Name:           CRISWELL ROBERT E JR
Organization:   CI ENGINEERING
Date:           20050829
Address1:       13 HERITAGE PARK
Address2:       
City:           HUNTINGTON
Country:        
State:          WV
Zip Code:       25704
Docket Number:  H023
Exhibit Number: 3-9
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Notice of a section 610 review; request for comments.

The Occupational Safety and Health Administration (OSHA) is conducting a review of the lead in construction standard under section 610 of the Regulatory Flexibility Act and section 5 of Executive Order 12866 on Regulatory Planning and Review. In 1993, in response to a statutory mandate to adopt a standard to protect construction workers from lead exposures, OSHA promulgated a standard that requires testing of construction sites for lead exposures, provisions to protect workers from exposure where lead is present, and medical monitoring of exposed workers.  The purpose of this review is to determine whether there are ways to modify this standard to make implementation more practical, to reduce regulatory burden on small business, and to improve its effectiveness, while still protecting worker health. OSHA solicits comments from the public on these and other relevant issues.

If you would like to submit an online comment in response to this notice,  please enter the information below.  Online submissions must be received by 11:59 pm, ET, September 6, 2005.  Note that you can also upload comments and any supporting materials as electronic document files on this Web site.

Thank you for your interest in occupational safety and health.






One of the hardest issues to continue to be in compliance with the Lead Standards is keeping your past data current.  I feel that data collected should have a more active life than one year.  Also, why can't OSHA solicit information from various construction companies to detemine an acceptable "Lead Free Determination?"

There are many times that companies perform work and have all the requirements fullfilled to find that the action levels were not exceeded.  Why can't different companies share information for similar work?  This would allow a wider spectrum of past history for companies to work with.  It would also make the cost of compliance go down.

