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and conducting such programs insofar as they deal with communicating led zeppelin thank you lyrics couple in love poster the hazards of chemicals on the job site.” AGC’s argument that the significance workers attach

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Over 4300 of those violations were cited as being serious, and 32 were considered to be willful.) There is evidence in the rulemaking record that complete training on chemical hazards led zeppelin thank you lyrics couple in love poster is not widespread in the construction industry despite the long – established requirements. As cited in the NPRM preamble , the most compelling evidence is a BLS study which indicated that only 23% of construction workers had been trained regarding such hazards. The BLS report was based on a survey administered to construction workers who had been injured on the job. The primary difference between the two rules is that the 1926.21 standard is very general and does not provide employers with sufficient guidance to establish an adequate training program for hazard communication. OSHA testified to this point in response to questions raised at the public hearing, Tr. .

This has been pointed out repeatedly by members of the Advisory Committee on Construction Safety and Health (Tr. ), and the Agency has attempted to somewhat rectify the problems by providing additional guidance in a compliance directive (Ex. 4-152). However, there are still problems with enforcement due to the way the provisions were drafted when adopted. There were suggestions in the record that unions be required to assume some of the compliance burden. The Flat Glass Marketing Association indicated that unions should be held responsible for training since the contractors frequently hire employees from union halls (Ex. ). “There is no reason why OSHA should not require the unions to include in their apprenticeship training programs courses on hazardous chemical identification, detection, and treatment. The unions should be required to cooperate with the employers in developing