NIOSH Comments to DOL on the Occupational Safety and Health Administration's Shipyard Employment Safety Standards; Proposed Rules by R. W. Niemeier, February 28, 1989

摘要

The testimony presents the comments of NIOSH in regard to the proposed revision of OSHA to six subparts of the existing OSHA shipyard employment safety standard. The six subparts include explosive and other dangerous atmospheres; welding, cutting and heating; access and egress; personal protective equipment; fall protection; and scaffolds. NIOSH notes that wherever possible OSHA replaced specific type provisions with performance oriented provisions. Overall the proposed changes provide better protection for workers from shipyard hazards. NIOSH agrees with OSHA that performance oriented standards may stimulate employer innovation for developing more creative solutions. NIOSH also recognized that performance oriented standards may provide insufficient guidance and detailed explanation of requirements to the employer and may thereby result inadvertently in inadequate worker protection. Comments are included concerning specific sections.