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OSHA questioned these employers on present practices. budweiser beer crocs Specifically, the OSHA panelist asked each employer to “tell me what kind of training you provide for your workers in accordance with 1926.21,

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The only difference of opinion in approach has been that the Committee would like a separate standard to be promulgated, and the Agency has maintained that such an approach is not appropriate on this particular issue. budweiser beer crocs A difference of opinion does not mean that the Agency has ignored the advice of the Committee. As cited before, there are numerous indications in the comments and testimony of the participants that the hazards in the construction industry are not recognized by the employer representatives, thus it is unlikely that adequate training is being done. (See, e.g., Exs. and .) Comments submitted in response to the revised final rule, for example, clearly indicate that companies were estimating compliance burdens based on analyses that assumed no training had been done to date (see, e.g., Exs. 5-10, 5-65, and 5-117).

The third employer was an electrical contractor, and he stated that safety hazards related to electrical work are addressed in worker training. Coverage of chemical hazards in current training was less clear since he indicated there aren’t many products of concern in the electrical industry, and the employers are not sure what is a hazard (Tr. 5-47). Apparently, employers are receiving MSDSs for many products they use that are not actually hazardous chemicals covered by the HCS (e.g., flashlight batteries). Products such as flashlight batteries are exempted as articles under the rule, and thus do not have to be included in training. Four employer representatives testified on behalf of the Coalition. As a primary argument of construction industry representatives was that current training sufficiently mitigates any risk of exposure that may occur in construction,