The majority of these were from representatives of the construction industry, george strait i cross my heart lyrics couple in love poster and from distributors of hazardous chemicals. The arguments generally involved the degree of risk encountered in the industry,
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to the risks of chemical exposures can be determined by the number of hours included in union apprenticeship training programs is spurious at best (Ex. 84). george strait i cross my heart lyrics couple in love poster And despite AGC’s claims to the contrary, the BCTD’s refusal to respond to AGC’s inquiries regarding such programs does not indicate that its members do not consider the issue to be important (Tr. ). As counsel for the BCTD indicated, “the employer has the responsibility to ensure safety on the work site, and that includes the safety training and hazard communication identification.” (Tr. 6-135.) Nevertheless, a member of the BCTD panel had already addressed knowledge gained in apprenticeship programs (Tr. ), and in response to similar inquiries from the AGC, both the Sheet Metal Workers (
Tr. ; Ex. 81) and the AFL-CIO (Tr. ) confirmed that such training is in fact included in union programs, and that the emphasis on such information has increased in recent years. Significant risk – OSHA’s findings. As has been discussed previously in this preamble, as well as in the preambles to the final rules in 1983 and 1987 and the Third Circuit litigation on the HCS, OSHA has determined that there is a significant risk to all workers exposed to hazardous chemicals without benefit of information regarding those hazards, the identities of the chemicals, and associated protective measures. Despite these explicit determinations by OSHA in 1983 and 1987, as well as by the Third Circuit in its decisions , and a subsequent reiteration of this determination in the NPRM, there were still some comments submitted which suggested that certain industrial sectors should be exempted from the rule, or only covered by limited provisions.