Notice of Intent to Appear from Myer, Dale, Arctic Storm Management group

I intend to testify how the proposed ruling for shipyards under 1915.81 are vague and impractical in that maintenance and cleaning operations at time necessitate that the walking on working surfaces be lifted from their frames. OSHA has been attempting to hold commercial fishing vessels to General Industry walking and working surface standard which are untenable and unattainable. Also, it is not always possible to eliminated snow and ice as it occurs in Alaska. Dale Myer, Director of Operations, I will speak for 10 mins.