VSRA News

Through National Alliance of the Shipbuilders Council of America (SCA) and OSHA, and in coordination with ASA, ASSE, AIHA, and NSRP, we are pleased to share the recently approved Safety Alert for Control of Hazardous Energy. This Alert is the next in a series of Alerts being developed on electrocution hazards in shipyard employment. We hope that you find this useful.

On August 19th,OSHA proposed adding language clarifying that noncompliance with PPE and training requirements may expose employers to liability on a per-employee basis. The amendments consist of new paragraphs added to the introductory sections and changes to the language of existing respirator and training requirements of Parts 1910 and 1915, among others.

IMPORTANT- This proposed action only affects the Agency's ability to treat an employer's failure to provide PPE or training to each covered employee as a separate violation. The amendments add no new compliance obligations. Employers are not required to provide any new type of PPE or training, to provide PPE or training to any employee not already covered by the existing requirements, or to provide PPE or training in a different manner than that already required. The amendments simply clarify the remedy for violations of these requirements.

What you need to know about this rule…

• OSHA is proposing to add a new section to subpart A of parts 1910, 1915, 1917 and 1918, and to subpart C of part 1926. These new sections contain general information about the scope and applicability of the standards in each part.
• Each new section will contain two new paragraphs, identical for each Part.
• The first new paragraph states that standards in the part requiring employers to provide PPE, including respirators, impose a separate compliance duty to each employee required to use the PPE, and that each failure to provide PPE to an employee may be considered a separate violation.
• The second new paragraph expressly states that standards in the part requiring training on hazards and related matters, such as standards requiring that employees receive training or that the employer train employees, provide training to employees or institute or implement a training program, impose a separate compliance duty to each employee covered by the requirement. Each failure to train an employee may be considered a separate violation.
• The proposed rule also includes revisions to specific respirator paragraphs including language explicitly stating that employers must provide an appropriate respirator and implement a respiratory protection program for each such employee. The affected standards include the general respirator standard, most general industry toxic-substance health standards in Subpart Z of 1910, as well as the shipyard employment asbestos standard 1915.1101 and 1915.1026, Chromium (IV).
  

All proposed language and additional information can be viewed in Respirator Enforcement language.

On a sunny day in June, family gathered to watch Ann Howell, VSRA Administrative Assistant, participate in the graduation of her Bachelor of Arts in Psychology from St. Leo University.  It was a proud day for her family, as it was for the VSRA staff.   But there was one thing that had to be accomplished for the degree - a comprehensive exam that was scheduled for late July.  After a bit of "angst" as the date grew near, Ann was fully prepared when the exam day arrived.  MISSION ACCOMPLISHED!  She has finally learned that she successfully passed the comprehensive.  She is now the elated recipient of a Bachelor of Arts degree.

Ann set her goal of completing her bachelor's degree while she was serving as a Religious Speicialist in the U.S. Navy.  With a steady strain and dedication, she continued her quest after leaving the Navy and joining the VSRA Team in late 2006.

Congratulations go to Ann from all the VSRA member companies who have the fortune of being served by Ann.  She is well known for her customer focus within the association.  BRAVO, Ann!

If you have any questions, please let me know.

Linda D. Mayle
Asst NAVSEA SSRAC Coordinator
SERMC Business Office Code 1220/Standards Coordinator
Ph:  904-270-5593
FAX:  904-270-5729
linda.mayle@navy.mil

On Tuesday, July 15th, Dwight Farmer, the newly apponted Executive Director of both the Hampton Roads Planning District Commission (HRPDC) and the Hampton Roads Metropolitan Planning Organization (MPO) addressed members of the Virginia Ship Repair Association at their monthly membership meeting.  The HRPDC is the regional planning organization with focus on transportation plan development. 

With the recently concluded special session of the Virginia legislature called to address transportation funding shortfalls, his address was very timely.  Mr. Farmer presented a sobering and clear assessment of the history of the Commonwealth;s transportation funding leading to the current crisis.  It was clear from his remarks that the failure of the legislature to pass adequate transportation funding in the special session exacerbates the crisis by delaying future transportation improvements while inadequately funding repairs.

Mr Farmer's MPO Transportation Presentation will give the details.

The Coast Guard has posted a proposed new rules under the Marine Debris Research, Prevention, and Reduction Act.  The proposed rule can be found at http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=0900006480600f08. 

Please note that the comment period ends on July 28th.  The link will describe how comments can be submitted.