Name:           SANSOUCY PAUL M
Title:          
Organization:   BOND SCHOENECK  KING PLLC
Date:           20030302
Address1:       
Address2:       
City:           SYRACUSE
State:          NY
Zip Code:       13202-1355
Docket Number:  S030
Exhibit Number: 7-3
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Safety Standards for Cranes and Derricks
 
The Occupational Safety and Health Administration is planning to establish a Crane and Derrick Negotiated Rulemaking Advisory Committee (C-DAC) under the Negotiated Rulemaking Act (NRA) and the Federal Advisory Committee Act (FACA). The Committee will include representatives of parties who would be significantly affected by the final rule. 
 
On July 16, 2002, OSHA published a Federal Register notice of intent to establish a negotiated rulemaking committee (67 FR 46612) and requested nominations for membership. In the current Federal Register notice OSHA is asking for comments on the proposed list of fifty-five nominations.  The list can be found in the complete notice.
 
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 at the address listed above. When submitting such materials to the OSHA Docket Office, clearly identify your electronic comments by name, date, subject, and Docket Number, so that we can attach the materials to your electronic comments.
 
Online comments must be received by March 31, 2003 COB EST.  If you wish to commit online on the proposed list of Committee members, please enter your submission in the box below.  Thank you for your interest in worker safety and health. 
 
Before this rulemaking is completed, the issue of hoists, apart from cranes/derricks should be addressed.My firm represents employers, and it is manifestly unfair to cite employers based on a provision of an ANSI regulation which is frequently outdated for a General Duty Clause violation.  This is particularly the case when the alleged violation is failure to have the load capacity of the hoist on the equipment.  Another part of this standard should include provisions dealing with lifting devices, whether mechanical, electro-magnetic, vacuum, or other.  Again, these often are cited as General Duty Clause violations with reference to an ANSI or ASME standard.  Sincerely,   Paul M. Sansoucy
 
