TCIA 1910.269 comment to Board

Tree Care Industry Association Page 1 of 13 [Date] OSHA Docket Office Docket No. S-215 U.S. Department of Labor 200 Constitution Avenue, NW Room N2625 Washington, DC 20210 RE: Comments on Docket Number S-215, RIN 1218-AB67, 29 CFR Parts 1910 and 1926, Electric Power Generation, Transmission, and Distribution; Electrical Protective Equipment; Proposed Rule Ladies and Gentlemen: The Tree Care Industry Association (TCIA, formerly the National Arborist Association) is a 67-year-old trade association for tree service businesses that represents the interests of some 1700 employers in the United States. Our membership is comprised of arborist firms engaged in residential and commercial tree trimming as well as the “line clearance tree trimming” industry, which trims trees proximate to overhead electric wires for their electric utility customers. In terms of numbers of companies, over half of our members are directly and materially affected by proposed changes to 29 CFR 1910.269. TCIA has been deeply concerned with and proactive about electrical hazards faced by workers in trees long before 29 CFR 1910.269. We have educated arborists to this hazard for over 30 years and in fact, in fiscal 2005 alone, we employed an OSHA/Susan Harwood grant to bring electrical hazards awareness training to over 2300 arborists in the field. Our association worked closely with OSHA throughout the original promulgation of 1910.269, as numerous references in ...