assessments of activities that are not required by the rule. dinosaur why hello sweet cheeks have a seat retro poster The AGC and the Coalition have not substantively addressed the specific recommendations of the ACCSH,
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OSHA is clarifying the regulatory text to address this misinterpretation of the rule’s requirements. However, OSHA does not find that these claims of infeasibility based dinosaur why hello sweet cheeks have a seat retro poster on an apparent disregard for current interpretations of the rule to be valid. Similarly, the Coalition has argued that the training requirements of the rule are technologically infeasible (Ex. ). And yet the employer representatives testifying on behalf of the Coalition did not indicate that this is the case. In response to a question from OSHA as to whether training of workers before they actually go out on a site is done, and is therefore feasible, the answer was yes (Tr. ). As the BCTD has pointed out (Ex. 89), employers’ claims of economic infeasibility are based on cost analyses that use inaccurate assumptions about requirements of the rule.
“While showing that the employer will incur some economic cost in complying with the standard, industry representatives have fallen far short of demonstrating that the cost they project will cause economic dislocation in the industry. But even their projected costs are greatly inflated.” The BCTD then analyzed projections by the Coalition that a general contractor with ten employees would have to spend $15,197.50 to comply the first year. Without questioning the unit costs used, the BCTD deleted costs assessed for activities that are not required by the rule. As a result, using the Coalition’s own figures, the costs would be reduced to $5,053. OSHA believes that even that figure is an overestimation of the actual costs, but in any event, the BCTD’s analysis aptly illustrates what OSHA itself has found to be true – that the construction industry’s statements regarding feasibility are based on inaccurate and inflated