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Regulatory Update Presented by: Martha Duggan, NRECA

Regulatory Update Presented by: Martha Duggan, NRECA. Presented to: National G&T Safety Forum Nashville, TN February 26-27, 2014. Today’s Agenda. Cranes and Derricks Harmonizing GHS and HazCom Crystalline Silica Record Keeping Subpart V. OSHA – Cranes & Derricks.

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Regulatory Update Presented by: Martha Duggan, NRECA

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  1. Regulatory UpdatePresented by:Martha Duggan, NRECA Presented to: National G&T Safety Forum Nashville, TN February 26-27, 2014

  2. Today’s Agenda • Cranes and Derricks • Harmonizing GHS and HazCom • Crystalline Silica • Record Keeping • Subpart V

  3. OSHA – Cranes & Derricks • May 29, 3013: OSHA publishes Final Rule reflecting digger derrick exemption. • Operators of digger derricks involved in electrical distribution or transmission work are exempt from certification requirements. • ANY USE OF DIGGER DERRICKS OUTSIDE ELECTRICAL DISTRIBUTION OR TRANSMISSION WORK MUST BE DONE BY A CERTIFIED OPERATOR AFTER THE CERTIFICATION DEADLINE. • But when is the certification deadline? More on that!

  4. OSHA – Cranes & Derricks • Certification Deadline Suspended – New Deadline of November, 2017 proposed • Listening Sessions – April 2 and 3, 2013 • Words Matter! • Certification vs. Qualification OSHA FAQ #21: Does an operator's certification mean that the operator is qualified to operate any type of equipment covered by the standard? No. An operator may operate a particular piece of equipment if the operator is certified for that type and capacity of equipment or for higher-capacity equipment of that type. For example, an operator certified for a 100-ton hydraulic crane may operate a 50-ton hydraulic crane but not a 200-ton hydraulic crane.

  5. OSHA – Cranes & Derricks • Listening Sessions – April 2 and 3, 2013 • Words Matter! • Size, Type and Capacity “Proposed paragraph 1427(b)(1)(ii)(B) would require that different levels of certification be provided, based on varying equipment capacities and types. This proposed requirement is designed to ensure that the extent of knowledge and skill required is commensurate with the type and capacity of equipment the employee operates.”

  6. OSHA – Cranes & Derricks • Other parts of the rule continue to apply • To train or not to train? • This question just became more Complicated. • Obligations as owner of facilities

  7. OSHA – Cranes & Derricks

  8. OSHA: Harmonizing GHS and HazCom HCS Pictograms and Hazards Flame Exclamation Mark Health Hazard • Carcinogen • Mutagenicity • Reproductive Toxicity • Respiratory Sensitizer • Target Organ Toxicity • Aspiration Toxicity • Flammables • Pyrophorics • Self-Heating • Emits Flammable Gas • Self-Reactives • Organic Peroxides • Irritant (skin and eye) • Skin Sensitizer • Acute Toxicity (harmful) • Narcotic Effects • Respiratory Tract Irritant • Hazardous to Ozone Layer • (Non Mandatory) Gas Cylinder Corrosion Exploding Bomb • Skin Corrosion/ Burns • Eye Damage • Corrosive to Metals • Gases under Pressure • Explosives • Self-Reactives • Organic Peroxides Flame over Circle Environment Skull and Crossbones (Non Mandatory) • Oxidizers • Acute Toxicity (fatal or toxic) • Aquatic Toxicity

  9. OSHA – Crystalline Silica • Crystalline Silica • Proposed Rule published in August 2013. • Comments originally due in December 2013. • Due date extended to February 11, 2014. • Proposed rule • decreases permissible exposure levels (“PELs”) • Requires employers to conduct initial and periodic assessments as often as every 3 months. • Requires air sampling for each shift, job classification and work area. • Requires employers to use accredited laboratories to analyze samples. • NRECA filed comments requesting that G&T’s be allowed further time for analysis of new requirements • Comments also suggested some wording changes to the rules to synchronize General Industry and Construction parts.

  10. OSHA–I2P2 Record Keeping • Proposed Rule published November 8, 2013 • Comments due March 10, 2014 • Would require filing of OSHA Form 300 electronically by all who keep the form. • OSHA would publish information • Not individual names • Issues: • Goal? Improve workplace safety? How?

  11. OSHA – Injury and Illness Protection Program – “I2P2” Proactive, comprehensive program • 34 states already have some form of I2P2 program Key Elements: • Stakeholder meetings in 2010, SBREFA Panel goal 2Q2012, nowin limbo • Internal NRECA Work Group • 2012 House budget bill kills any OSHA I2P2 activity. • NACOSH November 2012 meeting signals I2P2as priority

  12. OSHA – monitoring: • Combustible Dust • Stakeholder meetings three years running • SBREFA panel originally expected December 2011- has now been moved to “Long Term Items” in OSHA’s regulatory agenda. • Combustible dust mentioned in GHS rule • In February, 2013, House Democrats introduced legislation to accelerate the combustible dust rulemaking. Not expected to pass.

  13. OSHA: Subpart V • Notice of Proposed Rulemaking published June 15, 2005 • Draft Final Rule Went to OMB in July 2012 • OMB sent it back to OSHA with numerous questions that OSHA must address. • At last count, the Preamble was over 1,000 pages • What to expect: • PPE • Fall Protection • Minimum Approach Distance • Other?

  14. Transportation – Medical Certification

  15. Emergency Preparedness Resources • An Electric Cooperative’s Introduction to FEMA – updated! On Cooperative.com • Webinar April 24, 2013 • Mutual Aid Agreement (blank) • List of signatories to Mutual Aid Agreement Issues • Changes to FEMA processes: Sandy Recover Improvement Act of 2013 • Focus on reimbursements for estimated costs • New alternative appeals process • Regulatory guidance and rulemakings • FEMA funding • Limited federal resources = more pressure to deny requests • DOCUMENT, DOCUMENT, DOCUMENT!! • Interim Final Rule on debris removal.

  16. FEMA: Sandy Recovery Improvement Act • Alternative Procedures for Debris Removal • Declining cost share schedule • Revenue for debris recycling retained by applicant/subapplicant • Alternative Procedures for Permanent Work • Dispute Resolution/Arbitration Pilot Program • Expedited Unified Environmental/Historic Preservation Review • Straight Time Force Account Labor Costs (non-debris)

  17. Superstorm Sandy

  18. The Response to Superstorm Sandy

  19. The Response, Con’t.

  20. The Department of Energy • Org chart of new DOE ESF ops center

  21. ? ? ? ? ? ? ? ? ? Questions or Comments? ? ? ? ? ? ? ? ? ? Martha Duggan – Sr. Principal, Regulatory Affairs National Rural Electric Cooperative Association Martha.Duggan@nreca.coop Office: 703-907-5848; Mobile: 202-271-4395 ? ? ? ? ? ? ? ? ?

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