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
Notice of Intent to Appear from Conrad, Karen, North Pacific Fishing Vessel Owners' Association
This is comment on Notice
General Working Conditions in Shipyard Employment; Proposed rule; Notice of Hearing
View Comment
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