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Petitions for the issuance, amendment, or repeal of a standard.
OSHA has a procedure for "Petitions for the issuance, amendment, or repeal of a standard."
From URL:
www.osha.gov/pls/oshaweb/owadisp.show_do...NDARDS&p_id=9699
Regulations (Standards - 29 CFR) - Table of Contents Regulations
(Standards - 29 CFR) - Table of Contents
• Part Number: 1910
• Part Title: Occupational Safety and Health Standards
• Subpart: A
• Subpart Title: General
• Standard Number: 1910.3
• Title: Petitions for the issuance, amendment, or repeal of a standard.
1910.3(a)
Any interested person may petition in writing the Assistant Secretary of Labor to promulgate, modify, or revoke a standard. The petition should set forth the terms or the substance of the rule desired, the effects thereof if promulgated, and the reasons therefor.
1910.3(b)
1910.3(b)(1)
The relevant legislative history of the Act indicates congressional recognition of the American National Standards Institute and the National Fire Protection Association as the major sources of national consensus standards. National consensus standards adopted on May 29, 1971, pursuant to section 6(a) of the Act are from those two sources. However, any organization which deems itself a producer of national consensus standards, within the meaning of section 3(9) of the Act, is invited to submit in writing to the Assistant Secretary of Labor at any time prior to February 1, 1973, all relevant information which may enable the Assistant Secretary to determine whether any of its standards satisfy the requirements of the definition of "national consensus standard" in section 3(9) of the Act.
..1910.3(b)(2)
1910.3(b)(2)
Within a reasonable time after the receipt of a submission pursuant to paragraph (b)(1) of this section, the Assistant Secretary of Labor shall publish or cause to be published in the FEDERAL REGISTER a notice of such submission, and shall afford interested persons a reasonable opportunity to present written data, views, or arguments with regard to the question whether any standards of the organization making the submission are national consensus standards.
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Now START Petition OSHA, Write to;
Assistant Secretary of Labor for OSHA
David Michaels
U.S. Department of Labor
Occupational Safety and Health Administration
200 Constitution Ave., NW
Washington, DC 20210
Phone: (202) 693-2000
E-mail: PublicMichaelsDavid@dol.gov
DEMAND A CHANGE IN; J. 29 CFR 1910.425 Surface-supplied air diving. Part 3.
DEMAND THE FOLLOWING CHANGE - A FIVE PERSON DIVE TEAM MINIMUM!
NO EXCUSES, NO BULL S***!
J. 29 CFR 1910.425 Surface-supplied air diving.
Part 3.
For ALL Commercial surface-supplied air diving with one diver in the water requires a minimum of five dive-team members: a DPIC (see 29 CFR 1910.410(c)), a diver{the working diver] "who shall be continuously tended [by a tender other than the DPIC] while in the water" (see 29 CFR 1910.425(c)(1)), a standby diver{dressed, equipped and ready to enter] "who shall be continuously tended [by a tender other than the DPIC or the tender for the working diver] while in the water" However, based on the requirements of 29 CFR 1910.421(d) Planning and a****sment, the hazard analysis and a****sment of the dive will dictate the use of additional personal when underwater conditions and hazards or potential hazards involve: proximity to an underwater suction, no free access to the surface, the possibility of diver entanglement or entrapment, or unknown bottom conditions.
Let's start demanding changes!
Ever Person Reading Should Write a Request.
MAKE YOUR REQUEST KNOWN!
Write to;
Assistant Secretary of Labor for OSHA
David Michaels
U.S. Department of Labor
Occupational Safety and Health Administration
200 Constitution Ave., NW
Washington, DC 20210
Phone: (202) 693-2000
E-mail: PublicMichaelsDavid@dol.gov
..............................................................
Views: 88
Replies to This Discussion
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Permalink Reply by John Carl Roat on
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Good Work Joseph!!
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Where the three man team comes from;
Ross Saxon and Mr. Steve Butler OSHA, wrote the OSHA Standard loosely. It doesn’t say three man team in the CFR. Ross then ask for an interpretation: your request for an interpretation of OSHA’s Commercial Diving standards (29 CFR Part 1910, Subpart T) see attached yes he was given what he wanted by OSHA as an "interpretation"
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ADC3manletter.pdf, 21 KB
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Joseph and All;
the following is what I sent to the Department of Labor as a change request
"March 4, 2011
To: Assistant Secretary of Labor for OSHA David Michaels
From: John Carl Roat;
Sir;
Pursuant to Regulations (Standards - 29 CFR) - Table of Contents Regulations
(Standards - 29 CFR) - Table of Contents
• Part Number: 1910
• Part Title: Occupational Safety and Health Standards
• Subpart: A
• Subpart Title: General
• Standard Number: 1910.3
• Title: Petitions for the issuance, amendment, or repeal of a standard.
1910.3(a)
Any interested person may petition in writing the Assistant Secretary of Labor to promulgate, modify, or revoke a standard. The petition should set forth the terms or the substance of the rule desired, the effects thereof if promulgated, and the reasons there for.I am requesting such a change in: 29 CFR 1910.425 Surface-supplied air diving.
It should require: For ALL Commercial surface-supplied air diving with one diver in the water requires a minimum of five dive-team members: a DPIC (see 29 CFR 1910.410(c)), a diver{the working diver] "who shall be continuously tended [by a tender other than the DPIC] while in the water" (see 29 CFR 1910.425(c)(1)), a standby diver{dressed, equipped and ready to enter] "who shall be continuously tended [by a tender other than the DPIC or the tender for the working diver] while in the water" However, based on the requirements of 29 CFR 1910.421(d) Planning and a****sment, the hazard analysis and a****sment of the dive will dictate the use of additional personal when underwater conditions and hazards or potential hazards involve: proximity to an underwater suction, no free access to the surface, the possibility of diver entanglement or entrapment, or unknown bottom conditions.
Reasons for change
1. The current OSHA allows for a three man team: If you have to put the stand by diver in the water to assist the diver #1 while he is in duress: That leaves one person on the surface to tend two hoses; communicate to two divers and assist in the rescue, send down tools, get injured diver to surface and over the side or up the ladder, call for assistants etc. This is an unsafe practice !
2. OHSA CFRs 29 and Coast Guard 46 CFRs come into conflict in many Harbors, Lakes and rivers. one applies when diving from a rusty old barge in the Harbor, the other applies, when diving from a Licensed Vessel in the same Harbor. They can be doing the same job, in the same area; OSHA and the Coast Guard require different manning levels, different responsibilities and different reporting to different agencies. This confusion is one of our biggest safety problems. Minimum manning levels should be consistent Coast Guard requires a minimum of 5: 1 Supervisor, 2 Divers and 2 Tenders
Sincerely
John Carl Roat
Senior Supervisor/Diver"
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