Name:           THORNTON RONALD G
Title:          
Organization:   INLAND MARINE UNDERWRITERS ASSOCIATION
Date:           20020812
Address1:       
Address2:       
City:           NEW YORK
State:          NY
Zip Code:       10005
Docket Number:  S030
Exhibit Number: 3-3
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Notice of intent to establish Negotiated Rulemaking Committee; request for nominees and comments.
 
The Occupational Safety and Health Administration is announcing its intent to establish a Cranes and Derricks Negotiated Rulemaking Advisory Committee (C-DAC) under the Negotiated Rulemaking Act (NRA) and the Federal Advisory Committee Act (FACA).  The Committee will negotiate issues associated with the development of a proposed revision of the existing construction safety standards for the cranes and derricks portion (1926.550) of 29 CFR 1926 Subpart N - Cranes, Derricks, Hoists, Elevators, and Conveyors.  The Committee will include representatives of parties who would be significantly affected by the final rule.  OSHA solicits comments on the initiative and requests interested parties to nominate representatives for membership on C-DAC.
 
Please note that you may not attach materials such as studies or journal articles to your electronic comments.  If you wish to include such materials, you must submit three copies to the OSHA Docket Office, Docket No. S-030, US Department of Labor, Room N-2625, 200 Constitution Avenue, NW, Washington, DC 20210.
 
If you wish to submit a nomination or comment online, you may enter it into the box below.  If you are submitting a nomination, please read the Federal Register notice for a list of what is needed to complete the application.  Online comments or nominations must be received by September 16, 2002.
 
I am President & CEO of the IMUA, a not-for-profit organization founded in 1930, representing the interests of insurance companies underwriting commercial inland marine insurance.  With membership approximating 90% of the commercial insurance and reinsurance market place, and with contractors equipment [including cranes] being one of our members largest classes of business, I believe the IMUA is well suited to be a representative of the insurance industry.Several of our NY based technical committees - Construction [Jim Carter is a member of that committee]and Loss Prevention/Claims - are particularly focused on cranes.  In fact, our Construction Committee is in the process of writing an insurance-oriented paper on this very topic.While the IMUA is mainly focused on the physical damage asspect of cranes, it does get involved with time element insurance and other coverage forms.  Of particular interest to our association would be rules and regulations relating to the training and certification of crane operators.  Our members find that human error is probably the single largest cause of loss and damage.As you go through you evaluation process, I believe I could be a valuable point person for the insurance industry.  I would have access to extensive insurance technical information that would be hard to replicate.Thanks in advance for your consideration.Ron Thornton212-233-0550
 
