U.S. Occupational Safety and Health Administration
OSHA/DOL Docket Office, Docket #206C
200 Constitution Avenue, NW
Washington, DC 20210

The purpose of this letter is to provide commentary from the American Society of Safety Engineers (ASSE) addressing the OSHA 7/14/99 request for insight on fall protection standards in the construction industry.

Introduction
The American Society of Safety Engineers (ASSE), is the oldest and largest Society of Safety Professionals in the world. Founded in 1911, ASSE represents almost 33,000 dedicated safety professionals. Included in this membership are Certified Safety Professionals, Professional Engineers, agronomists, academicians, fire protection engineers, system safety experts, industrial hygienists, physicians, occupational nurses, and an impressive collection of other disciplines, skills, and backgrounds. We pride ourselves on our dedication to excellence, expertise, and commitment to the protection of people, property, and environment on a world-wide basis.

ASSE serves as Secretariat of seven (7) American National Standards Institute Committees (ANSI) developing safety and health standards which are used by private sector organizations as well as state/Federal governmental agencies such as MSHA, OSHA, etc... ASSE members also sit on over forty (40) additional standards development committees and the Society sponsors educational sessions on standards development. The Society also has twelve (12) technical divisions consisting of: Construction, Consultants, Engineering, Environmental, Health Care, International, Management, Public Sector, Risk Management and Insurance, Mining, Industrial Hygiene, and Transportation. The ASSE members included in these divisions are leaders in their field with the knowledge and expertise needed to move safety and health forward on a global level. Of specific interest to OSHA is that the ASSE Construction Division currently has a membership of over (Need this number), thus, the Division by itself is one of the larger professional safety construction organizations in the United States.

Commentary Insights
The intent of ASSE is not to speak either for or against the proposal, but rather to make comments based upon our member views, existing data, and anecdotal information. Based upon such collective insight, we submit the following general comments which should be of importance to OSHA when the Agency reviews the complete record:

ASSE is the Secretariat of the ANSI Z359.1-1992 (recently reaffirmed in 1999) standard titled: Safety Requirements for Personal Fall Arrest Systems Subsystems and Components. While the standard does not address construction, it does provide a great deal of technical guidance on the overall issue of fall protection, thus, we have enclosed a copy of the standard for review by OSHA. We have seen where Federal agencies have used the standard as a source document in past regulatory initiatives, (e.g.: SENRAC). The Agency may wish to cite references to the standard if/when such recognition would be appropriate from an overall view of effective fall protection systems. We have enclosed a copy of the standard for review by the Agency.

The Society has dedicated significant resources to research the overall fall protection issue. Of interest to OSHA is that ASSE is currently funding a full literature/background research project through Northern Illinois University (NIU). ASSE is providing funding for an intern at NIU to fully research the literature and research in fall protection. Much of this research may impact construction, and upon completion of the project we will provide our findings to the appropriate OSHA staff members. We believe it would be appropriate for OSHA to remain in the "loop" on this issue, as the results of the findings could have potential impact on the Agency's initiative.

The American National Standards Institute (ANSI) recently confirmed accreditation of the U.S. Technical Advisory Group (TAG) for fall protection. ASSE has also been selected to serve as administrator of the TAG. The U.S. TAG will meet and develop recommendations for the U.S. position on the international fall protection standards developed by the International Organization for Standardization's (ISO) Technical Committee 94, Subcommittee 4. ANSI, as the U.S. voting representative to ISO, casts the official vote for the U.S. on such standards. As proposed by ASSE, the U.S. TAG will consist of more than 20 entities with an interest in fall protection, including governmental agencies, users of fall arrest systems, professional societies representing safety professionals, manufacturers of fall arrest equipment and employers of those who use the equipment. With the globalization of the economy, there is an increasing reliance on international standards for both trade and safety at work. This accreditation will enable U.S. interests, including users, manufacturers and regulators, to present a U.S. perspective on fall protection to the worldwide community. We urge OSHA to participate in this activity as the data, research, and evidence obtained through this project could significantly impact the Agency.

On page 38081 of the Federal Register Announcement OSHA requests feedback on ladder safety issues, and specifically commercial hooking equipment used to secure ladders. We suggest that OSHA review the work of the ANSI A-14 Committee which develops voluntary national consensus standards for the safe design, construction, testing, selection, care and use of ladders. ASSE served as the first (charter) secretariat of this ANSI Committee. However, the American Ladder Institute now has assumed these responsibilities. These standards address, include but are not limited to: fixed, job built, portable, extension, step, trestle, extension trestle, sectional, combination, single, platform, and ladder type step stools. Here is a listing of A14 standards on ladder safety:

• A14.1 - Portable Wooden Ladders
• A14.2 - Portable Metal Ladders
• A14.3 - Fixed Ladders
• A14.4 - Job-Made Ladders
• A14.5 - Reinforced Plastic Ladders
• A14.7 - Rolling Ladder Stands
• A14.8 - Ladder Accessories (Draft in Progress)
• A14.9 - Fixed Attic Stairways
• A14.10 - Ultra Heavy Duty Portable Reinforced Plastic Ladders

Of significance to OSHA is that the draft A14.8 standard addresses ladder accessories, and this might provide insight for OSHA into the technical issues impacting the hooking equipment which the Agency seeks comment for. The American Ladder Institute can be contacted at 312/644-6610.

We see significant opportunity in the OSHA proposal, if it moves forward, on a cooperative partnership of labor, trade groups, and government representatives working together on this initiative. We urge that if such a proposal goes forward, it is important that there be participation from the professional safety and health associations/societies. In the 9/99 NACOSH statement made by ASSE Deputy Executive Director Tom Bresnahan, the Society urged that a place be found on such Advisory and Neg/Reg Committees for safety professionals. We would be reticent to support such an initiative moving forward that would impact large numbers of our members, and with ASSE having no voice in it. If such an Advisory Committee is to be established, ASSE would hope to be named to the panel, as we represent significant numbers of safety and health professionals employed in the construction industry. Finally, we have enclosed several articles which might be of interest to OSHA when reviewing the data either supporting or opposing the potential new initiative.

We thank you for your attention to this matter, and look forward to working with you in the future. If you should have any questions or issues please do not hesitate to contact the Society.

Regards,

Frank H. Perry, CSP, PE
Society President, 1999-2000

Copy To: ASSE Board of Directors
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                  ASSE Governmental Affairs Committee
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