Comment from Oswald, Wayne, Houston Business Roundtable

December 9, 2008 OSHA Docket Office Technical Data Center, Room N-2625 OSHA/U. S. Department of Labor 200 Constitution Avenue, NW Washington, DC 20001 www.regulations.org Re: Docket ID OSHA 2007 0066 Cranes and Derricks in Construction: Comment on Proposed Rule Dear Docket Clerk: The Houston Business Roundtable, HBR, appreciates the opportunity to submit comments on Occupational Safety and Health Administrations OSHA Proposed Rules for Cranes and Derricks in Construction that was published in the Federal Register on October 9, 2008 73 Federal Register 59714-59954 . Ensuring crane and derrick safety for maintenance and construction activities at our member companies facilities is an important and critical issue for our petrochemical and refining owners and for the contractors that provide services to them. HBR has a very active, experienced group of Crane and Rigging professionals that supports and commends OSHA for their positive efforts in upgrading these rules to reflect industry best practices for use of Cranes and Derricks in Construction. HBR is particularly supportive of establishment of detailed safety standards and certification of crane/derrick operators, signal persons and riggers to ensure the safety and skill development of construction workers across the United States. This HBR C and R Committee has spent many hours reviewing the proposed rules and has compiled the attached comments and recommendations for your careful review. We appreciate the opportunity to provide input and we respectfully offer these comments and suggestions for your serious consideration. Sincerely, Wayne Oswald Executive Director Houston Business Roundtable woswald@houbrt.com