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<title>Oklahoma</title>
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<title>New Mexico*</title>
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<title>Texas</title>
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* This is one of the 29 OSHA-approved State Plans. Twenty-two State Plans (21 states and Puerto Rico) cover both private and state and local government workplaces. The other seven State Plans (Connecticut, Illinois, Maine, Massachusetts, New Jersey, New York, and the Virgin Islands) cover state and local government workers only.

Affiliated States
SVG Map Height
310
SVG Map Width
390
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0
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STOP FALLS STAND-DOWN COORDINATORS EMAIL
christie.meghan@dol.gov

Region 6 - Alliance Annual Report - October 30, 2012


Region 6 - Alliance Annual Report - October 30, 2012

MCEPS Annual Alliance Report
October 30, 2012


  1. Alliance Background

    Original Date of Agreement: Signed September 9, 2007
    Renewed: August 20, 2009
    Renewed: September 16, 2010

    Overview:

    The MCEPS Alliance was initially established in September, 2007 to improve and promote awareness of safety, health and environmental issues in the Energy industry. With renewal of the alliance in September 2010 to include the Oklahoma Department of Labor/Consultation (ODOL/CON) as participant organization, the goals and objectives of the alliance continued to focus on improvements in work site conditions and reduction in work site fatalities and injuries through the delivery of safety training and education and the development and sharing of accident prevention programs.

    Implementation Team Members:

    Members of the alliance implementation team are officers in the MCEPS organization, members of the MCEPS executive committee, and representatives of Oklahoma Department of Labor/Consultation.

    Joe Kennedy, Chesapeake Energy
    Kevin Edinger, Bronco Drilling
    Todd Smith, Newfield Exploration
    Mark Altom, Scientific Drilling
    Tom Beddow, Oil Patch Chaplainsv Bob Keeton, Greene's Energyv Joyce Ryel, Complete Production Services
    Matt Smith, RT Energy Services
    Diana Jones, OK DOL-Consultation
    Ann Gilliand,Ok DOL-Consultation
    Heather Hartman, OSHA

    2012 MCEPS Executive Committee was as follows:

    Kevin Edinger, Chesapeake Energy-President
    Todd Smith, Newfield exploration-Vice President
    Van Mason, BP-Secretary
    Mark Altom, Scientific Drilling
    Tom Beddow, oilfield Chaplains
    Bob Keeton, Greenes energy
    Joyce Ryel, Complete Production
    Jorge Delucca, OSHA

    Contributors

    Contributors to the alliance, through their continuous participation and/or support of MCEPS organization, include meeting sponsors and presenters, and Francis Tuttle Technology Center(s).

    Evaluation Period:

    This evaluation covers the evaluation period from September 2011 through September 2012.

  2. Implementation Team Meetings

    Date Location Type of Meeting
    04-05-2011
    06-16-2011
    Chesapeake Office
    FTTC
    In-person
    In-person

  3. Events and Products

    Training and Education

    Events:

    There were 11 industry meetings where a variety of topics were covered by Organizations and Agencies with Operations/Services Related to the Oil and Gas Industry:

    October: Oilfield Theft
    November: Managing Health and Safety Risk
    December: How to execute a Successful Drug-Free Workplace
    January: Lithium Battery Safety
    February: Tornado Precautions on Drilling Rigs
    March: Training Methodology
    April: Safety is Good Business; OSHA CAS gave presentation on HAZCOM 2012 (GHS)
    May: Positive Stress Management is Good Accident Prevention
    June: Safety Stand Down (June 21)
    July: Transit, Haz-Mat, Motor carrier, Highway Traffic, Safety and Special Programs
    August: Pressure Considerations for Flow Lines during Frac and Flow Back Operations
    September: Industrial Respiratory Protection

    Products:

    With the consent of presenters at MCEPS meetings, power point presentations were provided by e-mail to meeting participants/members for their use

    Outreach and Communication

    Events:

    November 1: Jorge Delucca, OSHA CAS and MCEPS member, gave OSHA Update to BP meeting at Wilburton, OK.

    March 14: Jorge Delucca, OSHA CAS and MCEPS member, gave another OSHA Update to BP meeting at Wilburton, OK

    June 19: David Bates, OSHA Oklahoma City Area Director and MCEPS member, announced Safety Stand Down at BP meeting at McAlester, OK. David bates was interviewed telephonically by BNA reporter about Stand Down.

    June 21: Oil & Gas Stand Down at Cox Convention Center, Oklahoma City (500 attendees plus 30+ via webinar); discussed fatalities in O&G sites in FY 2012. Industry inspected 1200 sites, corrected 2500 hazards

    October 11 and 23: Jorge Delucca, MCEPS OSHA member and Betsy Kulakowski, ODOL Consultant, spoke at OIPA/Marginal Well Commission meetings about OSHA standards, PPE and fatalities in oil & gas

    October 26: Jorge Delucca, MCEPS OSHA member, spoke to Independent Insurance Agents of Oklahoma about FY 2012 oil & gas fatalities in Oklahoma and results of the stand down

    Products: Information distributed to MCEPS members:

    1. OSHA Publication on Health Effects of Heat

    2. OSHA-NIOSH Hazard Alert: Worker Exposure to Silica during Hydraulic Fracturing
    Clarifying and/or explanatory information provided in follow-up to subjects raised during MCEPS meetings, or in response to phone queries by individuals in the Oil & Gas Industry related to:

      Use of Flame Retardant Clothing (FRC) at oil & gas sites
      OSHA multiemployer citation policy
      General Duty Clause and API recommended standards
    Promoting the National Dialogue on Workplace Safety and Health

    Events: MCEPS Board members continue to participate in National STEPS meetings and contribute to safety and health issues including the national dialogue regarding the Hydraulic Fracturing issue.

    Products: None.

  4. Results

    Type of Activity (Conference, Training, Print and Electronic Distribution, etc.) Number of Individuals Reached or Trained
    Monthly MCEPS meeting attendance 50-80 each
    Electronic distribution (follow up information) 499
    Stand Down, June 21, 2012 530
    Workers trained during Stand Down 9883
    Speeches 467
  5. Upcoming Milestones

    The Alliance will continue to (a) expand participation in MCEPS by outreach efforts to smaller producers, operators and servicing companies, (b) identify meeting topics of tangible benefit to members, (c) encourage open discussion of issues of concern to members/industry and identification of best practices/solutions.

Region 6 - Alliance Annual Report - June 1, 2019


Region 6 - Alliance Annual Report - June 1, 2019

ANNUAL ALLIANCE REPORT
The U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) Oklahoma City Area Office And
The Oklahoma Department of Labor Consultation Services
And The Oklahoma City and Tulsa Chapters of the American Society of Safety Professionals (ASSP)
June 1, 2019


  1. Alliance Background

    1. Date Signed

      June 5, 2014 and renewed on June 17, 2016

    2. Evaluation Period

      June 1, 2018 to June 1, 2019

    3. Overview

      OSHA, Oklahoma Department of Labor (ODOL), and the Oklahoma City and the Tulsa chapters of the American Society of Safety Professionals (ASSP) formed an Alliance to provide ASSP members and others with information, guidance, and access to training resources that will help them protect the health and safety of workers, particularly by reducing and preventing exposure to occupational hazards, and understand the rights of workers and the responsibilities of employers under the Occupational Safety and Health Act (OSH Act). In developing this Alliance, OSHA, ODOL and ASSE recognize that OSHA’s State On-site Consultation is an integral part of the OSHA national effort.

    4. Implementation Team Members

      OSHA
      David Bates, Oklahoma City Area Director
      Jorge Delucca, Compliance Assistance Specialist

      Oklahoma Department of Labor
      Melissa McLawhorn Houston, Oklahoma Commissioner of Labor
      Jason Hudson, Oklahoma Department of Labor, Director for OSHA Consultation

      Alliance participants
      Aidan Steiner, President, ASSP Tulsa Chapter 2018
      Cody Vinyard, President, ASSP Oklahoma City Chapter, 2018

  2. Implementation Team Meetings

    The Alliance coordinators from both groups maintained regular contact throughout the reporting period to monitor the Alliance’s progress and results.

  3. Results

    The following table summarizes the Alliance’s activities in support of the goals in the Alliance agreement.

    Raising Awareness of OSHA’s Rulemaking and Enforcement Initiatives: Outreach and communication

    Activity Type

    Activity Name/Summary

    OSHA Areas of Emphasis Supported

    Number Reached

    Alliance Product

    No activity

     

     

    Dissemination

    10/17/18: Jorge Delucca, CAS, shared the National Emphasis Program on Trenching and Excavation Instruction

    Raising awareness of OSHA’s rule making and enforcement

    700

    Dissemination

    10/19/18: Jorge Delucca, CAS, shared OSHA Launches Program to Target High Injury and Illness Rates

    Raising awareness of OSHA’s rule making and enforcement

    700

    Speech / Presentation

    10/12/18: David Bates, AD, gave an OSHA Update at a meeting of ASSP in Oklahoma City

    Safety & Health Management System

    39

    Dissemination

    11/6/18: Jorge Delucca, CAS, shared One Minute Safety Video

    Training and Education

    700

    Dissemination

    11/7/2018: Did you know OSHA publications are available as eBooks?

    Outreach and communication

    700

    OSHA Product Review

    No activity

     

     

    Exhibit

    No activity

     

     

    Dissemination

    11/16/18: Jorge Delucca, CAS, shared New Websites - www.worker.gov and www.employer.gov

    Outreach and communication

    700

    Dissemination

    1/10/19: Jorge Delucca, CAS, shared ALI Presents Third Annual National Ladder Safety Month

    Outreach and communication

    700

    Dissemination

    1/18/19: Jorge Delucca, CAS, shared FY 2019 OSHA Outreach Initiatives

    Raising awareness of OSHA’s rule making and enforcement

    700

    Dissemination

    1/25/19: Jorge Delucca, CAS, shared For Your Information: OSHA Final Rule on Electronic Submission of Injury/Illness Information

    Raising awareness of OSHA’s rule making and enforcement

    700

    Dissemination

    1/25/19: Jorge Delucca, CAS, shared a DOL article on “U.S. Department of Labor Publishes New Frequently Asked Questions on Controlling Silica in General Industry.”

    Raising awareness of OSHA’s rule making and enforcement

    700

    Dissemination

    2/26/19: Jorge Delucca, CAS, shared Resources and Posters for National Stand Down to Prevent Falls in Construction

    Training and Education

    700

    Dissemination

    3/15/19: Jorge Delucca, CAS, shared OSHA Requests Information on Powered Industrial Trucks Standards

    Raising awareness of OSHA’s rule making and enforcement

    700

    Dissemination

    4/1/19: Jorge Delucca, CAS, shared a safety message “Big Ass*TM Fan Safety Alert”

    Outreach and communication

    700

    Dissemination

    4/18/19: Jorge Delucca, CAS, shared Whistleblower Stakeholder Meeting - May 14, 2019

    Raising awareness of OSHA’s rule making and enforcement

    700

    Dissemination

    5/14/19: Jorge Delucca, CAS, shared For Your Information: OSHA Standards Improvement Project IV - Final Rule

    Raising awareness of OSHA’s rule making and enforcement

    700

    Dissemination

    Jorge Delucca, CAS, shared OSHA campaign information “For Your Information: Safe + Sound Campaign: Management Leadership Challenge.”

    Outreach and communication

    700

     

    TOTAL

       

    10,539

  4. Evaluations

    Alliance activities during this period effectively communicated the need for safety and health training and safety and health management programs in the workplace to hundreds of employers, safety professionals, and college students. ASSE, ODOL and OSHA will explore additional ways to increase cooperation between the two ASSP Oklahoma chapters, federal OSHA and state OSHA Consultation.

  5. Upcoming Milestones

    The alliance will be renewed on July 11, 2019.

    Report prepared by: Jorge Delucca, Compliance Assistance Specialist.

Region 6 - Alliance Renewal Agreement - September 5, 2019


Region 6 - Alliance Renewal Agreement - September 5, 2019

AGREEMENT RENEWING AN ALLIANCE
BETWEEN
OKLAHOMA CITY, OK AREA OFFICE
THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
U.S. DEPARTMENT OF LABOR
AND
THE OKLAHOMA DEPARTMENT OF LABOR
OSHA CONSULTATION DIVISION
AND
THE OKLAHOMA SECTION OF THE AMERICAN INDUSTRIAL HYGIENE
ASSOCIATION


The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) Oklahoma City, OK Area Office (hereafter referred to as OSHA) and The Oklahoma Local Section of The American Industrial Hygiene Association (hereafter referred to as OKAIHA) continue to recognize the value of maintaining a collaborative relationship to foster safer and more healthful American workplaces. To that end, OSHA and OKAIHA hereby renew the Alliance signed August 21, 2012 and renewed August 21, 2014, and August 26, 2016, with a continued emphasis on safety and health training. Specifically, both organizations are committed to providing OKAIHA members and others with information, guidance, and access to training resources that will help them protect the health and safety of workers and understand the rights of workers and the responsibilities of employers under the Occupational Safety and Health Act (OSH Act). Through the Alliance, the organizations will continue to address occupational safety and health issues.

This renewal agreement provides a framework and objectives for the Alliance’s activities. Alliance participants will summarize specific activities and timeframes for completion in a written work plan.

Through the Alliance, the organizations will use relevant injury, illness, and hazard exposure data when appropriate to help identify areas of emphasis for Alliance awareness, outreach, and communication activities. The Alliance will also explore and implement selected options to evaluate the effectiveness of the Alliance and measure the impact of its overall effort on improving workplace safety for employers and workers. In renewing this Alliance, OSHA and OKAIHA recognize that OSHA’s State Plan and On-site Consultation Project partners are an integral part of the OSHA national effort, and that information about the products and activities of the Alliance may be shared with these partners for the advancement of common goals.

Raising Awareness of OSHA's Rulemaking and Enforcement Initiatives

The Participants intend to work together to achieve the following objective related to raising awareness of OSHA’s rulemaking and enforcement initiatives:

  • To share information on OSHA’s National/Regional/Local Emphasis Programs, Regulatory Agenda, and opportunities to participate in the rulemaking process.
  • To share information on occupational safety and health laws and standards, including the rights and responsibilities of workers and employers.
  • To convene or participate in forums, roundtable discussions, or stakeholder meetings on emerging occupational health and safety issues to help forge innovative solutions in the workplace or to provide input on safety and health issues.

To encourage worker participation in workplace safety and health by participation in professional conferences, and technical presentations at lunch or dinner meetings.

Training and Education

The Participants intend to work together to achieve the following training and education objectives:

  • To develop effective training and education programs for business, industry and health and safety professionals regarding current or emerging health, safety, or compliance issues, and to communicate such information to constituent employers and workers.
  • To develop effective training and education programs for business, industry and health and safety professionals to promote understanding of workers’ rights, including the use of the OSHA complaint process, and the responsibilities of employers and to communicate such information to workers and employers.

Outreach and Communication

The Participants intend to work together to achieve the following outreach and communication objectives:

  • To develop information on the recognition and prevention of workplace hazards, and to develop ways of communicating such information (e.g., print and electronic media, electronic assistance tools, and OSHA’s and the OKAIHA Web site) to employers and workers in industry.
  • To speak, exhibit, or appear at OSHA’s or OKAIHA conferences, local meetings, or other planned events.
  • To share information among OSHA personnel and industry safety and health professionals regarding industry good practices or effective approaches through training programs, workshops, seminars, and lectures (or any other applicable forum) developed by the participants.
  • To work with other Alliance participants on specific issues and projects on current or emerging safety and health or compliance issues that are addressed and developed through the Alliance Program.
  • To develop and disseminate case studies on industry or government health and safety issues and publicize their results.

OSHA’s Alliances provide parties an opportunity to participate in a voluntary cooperative relationship with OSHA for purposes such as raising awareness of OSHA’s rulemaking and enforcement initiatives, training and education, and outreach and communication. These Alliances have proved to be valuable tools for both OSHA and its Alliance participants. By entering into an Alliance with a party, OSHA is not endorsing or promoting, nor does it intend to endorse or promote, any of that party’s products or services.

An implementation team made up of representatives of each organization will meet to develop a work plan, determine working procedures, and identify the roles and responsibilities of the participants. In addition, they will meet at least two times per year to track and share information on activities and results in achieving the goals of the Alliance. OSHA team members will include representatives of OSHA, OSHA Consultation and OKAIHA and any other appropriate offices. OSHA will encourage State Plan States’ and OSHA On-site Consultation Projects’ participation on the team.

This agreement will remain in effect for three years. Any signatory may terminate it for any reason at any time, provided they give 30 days written notice. This agreement may be modified at any time with the written concurrence of all signatories.

Signed this 5th day of September 2019.

 


Steven Kirby
Area Director
Occupational Safety and
Health Administration

 


Leslie Osborn
Oklahoma Commissioner of Labor

 


Jun Wang, Ph.D., PE, CIH
President
Oklahoma Section of the American Industrial Hygiene Association

Region 6 - Alliance Annual Report - August 20, 2019


Region 6 - Alliance Annual Report - August 20, 2019

ANNUAL ALLIANCE REPORT
The Occupational Safety and Health Administration (OSHA)
And The
Oklahoma Department of Labor OSHA Consultation Division
And The
Oklahoma Section of the American Industrial Hygiene Association
August 20, 2019


  1. Alliance Background

    1. Date Signed

      August 21, 2012; last renewed August 26, 2016

    2. Evaluation Period

      August 12, 2018 - August 20, 2019

    3. Overview

      The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) Oklahoma City, OK Area Office (hereafter referred to as OSHA) and The Oklahoma Local Section of The American Industrial Hygiene Association (hereafter referred to as OKAIHA) continue to recognize the value of maintaining a collaborative relationship to foster safer and more healthful American workplaces. To that end, OSHA and OKAIHA hereby renew the Alliance signed August 21, 2012 and renewed August 21, 2014, and August 26, 2016, with a continued emphasis on safety and health training. Specifically, both organization(s) are committed to providing OKAIHA members and others with information, guidance, and access to training resources that will help them protect the health and safety of workers and understand the rights of workers and the responsibilities of employers under the Occupational Safety and Health Act (OSH Act). Through the Alliance, the organizations will continue to address occupational safety and health issues. This renewal agreement provides a framework and objectives for the Alliance’s activities. Alliance participants will summarize specific activities and timeframes for completion in a written work plan.

    4. Implementation Team Members

      OSHA
      David Bates, former Area Director, Oklahoma City Area OSHA Office until January 2019.
      Steven Kirby, Area Director, Oklahoma City Area OSHA Office since June 22, 2019
      Jorge A. Delucca, MS, MA, CAIH, Compliance Assistance Specialist

      Oklahoma Department of Labor (ODOL)
      Leslie Osborn, Oklahoma Commissioner of Labor
      Jason Hudson, MS, Director, OSHA Consultation Division

      American Industrial Hygiene Association (AIHA) - Oklahoma Local Section
      Jun Wang, PhD, P.E., President
      Terri Pearce, PhD, President Elect
      Chris Bradshaw, EdD, MT (ASCP), CEA,
      Margaret Levin Phillips, Ph.D., CIH; Treasurer, OKAIHA
      Rachel Butler, MS, CIH, Secretary, OKAIHA
      Gregory Day, PhD, Director, OKAIHA
      Bryan Stolte, PhD, CIH, Director, OKAIHA
      Susanna Przywojski; Director, OKAIHA

  2. Implementation Team Meetings

    • Board planning meeting, June 12, 2019
    • Fall Conference planning meeting, August 19, 2019
    • Six Planning meetings for Workers Memorial Day 2019, conducted between November 27, 2018 and April 23, 2019. Chris Bradshaw EdD, and Rachel Butler, CIH, represented OKAIHA.

    In addition to these formal meetings, the Alliance coordinators from both groups maintained regular contact throughout the reporting period to monitor the Alliance’s progress and results.

  3. Results

    The following table summarizes the Alliance’s activities in support of the goals in the Alliance agreement.

    Training and Education: Emerging safety and health issues

    Activity Type

    Activity Name/Summary

    OSHA Areas of Emphasis Supported

    Number Reached

    Fall Conference

    October 18 and 29, 2018: Regulatory Update. Jorge Delucca, CAS, recruited speakers and provided an update on the OSHA Voluntary Protection Program (VPP); David Bates, AD, presented an OSHA Update; Renato Uribe, Whistleblower Investigator, provided an update on the 11C Whistleblower Protection Program; Melissa Houston, Oklahoma Commissioner of Labor, provided an update on the Oklahoma department of Labor OSHA Consultation. Consultant Denesse Deeds gave an update on the United Nations HAZCOM Globally Harmonized System. Lee Warden, Oklahoma Department of Environmental Quality gave a presentation on the Clean Air Act and air quality toxics in Oklahoma. John Dyer, Oklahoma Department of Labor, gave update on the Public Employee Occupational Safety and Health.

    Raising awareness of OSHA’s Rulemaking and Enforcement Initiatives

    33

    Lunch meeting

    Dr. Greg Day, Director OKAIHA, gave presentation on “Industrial Hygiene Air Sampling for Metals: Aligning Measurements to Standards.”

    Training and Education

    12

     

    Raising Awareness of OSHA’s Rulemaking and Enforcement Initiatives:

    Activity Type

    Activity Name/Summary

    OSHA Areas of Emphasis Supported

    Number Reached

    Dissemination via email

    9/4/2018: Jorge Delucca, CAS, forwarded OSHA Amputation Stand-Down - September 5, 2018

    Raising awareness of OSHA’s Rulemaking and Enforcement Initiatives

    64

    Dissemination via email

    10/19/2018: Jorge Delucca, CAS, forwarded “For Your Information: OSHA Launches Program to Target High Injury and Illness Rates”

    Raising awareness of OSHA’s Rulemaking and Enforcement Initiatives

    64

    Dissemination via email

    11/7/2018: Jorge Delucca, CAS forwarded “Did you know OSHA publications are available as eBooks?”

    Raising awareness of OSHA’s Rulemaking and Enforcement Initiatives

    64

    Dissemination via email

    Jorge Delucca discussed a letter to the editor of The Synergist praising the article “Ending Modern Slavery” (The Synergist, September 2018) published in the November issue of The Synergist, page 10.

    Training and Education

    8,500

    Dissemination via email

    12/10/2018: Jorge Delucca, CAS forwarded “For Your Information: OSHA Proposes Revisions to Beryllium General Industry Standard”

    Raising awareness of OSHA’s Rulemaking and Enforcement Initiatives

    64

    Dissemination via email

    Jorge Delucca, CAS forwarded “U.S. Department of Labor Publishes New Frequently Asked Questions on Controlling Silica in General Industry”

    Raising awareness of OSHA’s Rulemaking and Enforcement Initiatives

    64

    Dissemination via email

    Jorge Delucca, CAS forwarded “For Your Information: OSHA Standards Improvement Project IV - Final Rule”

    Raising awareness of OSHA’s Rulemaking and Enforcement Initiatives

    64

    Dissemination via email

    Cheri Marcham, PhD, CIH, CSP, published “Electronic Cigarettes and the IH” with co-author Jack Springston in the May 2019 issue of The Synergist

    Training and Education

    8,500

    Dissemination via email

    7/25/2019: Jorge Delucca, CAS forwarded a Heat Illness Press Release

    Training and Education

    64

     

    Activity Type

    Activity Name/Summary

     

    Number Reached

    Workforce outreach

    OKAIHA co-sponsorship of the Workers’ Memorial Day observance on April 30, 2019

    Workers’ Memorial Day

    200

     

    TOTAL

     

     

    17,693

  4. Evaluations

    This alliance has resulted in a very close relationship and cooperation between OSHA and members of OKAIHA that encompass representatives of academia, industry and other federal agencies.

    The Fall Conference provides valuable information to attendees regarding emerging issues in industrial hygiene and the various aspects of OSHA activities. The conferences provide certification maintenance points for members with the Certified Industrial Hygienist and the Certified Safety Professional credentials.

    Dinner and lunch meetings with guest speakers provided continued education outreach to members, students and other Environmental Health and Safety professionals.

  5. Upcoming Milestones

    1. Alliance renewal, first week of September 2019.
    2. OKAIHA Fall Conference, Regulatory Update, October 24 (Preparation for CIH exam and Professional Development Courses, and October 25 Full day seminar on Medical Marijuana, at the College of Public Health of the University of Oklahoma, Health Sciences Center, Oklahoma City.
    3. Annually, provide free EH&S Webinar Training via AIHA eLearning Subscription to Local Section Members (offered on a monthly basis by AIHA through the OKAIHA Local Section). ** ** Live Webinars provided by AIHA. Archived Webinars are available on demand.

    Report Prepared by:
    Alliance Coordinator, Jorge A. Delucca, Compliance Assistance Specialist,
    Oklahoma City Area Office
    August 20, 2019