Notice of Intent to Appear from Lee, Lurilla, Trident Seafoods

Document ID: OSHA-S049-2006-0675-0139
Document Type: Public Submission
Agency: Occupational Safety And Health Administration
Received Date: July 16 2008, at 12:10 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: 8067db56
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I intend to testify in Seattle Washington on October 21,2008. I will be discussing the need for OSHA to consult with industry who must comply with their regulations. I will testify on the vagueness of the regulation and the need for definition. How OSHA seems to be providing the employer with broad flexibility to meet these requirements, but the regulatiions as written appear very subjective. The need for one LOTO standard under 1915.89 to ensure consistency and safety. I will recommend working with NPFVOA through the alliance with OSHA to make recommendations on LOTO. Lurilla Lee, VP of Safety, Trident Seafoods. I will speak for 10 minutes.

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