Notice of Intent to Appear from Conrad, Karen, North Pacific Fishing Vessel Owners' Association

Document ID: OSHA-S049-2006-0675-0135
Document Type: Public Submission
Agency: Occupational Safety And Health Administration
Received Date: July 15 2008, at 04:25 PM Eastern Daylight Time
Date Posted: July 16 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: December 20 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: August 8 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 80679a69
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I intend to appear and testify in Seattle, WA., on Docket OSHA-S049-2006-0675 on October 21,2008. I will be testifying on the erroneous assumptions in developing the proposed rule. This misinformation has made OSHA's approach to fish processing vessels flawed. I will testify and urge OSHA to reconsider the reasons given for their approach, as most are based on incorrect informaiton. I will also testify on the LOTO proposed rule. I will urge OSHA to cover LOTO under one regulations (1915.89) and not 1910, since employess work on both ship's systems and processing equipment. I will urge to allow NPFVOA and local OSHA office by working through our alliance to come up with input for a LOTO regulation that can be followed no matter where the vessel is operating. The fishing industry needs a useful adn workable lockout standard. Karen Conrad, Asst. Director, NPFVOA Vessel Safety Program

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