Name:           BASDEN BRUCE
Title:          
Organization:   BASDEN STEEL AND ERECTION INC
Date:           20030331
Address1:       
Address2:       
City:           BURLESON
State:          TX
Zip Code:       76097
Docket Number:  S030
Exhibit Number: 7-15
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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. 
 
Big B Crane & Rigging645 East Renfro StreetBurleson, Texas  76028(817) 447-9813March 28, 2003ecomments.osha.govOSHA Docket OfficeDocket No. S-030US Department of Labor200 Constitution Avenue, NWRoom N-2625Washington, DC 20210Re: Crane & Derrick Negotiated Rulemaking Advisory Committee       C-DACDear Sir or Madam:We were quite shocked to learn that this committee has no representation for independent, non-union crane service companies.  Companies like mine form the backbone of the crane industry in the U.S. and will likely be most affected by the new rules this committee is charged with writing. There may be persons on the committee who are members of SCR&A, but are not actual owner/users like me, who will be most directly affected by the regulation and subject to OSHA citations.We strongly object to the inclusion of two representatives from the International Union of Operating Engineers while open shop operators have no representative. My understanding is that approximately eighty percent (80%) of the crane work is open shop, verses the twenty percent (20%) union.  It would be a major mistake for these companies not to be properly represented.  We feel our viewpoints and interests would be well represented by a member of the Specialized Carriers and Riggers Association (SCR&A). This group represents over 1100 crane industrial members and is a leader in promoting crane safety.Doug Williams, the candidate proposed by SCR&A, served on the ACCSH work group and this experience will be tremendously valuable on the Subpart N committee.  He is well recognized in the industry and as General Manager for a large crane rental company is subject to the reality of any OSHA rules.  Mr. Williams has been heavily involved in the CCO program for operators and would represent a large number of open shop operators. Furthermore, Mr. Williams is a company owner, which is an important perspective that is currently only reflected in a minor way on the committee.We urge you to include SCR&As candidate Doug Williams on the Subpart N Committee.  Thank you for your consideration.Respectfully submitted,Bruce Basden, CEO
 
