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NECA Comments on OSHA Standards
March 7, 2008

The National Electrical Contractors Association (NECA) recently submitted comments to the Occupational Safety and Health Administration (OSHA) on new proposed standard on confined spaces in construction. The proposed rule has the potential to reduce fatalities and injuries among construction workers performing work in confined spaces, ranging from manholes and tunnels, to crawl spaces under buildings, to crowded electrical equipment closets. These locations present specific safety concerns due to a lack of mobility, reduced communications with other workers, and the difficulty of making a quick emergency exit. Hazards also exist for the rescue teams who may have to enter confined spaces.

NECA places electrical and construction worker safety as one of its highest priorities and agrees that OSHA’s strengthened requirements for confined spaces are necessary. However, the organization voiced strong concerns about particular aspects of the proposed rule in its comments to OSHA. Michael Johnston, NECA’s Executive Director of Standards and Safety, submitted comments to OSHA that clearly define NECA’s concerns and, in some cases, offer suggestions and alternatives to OSHA’s plan.

According to Mr. Johnston, “Regulations, codes, and standards are effective when they are understandable, practical, and enforceable. NECA has concerns about the complexity and additional burden of the new proposed regulations. Additional costs associated with their implementation may cause some in the industry to ignore the rules in some cases, placing workers at greater risk.”

NECA also offered specific comments on portions of the standard concerning construction work in confined spaces, including:

· Equipment necessary for a single attendant to monitor multiple Permit-Required Confined Spaces (PRCS)
· Mechanical device(s) for vertical retrieval during rescue
· Timely response to a rescue summons
· Maintaining Controlled Atmosphere Confined Space (CACS) and Isolated Hazard Confined Space (IHCS) verification documents

NECA’s comments were offered in response to OSHA’s request for feedback surrounding the proposed standards. The deadline for submission of these comments was February 28, 2008. This was an extension from an earlier due date in January after multiple organizations requested more time to review and respond to this important document.

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