MR. GEORGIADES:
When a new person comes in, they adapt to a system. There are things that are in different places. You do adapt to it.

MR. TIPTON: We have been using this for a while, over a year now. There certainly was growing pains and learning curves. We have noticed people that were not so computer savvy before found this more difficult. It is more modern. There is a lot more places to go look and enter information into.

With repetition, it gets easier, it gets faster, and once you figure out what information has to be in there, it's a lot easier to use.

Certainly, it has been a learning curve. There has been a lot of grumpiness because of it. Once we get beyond that, it's actually starting to work pretty well.

CHAIRMAN STAFFORD: Any other questions or comments?

(No response.)

CHAIRMAN STAFFORD: Cecil, on behalf of all the committee, we thank you for calling in at such an early hour. We appreciate the presentation. Gus, thank you for joining us as well.

MR. GEORGIADES: We apologize that the person who was supposed to do the presentation couldn't make it. Thank you.

CHAIRMAN STAFFORD: Thank you. We really appreciate it.

Let's go ahead and take a break. We will reconvene at 10:00.

(A brief recess was taken.)

CHAIRMAN STAFFORD: Let's reconvene, please. A final reminder. At the end of the meeting, we will have a public comment period. If you would like to make public comment to the committee, please sign the sign in sheet.

We have two items left on the agenda this morning. Paul will do SIP IV first and we will talk about post tensioning.

Sarah needs to add a few things.

MS. SHORTALL:
Before we get into the presentation, Paul, I'd like to enter into the record as Exhibit No. 33, Walter Jones' proxy designating Pete Stafford to vote in his place today.

As Exhibit 34, OSHA Information PowerPoint presentation.

CHAIRMAN STAFFORD: Thank you, Sarah.

Paul, update on SIP IV.

UPDATE ON SIP IV

MR. BOLON: SIP stands for Standards Improvement Project. This would be the fourth such project that OSHA has done. Dayton Eckerson is the staff person that is working on SIP.

When I talked to ACCSH about SIP in the last meeting, I thought when I was sitting here today that we would be discussing items in a proposal. What has happened is this being an election year, the review and clearance process has slowed down.

What we were going to do was publish a Request for Information in the Federal Register to initiate the project. We prepared that. It was actually that cleared by OMB within the past week to be published.

Before, I had anticipated that would be published in the Summer. There would be a 60 day comment period. Then we would be presenting to the Advisory Committee a lengthy table of ideas and ones that we initially thought we would go forward with as a proposal.

Since the RFI is only going to be published in the next week or two, we don't have a proposal for you.

I guess my news is the RFI will be published very soon. As soon as it is posted by OMB, we will send to the committee that posting and next, we can forward the Federal Register Notice.

At that point, the Docket will be open, I believe, for 60 days. The public is invited to offer ideas.

Besides the formal process, going on Regulations.gov and offering ideas, you can always contact us, that is Jim or myself, Jim Maddux, or Dayton, and give us your ideas over the phone or e-mail. We keep them all.

The Docket is a great way for the public to be informed and participate. It's not the only way we will take ideas.

I just wanted to mention a couple of things about the Standards Improvement Project. It is not normal rulemaking. We usually don't address new areas of risk. It's done to fix items, to correct items.

Sometimes we can change things and provide more protections. Generally, it would be things that don't create a lot of new costs.

It is formal rulemaking. We have a proposal, but we usually don't have public hearings. The items are not that controversial. We don't have a small business panel because we are not imposing costs on small employers.

With that, I'll just mention the kinds of criteria that we look for for things we fix in SIP.

First, ideas to provide more alternatives than are in the current standards, and therefore, provide alternatives, flexibility for compliance.

We take actions on things to eliminate unnecessary paperwork. We will delete provisions that we think have been determined to be unnecessary for employers to do.

We will rewrite language to make employer responsibilities clearer. Sometimes there are inconsistencies within our standards, and we will address that and resolve that.

If there is new technology or a more effective way to do something, to provide employee protection, we will make that change.

I think the item that came up last time that falls under this was in the tunneling standards where tunneling is often done with variances. One of the major things there is decompression tables that OSHA thinks are out of date. There are several more that are better.

That is the kind of thing we can pick up through SIP, but it doesn't get into the cost to small business type issues.

Sometimes we delete obsolete or antiquated standards, and then we will fix typographical errors, ambiguous language, grammar, and such things like that.

That is the criteria and the kind of candidates we look for and we will be looking for again once the Federal Register Notice is published.

CHAIRMAN STAFFORD: Thank you, Paul. I want to talk with staff at the end to get some kind of inkling on when the next ACCSH meeting may be, and if we are the cycle we have been, we can anticipate that it probably will be in the May-ish range.

How does our next meeting kind of fit in with the time table of getting formal input or action from this committee?

MR. BOLON: It fits in pretty well. There is a 60 day comment period. We will look at all the suggestions, candidate ideas that have come in, evaluate them. We will select the ones we want to propose.

I haven't talked to Jim Maddux about this, but I would like to present ACCSH with that well before the next meeting, so you will have time to look at it and think about it, and we can have a good discussion.

Hopefully, before the meeting, we can distribute it. You will have time to look through the things that were offered and the things we initially at least would like to propose.

CHAIRMAN STAFFORD: Okay. I think that would be great and we would appreciate that.

Any questions or comments on SIP IV?

MR. STRIBLING: Paul, I think a few things may have come your way that the states sent in to Steve. When the comment period opens, does that need to be resubmitted? The fact that it came to you, does that count?

MR. BOLON: If you want to just contact me, Dayton keeps the table. We will check and make sure everything is on the table that should be.

MR. STRIBLING: Okay.

MR. BOLON:
You can always resubmit it to Regulations.gov.

CHAIRMAN STAFFORD: Scott, do you have a question?

MR. SCHNEIDER:
For the time table -- [Inaudible.]

MR. BOLON: If you all are reviewing and assuming coming to some agreement on giving us your advice in a May or June meeting, the approval process is roughly six months once the preamble is written, if OMB takes the full 90 days.

I can tell you it will be at least six months before the proposal would actually be published.

MR. GILLEN: Paul, the RFI, does it just ask for ideas or which ones you are thinking about and ask for ideas?

MR. BOLON:
It just asks for ideas.

CHAIRMAN STAFFORD: Any other questions or comments?

MS. SHORTALL: I think it is important to point out that if you want to go to Regulations.gov to provide your comments on this or anything else Paul was talking about, you need to make sure to also do it in writing. We need to have the material to be able to put into the Docket. Oral conversations, unless their staff has time to reduce them to text, they won't be reflected in the record.

MR. BOLON:
Yes. We have a number of e-mails. Good point.

CHAIRMAN STAFFORD: Thank you. Any other questions or comments?

(No response.)

CHAIRMAN STAFFORD: Let's switch gears, Paul, and talk about reinforced concrete, post tensioning and the RFI.

RFI UPDATE - REINFORCED CONCRETE AND POST TENSIONING

MR. BOLON: The RFI for reinforcing operations in concrete was published along with the back over in March. We had a 90 day comment period that went to July.

This is Blake Skogland. He is the staff person working on the post tensioning and reinforced area. He can describe what we got in terms of comments in the Docket.

CHAIRMAN STAFFORD: Thank you, Paul.

MR. SKOGLAND: I am Blake Skogland with DOC. I'm working on the reinforcing concrete and post tensioning part of the RFI.

As Paul said, the Docket closed on July 27, and since then, DOC has been reviewing the comments and reviewing fatalities and injuries associated with reinforcing concrete and post tensioning, and also reviewing our current standards.

OSHA received about 13 unique comments from a number of constituencies, including home builders, large construction companies, insurance services, concrete providers, equipment manufacturers, iron workers, foundation drillers, post tensioning systems manufacturers, safety professionals, trade unions, and ship builders.

One comment from the industry coalition of reinforcing stakeholders, very comprehensive, and there were about 80 comments that either were nearly identical or submitted in support of their comments.

CHAIRMAN STAFFORD: I'm sorry, Blake. What was the last group?

MR. SKOGLAND: Industry coalition of reinforcing stakeholders submitted a comprehensive comment and then there were either identical comments or comments in support of that comment submitted.

About four comments really got into the questions that we asked. Most of the comments were pretty short, talking about something very specific or just a general I'm for this or for this or against it.

About four comments really got into the lengthy questions that we had.

The coalition's comments reflected what was submitted to the committee in the impact report maybe two meetings ago or three.

MR. BOLON: I think it was the last meeting.

CHAIRMAN STAFFORD: Two meetings ago.

MR. SKOGLAND: In general, that comment was probably the strongest advocate for rulemaking and the comments in support of it. Many of the concepts in that proposal are similar to some of the newer certifications, third party evaluators, and written verification rules that we have seen in some more recent rules from OSHA that were negotiated.

The other comments focused on more particular topics, such as making and setting rebar, post tension, training, fall protection, rebar caps, safety products and site conditions.

None of the comments started out saying we are for this or against it, but you can gleam if they are or not. A lot of them were neutral. I would say the overall agreement of the comments was enforcement of the current rules is a must and increased training and inspecting is probably the most beneficial that we can promote in a possible new rule.

In addition to that, I just wanted to note that ANSI A10.9 is currently under revision, which is concrete and masonry safety requirements. I believe the committee is nearing completion on that. They may be having a final vote this month.

We are looking forward to what they have in that. Some of the proposals we have seen are very similar to the proposal from the coalition and other stakeholders.

Other than that, we have been reviewing fatality reports, trying to determine causes, how particular standards we have now relate to those, and we are still under that review process.

I don't know if Paul wants to add a few things.

MR. BOLON: No. Just to say I don't think we got any new information about injuries, accidents, fatalities in the comments in the Docket. We are still looking very closely at the accident reports that we have.

The Agency hasn't made a determination about what the next regulatory step is.

We did see a draft of the ANSI report eight or nine months ago, I think. Since it has gone into voting mode, we haven't seen what is in the final. I believe the final is supposed to be maybe cleared out of ANSI within a matter of weeks.

Our next step is to see what ANSI is going to propose and then the Agency will have to review everything and make a decision about going forward.

CHAIRMAN STAFFORD: What do you know in terms of the data, fatalities and injuries around this?

MR. SKOGLAND: In the comments, we did a lot of descriptions of the types of injuries that occur on post tensioning and reinforcing concrete, but we didn't get any new specific data about particular accidents.

As far as the information we have, we have information going back many years, but we focused on the last four years, from 2007 to 2010. We had 25 accident reports that mentioned reinforcing steel with at least one fatality, and reinforcing steel was directly involved in about 14 of those accidents resulting in 17 fatalities.

That is what we had over a four year period.

MR. BOLON:
We have to look at these, we have to look at exactly what their cause was. It might be a fatality where somebody fell 50 feet and hit rebar. When you look at that kind of risk, you ask yourself was it really rebar, was that a direct cause, or was it really fall and fall protection.

We have to see what kind of risks, what kind of accidents could be addressed by a new standard.

CHAIRMAN STAFFORD: Any other questions or comments?

(No response.)

CHAIRMAN STAFFORD: OSHA has no plans to go out and have stakeholder meetings on this topic?

MR. BOLON:
No, not yet. We are going to be briefing the senior OSHA managers and actually we need to look at what ANSI does first also.

CHAIRMAN STAFFORD: Thank you. Any other questions or comments?

(No response.)

CHAIRMAN STAFFORD: Thank you, Paul and Blake, very much.

MS. SHORTALL:
Mr. Chairman, at this time, I'd like to enter into the record Guidance to Compliance Officers for Focused Inspections in the Construction Industry, Memorandum for Regional Administrators, dated August 22, 1994.

CHAIRMAN STAFFORD: That is something that was handed out at the break. This is a follow up on our conversation from yesterday.

We have moved to the point in time where the formal agenda items have been completed. Is there anyone that is signed up for public comment? We have two signed up for public comment.

Nigel, please come to the table and introduce yourself.

MR. BONNEAU: When it comes to public comments, is the phone still open?

CHAIRMAN STAFFORD: I think Steve is still on. Right, Steve?

MR. HAWKINS:
Yes.

CHAIRMAN STAFFORD: Nigel, go ahead, please.

PUBLIC COMMENTS


MR. ELLIS: Thank you, Mr. Chairman. My name is Nigel Ellis. I've been in the safety business since 1970 and in the fall protection business since that time also.

I'm a regular reader of the BNA, and almost on a weekly basis we have words from OSHA Construction with words from the NRCA.

I realize there is a problem with re-roofing issues, re-roofing as a construction activity, and perhaps the need for guidelines.

Four years ago, I re-roofed my own house. Not me personally because I have the largest roofer in the Delaware Valley area. There were 38 squares to get done. I decided to videotape and take photographs of the entire activity.

Thirty-eight squares. There were two previous roofs. The entire sheathing was removed and replaced. I was essentially the safety director on my own house, with regard to roofing activities.

I can honestly say this roof was re-roofed with 100 percent fall protection, maybe the only home in the hemisphere with such a claim.

I actually published a video, a movie of this. I did present the entire package of 1,500 photographs I took and video's, 500 professional photographs, many taken from a aerial lift in my driveway.

The work consisted of the tear off initially and the chimney work, siding, and also taking care of four skylights.

The method I chose was a form of slide guards, which I believe were safe with a couple of rules and some instruction to the two foreman persons and the Spanish speaking work crew.

What I would like to offer, since we have an impasse right now it seems with NRCA members stopping using slide guards as they were presented by OSHA, perhaps restore them to a safer use of these devices with specification and with some rules.

I am proposing this might be an interesting presentation to present to you guys at your next meeting for whatever length of time I am granted, and to work up some proposal and some guidelines which might be useful for OSHA to work with the re-roofing industry, perhaps establish re-roofing as a type of work which is different from new construction of roofs and residential construction.

That is really my presentation. I am offering to present that. I have thousands of pictures to choose from, video's.

I would be bringing to the ACCSH Committee a level of technical competence, having worked in the fall protection field for 40 years.

Hope it would be relevant, and make sure that all the views of the different members of the committee are taken into account, and hopefully begin to move the process ahead so the ACCSH community can be effective in having a proposed resolution between the NRCA and its members and OSHA's commitments to safety.

CHAIRMAN STAFFORD: I appreciate that, Nigel. Any questions or comments? Chuck, please.

MR. STRIBLING: Thank you. We do have a standard that addresses residential construction fall protection, and we do allow slide guards with specific parameters.

Can you just share a little bit about the specs on the slide guards you use? Just a quick overview.

MR. ELLIS: As I recall, without looking at notes, these were two by six, right angles to the roof. I need to look into OSHA's records of how they came up with the system to begin with. The rule is critical, otherwise, this system is useless.

MR. HERING: I totally agree with you. You are probably the only person who had this.

I just want to point out, and you all know what we went through in New Jersey, I think just down in my area, every third house had part of its roof ripped off. We saw gusts of up to 130 mph.

I have only seen one contractor in four weeks that had fall protection. I'm telling you there were contractors all over. Only about several days after we had the hurricane, we had a snow storm.

I just said to my wife you have to put blinders on me, I can't keep watching this. It was unbelievable. This was a different venue because now you had literally thousands of houses with damage to the roofs, just the area I am in, which was about 18 miles north of where the eye came in.

It was just unbelievable to see. I don't know if there were any fatalities or who fell off a roof. There were an awful lot of people up on roofs, including home owners. Some of these houses today are pretty tall.

MR. ELLIS: I recognize it is going to take weeks and months to get done, with tremendous damage. There needs to be a menu of fall protection, and I'd like to work with the AGC to come up with what is the best way to present these things.

MR. PRATT: Nigel, I'm Don Pratt. I represent employers. I would urge you to share this information with the National Association of Home Builders. We are attempting to work with NRCA to see if there is some ground of commonality between re-roofing and new construction.

I would urge you to share that with them. If you can get out to Las Vegas, we are going to have a committee meeting at our International Builders Show in January. There may be time to be able to do some presentation at that committee meeting.

I urge you to contact them and see if there is some kind of ground.

MR. NIGEL: Thank you.

MR. STRIBLING: What was the pitch on the roof?

MR. ELLIS: 7.5 and 12, except near the access. I have a product called the Ladder Station, which relieves pressure off gutters for one access only, which was 12 feet. CHAIRMAN STAFFORD: Any more questions or comments? Matt?

MR. GILLEN: I would just like to thank you for sharing that information. It just goes to show we can achieve a high level of safety with an active, involved owner.

MR. ELLIS: Thank you.

CHAIRMAN STAFFORD: Nigel, thank you very much. Obviously, I can't speak to whether or not you will be on the committee at our next meeting as a public representative, but certainly in talking to the staff, we will consider your request for a presentation.

MR. ELLIS: That would also have in mind the idea that there would be a fall protection proposal in the future, and we could perhaps make use of my services.

CHAIRMAN STAFFORD: All right. We appreciate that. Thank you very much.

Bill Mott with Home Construction Group had signed up but Bill had to run to the airport. That was the last of the public comment unless any of you have changed your mind.

Steve, do you have any comments or questions you would like to make before we move on?

MR. HAWKINS:
No. Thank you for allowing me to participate on the phone.

CHAIRMAN STAFFORD:
We appreciate you joining us, Steve. It is time to wrap up. I don't see Jim in the room. If someone on the staff could give us a general idea of what the thinking is in terms of next ACCSH meetings or if it is too early to do that. I am just looking for some direction from DOC on what we are talking about here.

MR. BARE:
I think from our perspective, we are looking at there being another one or possibly two more meetings this year, probably one for sure.

CHAIRMAN STAFFORD: Calendar 2012.

MR. BARE: Right. I'm thinking fiscal year. In 2013, there will be one or two meetings. The next meeting would be like April/May/June time frame of 2013.

If you guys have comments or recommendations for the meetings, start thinking about those. I think, Damon, we will start planning that and looking at it in general. Damon will be in contact with you after consulting with Jim, see how things shape up for this new year.

We have a number of things going on in DOC, the rulemaking, RFIs, and so forth, that we are looking at, developing directives. We have other work.

CHAIRMAN STAFFORD:
Okay. Thanks. That is a pretty broad time frame. Damon, I'm assuming at some point, once you talk to Jim and the rest of the staff, the committee will be getting a list of options that we can consider for the next meeting.

MR. BONNEAU:
Absolutely.

CHAIRMAN STAFFORD: From the committee, if you have any closing comments.

CLOSING COMMENTS

MS. DAVIS: Our assignments are comments on the women's web page in 30 days and on the checklist and companion guidance in 60 days.

CHAIRMAN STAFFORD:
Right. I'll follow up with the Agency with respect to our outreach and training work group about the OSHA OTI outreach program and next steps on that.

MS. BARBER:
Also the web page and fact sheet for women in construction.

CHAIRMAN STAFFORD: Are due in 30 days.

MS. BARBER: I think we need to set a specific date to get the comments back from everybody, the ACCSH members. I don't have that date today. Is e-mail okay?

CHAIRMAN STAFFORD: Yes, that would be the preferred way. I think in our recommendation, Kristi, I'll have to go back and look at the motion we approved, I think we said it would be due within 30 days to the co-chairs and then fed to me. We ought to stick with that.

MR. PRATT:
Being new on the committee, I would just like to thank all of you for making me feel welcome. I was impressed with the process that took place. I am impressed with you, Mr. Chairman, and appreciate your effort and energy you put forth on this endeavor.

I look forward to many more ACCSH meetings.

CHAIRMAN STAFFORD:
I appreciate that. From my perspective as the chair of the committee, I think we had an excellent meeting this time. We are certainly making a lot of progress on a lot of fronts.

I would like to thank all the ACCSH members, our new members in particular, and of course, all the OSHA staff for your good work. It is really encouraging to see us press forward on some of these issues.

MR. HERING: I just want to add to that. I have been here for a year and a half now. I've been involved in a lot of things with safety in my adult life.

What I learned coming here is the passion for safety that you see with this agency and this division. From Damon and everybody on down, Jim, staff, Ben, everybody else, the passion for safety is here. You can see how they are working on it.

I just want to thank you guys, from our State of New Jersey and all we do in safety and health, and past president of ASSE, all the things I've been involved in, you guys are really the best. I just want to put that on the public record. Bill Hering, employer rep.

CHAIRMAN STAFFORD: Thank you, Bill.

MR. CANNON: I have a question for Ben following up with the type and capacity issue and hopefully coming to some type of resolution.

Is that an issue that this committee can play a role in?

MR. BARE: Yes. We can certainly consider that and follow up with that. Hopefully, there will be a resolution before then. If not, we will certainly put that on the agenda for you guys to discuss and consider and give us recommendations at that time, or if on an individual basis, if you want to communicate with us or through Pete, some work or some recommendations, we would certainly be interested in hearing what those solutions might be.

CHAIRMAN STAFFORD:
Thank you. This is with respect to the issue on certification, different capacities and types of cranes?

MR. HAWKINS: Yes. [Inaudible.]

CHAIRMAN STAFFORD:
I would be glad to do that for you, Steve. Any other questions or comments?

MR. HAWKINS: Thank you. [Inaudible.]

CHAIRMAN STAFFORD: Thank you, Steve. You, too, happy holidays to you as well. Sarah?

MS. SHORTALL:
I'd like to get a couple of things resolved on the work the work groups are going to do and giving those to ACCSH.

Yesterday, we were discussing Women in Construction. Letitia, in this motion, saying on behalf of ACCSH, because ACCSH is the body that OSHA responds to, saying that ACCSH recommends that OSHA incorporate the comments that are going to come in from the work group.

If there are any other things you are planning to give to OSHA and want them to work on prior to our next meeting, you may want to make a similar motion at this time.

MR. BETHANCOURT:
I'll make a motion based on Sarah's recommendation, any other comments we would like to work on in the next meeting, that we get that information out.

MS. SHORTALL:
No. You wanted to have a call, was it on OTI?

MR. CANNON:
The GAPs analysis.

MS. SHORTALL: Are you planning on having the GAPs analysis go to OSHA before your next meeting?

MR. CANNON:
Yes.

MS. SHORTALL: I would suggest you make a motion to the effect that ACCSH recommends OSHA -- do you want them to incorporate it or do you want them to study it?

CHAIRMAN STAFFORD: Hold on. I'm confused. What are we talking about here? A motion on what? GAPs analysis on what?

MR. CANNON: The plan is to do some work in between so we would have at least a list that we could reference during the next meeting, areas we have identified as having gaps.

CHAIRMAN STAFFORD:
What are we talking about?

MR. CANNON: Compliance assistance materials.

MS. SHORTALL: If you are planning to simply do that study and then present it at the next ACCSH meeting, that's fine. If you want something to go to OSHA before the next meeting, you should probably do that.

What about on I2P2? Is there anything that was going to --

MS. DAVIS:
I think we are going to compile information and present it at the next meeting.

MS. SHORTALL: Is there anything else any of the work groups wanted to have ACCSH give to OSHA before your next meeting, other than the Women in Construction?

CHAIRMAN STAFFORD: No, I don't think so.

MS. SHORTALL: A couple of other things. One, I have a card here for people to sign if they want to send their best wishes and condolences to Mike Thibodeaux. I'll leave that here.

CHAIRMAN STAFFORD: Thank you very much, Sarah.

MR. BETHANCOURT: I just want to clarify that on the information for the Women in Construction work group, we are still waiting for OSHA to give us copies of the Board documents or whatever that was.

Is there a time line that we say we need them to get us this information so we can get it done within that 30 days?

CHAIRMAN STAFFORD:
Danezza or Dean?

MR. McKENZIE: Dean McKenzie with DOC. We will get the PDF of the web page e-mailed out to the members.

CHAIRMAN STAFFORD:
Thank you. Jeremy, are you finished?

MR. BETHANCOURT:
That was all we needed; right?

CHAIRMAN STAFFORD:
Yes. Thank you.

MR. STRIBLING: I was just going to ask, Mr. Chair, if you could send out a memo on when they are due just so I can keep it straight.

CHAIRMAN STAFFORD: I'd be happy to, on both of these issues. I'll make a note of that.

MR. BARE: For clarification, when I looked at the handout's we had on the proposed website, weren't all the tabbed information included in the document?

MR. McKENZIE:
Yes.

MR. BARE: The headings on each page, they represent the tabs that were on the front page.

MR. McKENZIE:
That is correct. There are four buttons across the top of the page that have nothing. That material has not been generated or created yet.

You have been given everything. We can e-mail it out again, the draft material that we presented at the work group.

PARTICIPANT:
Danezza, the work group had asked about material on the resources page, specifically about reproductive hazards and other ones. Has that been written up yet? You said material was there.

MS. QUINTERO:
[Inaudible.]

PARTICIPANT: The work group wanted to see what was in that link.

MS. QUINTERO:
[Inaudible.]

CHAIRMAN STAFFORD: Jeremy?

MR. BETHANCOURT: I do have another thought. This is sort of directed to you, and I don't know if it's prudent. Would it be prudent for us to be able to see the information that Matt was going to get back to us on on the reproductive part?

Perhaps we can make better comments in that 30 day period, perhaps on what Matt has available.

CHAIRMAN STAFFORD:
Send it to the work group chairs and the chairs will sent it out to the rest of the work group.

MS. SHORTALL: Might be easier for you, Matt.

CHAIRMAN STAFFORD: It's not about making it easy for Matt.

(Laughter.)

MS. BARBER: What is going to be behind the tabs and who is going to determine that?

MR. McKENZIE: We will. It will be OSHA's product. We have to get approval from other directorates and the rest of the regional offices for all the material we put on there.

CHAIRMAN STAFFORD: If we give comments back saying we think you should link to this site or we think this training program should be on a tab, do those still have to go through the process of vetting all the materials that are submitted to be linked or added?

MR. McKENZIE: Yes.

CHAIRMAN STAFFORD: Once we give things to you, when could we expect it to go live?

MR. McKENZIE:
Our hope is in the reasonably near future to get the page live. It may not have all the content it will end up with. We add material to all our web pages on a regular basis.

CHAIRMAN STAFFORD: Any other questions or comments? Tish?

MS. DAVIS: In the spirit of keeping the issue of targeting on the agenda, the possibility of bringing David Weil in who has done this study, I just want to put that forward as a recommendation.

CHAIRMAN STAFFORD: Actually, Scott and I talked about that earlier at the break.

Any other questions or comments?

(No response.)

CHAIRMAN STAFFORD: Again, I want to thank everyone for your hard work and OSHA staff. Meeting adjourned.

(Whereupon, at 10:50 a.m., the meeting was concluded.)   *  *  *  *  *

EXHIBITS

Exhibit No. 33 - Walter Jones' proxy designating Pete

Stafford to vote in his place at today's meeting

Exhibit No. 34 - OSHA Information PowerPoint presentation

Exhibit No. 35 - Guidance to Compliance Officers for Focused Inspections in the Construction Industry, Memorandum for Regional Administrators, dated August 22, 1994