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August 6, 2004

Steve Rank
California Occupational Safety and Health Standards Board
2520 Venture Oaks Way, Suite #350
Sacramento, CA 95833

RE: Petition to Recognize Revisions of ANSI Voluntary Consensus Standards

Dear Mr. Rank:

The American Society of Safety Engineers (ASSE ), on behalf of its members in California, formally petitions the California Occupational Safety and Health Standards Board (OSHSB) to adopt or otherwise recognize the most current versions of the standards that have been included below, as appropriate.

These significant American National Standards Institute (ANSI) national voluntary consensus standards have in recent years been revised, reaffirmed or created . OSHSB has a responsibility to ensure that workplace safety and health standards used by California Division of Occupational Safety and Health (Cal-OSH) reflect the best possible levels of knowledge of means to protect workers from safety risks, which the ANSI voluntary consensus process helps ensure. Continued use of out-of-date standards (e.g., Z87.1 Eye and Face Protection) by Cal-OSH, particularly in enforcement and interpretation proceedings, is of significant concern to ASSE and its members' efforts to advance safety for California's workers. OSHSB's recognition of the current

version of ANSI standards will positively impact workplace safety and health in California.

The particular revised and updated standards that ASSE believes OSHSB should recognize are:

  • ANSI/ASSE Z117.1-2003, Safety Requirements for Confined Spaces.
    As you are aware, confined spaces continues to be a significant occupational safety and health issue in the United States, and our belief is that enhanced recognition of the latest ANSI standard by CAL-OSH would be of significant assistance in preventing future injuries, illnesses, and fatalities arising from confined spaces. It should be noted that the federal Occupational Safety and Health Administration (OSHA) references the Z117.1-1989 Standard in a number of locations on the OSHA website and has updated its site to include the 2003 version of the standard. Our view is that the Z117.1-2003 Standard provides a level of protection superior to the 1989 version of the standard.
  • ANSI/ASSE Z244.1-2003, Control of Hazardous Energy – Lockout/Tagout And Alternative Methods
    Federal OSHA also recognizes this standard and Lockout/Tagout continues to be a significant occupational safety issue for business and industry. This version of the standard we believe is significantly stronger than past standards and the current regulatory requirements.
  • ANSI/ASSE Z490.1-2003, Accepted Practices in Safety, Health, and Environmental Training
    We note that training issues are addressed in a whole series of regulations. Our request is that the regulations be updated to reflect that training should be consistent with the Z490.1 Standard as it provides for a comprehensive benchmark to improve and move safety and health training programs forward.

    Of key importance is the fact that this standard provides a 30,000-foot view of safety, health, and environmental training. It is not the intention of the Z490 Committee to attempt to address every aspect of safety, health, and environmental training in one comprehensive document. Such an approach would not be effective and would be a disservice to the key objectives we are trying to achieve. Our hope is that with this standard as a basic guideline, additional projects will provide training standards on specific applications.
  • ANSI/ASSE A1264.1-1995(R2002), Safety Requirements for Workplace Floor and Wall Openings, Stairs and Railing Systems
    This standard addresses s afety standards intended to provide protection to persons in workplaces where there is danger of persons or materials falling through the floor or wall openings or from stairwells, platforms, or runways.
  • ANSI/ASSE A1264.2-2001, Standard for the Provision of Slip Resistance on Walking-Working Surfaces
    This standard sets forth provisions for protecting persons where there is potential for slipping and falling as a result of surface characteristics or conditions.

The OSHSB and its members have actively supported ASSE, several members belong to the Society, and OSHSB's past consideration of the Society's positions and initiatives is greatly appreciated. We look forward to your response to this petition. If you should have any questions or concerns, please contact Dave Heidorn, ASSE's Manager of Government Affairs and Policy, at 847/768-3406.


Gene Barfield, CSP

cc: ASSE Board of Directors
Chief, Cal-OSH
Members, ANSI Accredited Standards Committees
Members, OSHSB
Standards Development Committee
Tom Butler, ASSE Region 1 ARVP for Governmental Affairs