Name:           POCOCK PAMELA W
Title:          
Organization:   STEEL ERECTORS ASSOCIATION OF AMERICA
Date:           20030331
Address1:       
Address2:       
City:           GREENSBORO
State:          NC
Zip Code:       27407
Docket Number:  S030
Exhibit Number: 7-17
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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. 
 
March 31, 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 feel strongly that the Specialized Carriers and Riggers Association (SC&RA) should have a seat on the Subpart N committee.This group represents over 1100 crane industrial members and is a leader in promoting crane safetyDoug Williams, their proposed candidate, 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.We do object to the inclusion of two representatives from the International Union of Operating Engineers.  Mr. Williams has been heavily involved in the CCO program for operators and would represent a large number of open-shop operators.  There are more open shop operators than union operators nationwide.  Our information 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 operators to not be properly represented.  Furthermore, Mr. Williams is a company owner, which is an important perspective that is currently only reflected in a minor way on the committee.There may be persons on the committee who are members of SC&RA, but are not actual owner/users, who will be most directly affected by the regulation and subject to OSHA citations.We urge you to include SC&RAs candidate Doug Williams on the Subpart N Committee.  Thank you for your consideration.Respectfully submitted,John Garrison, Past PresidentPamela W. Pocock, Executive DirectorThe Steel Erectors Association of America
 
