Public Comment

It is widely acknowledged that an update of OSHA SubPart O, 1910.217 is long overdue. This regulation was promulgated from ANSI B11.1-1971 which has been updated 3 times since then, 2001 being the most recent version. Please be aware however that ANSI B11.1 is in the process of another update which is due for completion in either the 4th quarter of 2007 or the 1st quarter of 2008. Many of OSHA's questions in the ANPR will be answered in this new version. OSHA would be wise to base the 1910.217 update on this soon to be completed version of ANSI B11.1 (since the 2001 version will soon be outdated). This new version of ANSI B11.1 will also provide the latest thinking on PSDI, another concept long overdue for approval using self-certification instead of the current third-party certification. Although unrelated to the .217 discussion, OSHA may want to consider adopting other ANSI B11 Safety Standards (there are 24 in this series) simply as reference materials for a wide variety of equipment under 1910.212 or (5)(a)(1) GDC. ANSI B11 Safety Standards are usually updated every 5 years to keep them current. Roger Harrison, Rockford Systems Inc.