Cranes and Derricks in Construction 29 CFR Part 1926

January 2, 2019

OSHA Docket Office

U.S. Department of Labor,

Room N-2625,

200 Constitution Avenue, N.W.

Washington, D.C.20210

Regarding: Docket No. OSHA-2007-0066

Cranes and Derricks in Construction – 29 CFR Part 1926

Dear Administrator:

NECA appreciates the opportunity to submit comments on the proposed ruling for Cranes and Derricks in Construction.

NECA like OSHA is equally committed to providing the workforce with a safe and healthful working environment. We hope that these comments are looked upon as a sincere effort toimprove the proposed rule wording and enhance interaction. NECA will continue to provide meaningful support in the OSHA Rulemaking processes.

Exceptions

NECA understands that there is a potential for misinterpretation in one of the proposed exemption as its currently written:

1926.1400 (c) (4) Service trucks with mobile lifting devices for the use of power line and electrical service industries, such as digger derricks (radial boom derricks), when used in these industries for auguring holes to set power and utility poles, or handling associated materials to be installed or removed from utility poles.

In order to avoid any confusion and to honor the initial intention of the C-DAC committee, NECA recommends that the proposed exemption read as follows:

Operator qualification and certification

1926.1427 (c)(6)(i)NotPortable.

Electrical contractors dedicated to Subpart V work many times are called upon by our nation in response to natural disasters. Under the proposed ruling 1926.1427 (c)(6)(i) operators certification are not portable. NECA recommends that OSHA consider employees crossing state line when responding to national disasters.

NECA recommends the proposed ruling should read as follows:

1926.1427(c)(6)(i)Not Portable,unless the operator is engaged in activities related to a national emergency and/or certified through a nationally recognized accredited agency.

NECA is the voice of the $130 billion electrical construction industry that brings power, light, and communication technology to buildings and communities across the U.S. NECA’s national office and 119 local chapters advance the industry through advocacy, education, research and standards development. For more information, visit

Sincerely,

Jerry E. Rivera

Director of Safety

National Electrical Contractors Association

NATIONAL ELECTRICAL CONTRACTORS ASSOCIATION

3 Bethesda Metro Center, Suite 1100, Bethesda, MD20814

(301) 657-3110 x614 tel; (301) 215-4500 fax;