Thursday, September 30, 2010


I got a request to start a new thread on the Crane standard, but since I'm an IH and don't have much crane experience (and no experience yet with the new standard) I'm posting the request here in the hopes that others can bring about a discussion:
I have a suggestion for a new blog thread. Why has OSHA adopted new technology for insulated links for use with cranes without doing sufficient research and testing. Look what happened when NIOSH tested proximity warning devices, they failed miserably. Now even though they are still mandated in subpart CC, OSHA admits they are flawed and does not require their use. OSHA should do the same for Links and ask NIOSH to study and test their performance, use, maintenance, and the reliance issues that may occur with thier use.

Also, OSHA should look at how UL went about writing a standard, and how one provider is now marketing that his product meets Subpart CC, even though OSHA stated in the preamble that there are no NTRL's approved by OSHA to certify links.

Wednesday, September 29, 2010


So this morning I had a radical idea on how to deal with our PELs.  Everyone on the planet knows our PELS are horribly out of date, they're from 1968 or 1970 (general industry vs construction) and many don't take into account health effects that may occur at lower exposures.  So here's the idea:
Withdraw the standards, both 1910.1000 and 1926.55.
Totally insane isn't it?  When it first occurred to me I actually laughed out loud, you can imagine the looks.  But why not?  We already cite 5(a)(1) for chemicals that don't have exposure limits and we can cite 5(a)(1) when there is a PEL, if people exhibit health effects not covered by the original TLV documentation and we can show the employer knew.  Even though we can do this, we almost never do because we're either too busy or too lazy.  So why not go 5(a)(1) for everything?

It would take a little more work, but it would also allow us to enforce based on current science, not 40 year old science.  Business probably wouldn't like it very much, they would be afraid that enforcement would be too inconsistent and they wouldn't know to what level they would need to protect their employees.  And they would probably be right, at least partially.  This would very likely lead to the call for a return of the PEL tables, which might be enough for Congress to give us a special dispensation to adopt new PELs, which would then allow us to update the PELs to appropriate levels.  Even the threat of doing this might be enough to bring about the changes that are needed.

It's a radically insane idea that might or might not work, but it doesn't really matter since no one has the stones to try it.