THE CHAIRMAN’S NOTES – OSHA Standards Update. Several standards and issues have been moved ahead by OSHA.
Fire Protection in Shipyard Employment (29 CFR1915 Subpart P) In the final rule, issued Dec 14, 2004, OSHA gave employers until March 14, 2005 to accomplish the training required by the standard. An ASA representative sent a letter to OSHA requesting a delay of the effective date in order to make it coincide with the training deadline: training typically occurs before placing a new standatd in place. Those close to the process believe there is little chance for the requested delay to be granted. Marine Chemists should consider the standard to be in effect.
OSHA is preparing a Subpart P guidance document that will help clarify certain parts of the standard. They requested that Marine Advisory Committee on Safety & Health (MACOSH) assemble a work group to prepare a list of questions about the standard. (Your MCA Chairman was present at the work group session.) OSHA is preparing responses to those questions and will publicize the answers on their FAQ (Frequently Asked Questions) website. When we see the responses we will inform you via the MCA website.
General Working Condition (29CFR1915 Subpart F) – The notice of proposed rulemaking is scheduled for March 2005. This is the standard that addresses work in confined or isolated spaces as well as lock out/tag out. OSHA has asked the SHAC committee to assist them in gathering information about current lock-out/tag-out processes in the maritime industry. At its last meeting SHAC presented the following conclusions of their research. Tags are used as a primary control measure at most shipyards, though some use additional locking devices. Most yards have separate programs for landside activities. It is expected that the new standard will require a “tags plus” approach, but currently there are no specifics on the “plus” aspect, other than tags by themselves may not be enough. The MCA is following development of this standard as it has the potential to have a significant impact on our current practices. We hope to have SHAC Co-Chair Thresa Nelson address the standard at our national seminar.
Hexavalent Chromium (29CFR1915.1026) – The Notice of Proposed Rulemaking (NPRM) was issued on Oct 4, 2004, the comment period closed Jan 3, 2005 and there is a Jan 18, 2006 Court deadline for the final rule. The NPRM asked for industry’s answers to some 65 questions about the standard and hexavalent chrome in general. Representatives from many maritime committees, associations and shipyards provided comments. Of significance is the development of a separate standard for the maritime industry that addresses some of our industry-specific issues. As this standard is in the proposal stage, it is too early to provide any specific information about how the standard may impact our industry.
The MCA will continue to track the development of this standard and keep you informed about its progress.
Maritime Fatality Videos – A second OSHA maritime fatality video is nearing completion, and as many of you may recall from the 2003 mini seminars where the first video was displayed, these computer-animated representations videos of actual marine industrial make fantastic training tools. When complete, the MCA will obtain a copy and possibly distribute to all chemists for their use. Greg Grondin, Chairman
Sectional Seminars – This year’s seminars will address several topics of concern to the MCA, the MCQB and the USCG. The locations and dates are as follows:
Gulf-Inland Sectional Seminar:
Saturday, February 26, 2005
(Note: ExCom Meeting, Sunday February 27)
New Orleans Hilton Hotel. tel: 504/469-5000
Atlantic Sectional Seminar:
Sunday, March 13, 2005
Norfolk Hilton Hotel. tel: 757/466-8000
Pacific Sectional Seminar:
Saturday, March 19, 2005
InnSuites Hotel, Tucson, AZ. tel: 520/622-3000
The Program planned is as follows:
– Adjacent Spaces & Certificate Implications
– New Subpart P Requirements
– Implications of the Trinity Case
-‘Safe Boat’ Repair Procedures & USCG Requirements
– MACOSH & SHAC Update
– National Certificate Review Results & Comments
– Incidents/Near Misses
– CHT/Sewage & Certificate Writing
– The CMC AGST Training Module
‘Safe Boat’ work has become an especially hot topic. The USCG has issued a procedure required of its industrial facilities when repairing these gasoline-driven boats. Frequent mention of marine chemists in this procedure will be addressed and discussed at the ‘minis’. These boats have exploded during improper repair.
As always, sectional business meetings will be held after each sectional seminar. You are encouraged to contact your representatives to ensure any issues you wish discussed are covered as part of your section’s meeting.
Elections – This is an election year! In addition to new representatives and/or alternates, a new chairman-elect will be selected this spring in accord with the MCA Bylaws to begin a six year service cycle. In summary, the Secretary must receive nominations by March 15th. Candidates must submit or have forwarded three letters of endorsement, one from at least one member of each section, and a letter must be submitted from the candidate (with supporting biographical information) affirming their willingness to stand for election and serve. The MCA Executive Committee’s nomination committee shall then submit to the membership a list of qualified candidates. The Secretary shall prepare and circulate ballots by May 1st. Ballots will be tallied on June 1st. Don Raffo, CMC 668 of Stonington CT, a long-time active member in service of the executive committee, has agreed to put his hat in the ring, Any other candidates are encouraged to come forward before we put our fingers in purple ink this May.
News Items – Blair Duff, CMC 698 is our newest chemist. Blair hails from Hollywood, Florida and has been brought along by Pete Rimmel, CMC 638. Blair’s neighborhood is populated with some of the largest steel yachts in the US, along with the usual assortment of tankers, shore-side tanks and USCG vessels. Welcome aboard!
Jim Wadatz, CMC 617, has added CSP to the CMC and CIH in his professional title. Jim has joined an exclusive group of chemists: T o m Beacham, CMC 635, Troy Corbin, CMC 644, Frank Monaghan, CMC 656, and John Fernandez, CMC 696 as possessing what are generally considered the three key-stone certifications for safety and health professionals – a rare and noteworthy accomplishment. Congratulations.
Gone to NZ and the tennis courts! – Marty Finkel, CMC 640, is in the final stages of emigration to New Zealand. After years of careful planning, Marty is hanging up his sniffer and taking up something new. He has built a new home and is training for work as a volunteer Ambulance Officer and Emergency Medical Technician (EMT- 3) for his new community of Coopers’ Beach in Mangonui, NZ. Also retiring is Ken Chang, CMC 625 of Honolulu. Ken was a mainstay chemist for Honolulu Shipyard and on the clay courts at Ala Moana Park for years, and now he and Donna plan to take it easy. Fair wind and a following sea, gentlemen! Thanks for many fine years of invaluable service to our industry and its workers.