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10th Construction Equipment Joint Technical Meeting CECE, CIMA, EMI and CEMA CECE, CIMA, EMI and CEMA CECE, CIMA, EMI and CEMA CECE, CIMA, EMI and CEMA 2000 May 22, 23 2000 May 22, 23 2000 May 22, 23 2000 May 22, 23 Versailles, France Versailles, France Versailles, France Versailles, France 6.1 ISO 14000 ENVIRONMENTAL MANAGEMENT The following comment is taken from a press release by ISO. “More than 80 percent of 500 companies surveyed on their experiences with implementation of environmental management systems (EMS) found them to be cost effective. Sixty percent of the companies quoted payback periods on their investments of less than 12 months.” The aforementioned statement was quoted from ISO (International Organization for Standardization) in the publication ENVIRONMENTAL MANAGEMENT AND ISO 14000 (ISBN 92-67-10280-X) based on a survey of European companies. This publication was prepared by a panel of authors from ISO/TC207, the technical committee responsible for ISO 14000. There are two key areas for off-highway equipment manufacturers; Environmental Labeling and Life Cycle Assessment. Environmental Labeling is covered in the series 14020-25 and is a work in progress; 14020 General Principles 14021 14022 Self Declared Environmental Labels – Type II 14023 14024 Principles and Procedures – Type I 14025 Guiding Principles and Procedures – Type III Environmental Labeling is categorized into categories. TYPE I - requires analysis of the products environmental attributes and communicates them through a single label (Green Seal, White Swan, Blue Angel, etc.) TYPE II - are self assertions or claims made about a product by the manufacturer on a particular feature – if it is recyclable, or made from recyclable material. TYPE III - lists the environmental effects of a product similar to nutrition labeling. The most significant aspect of labeling is the level of integrity in the claim and the extent of its applicability to local, regional, or global markets. Further aims of the series are; - limited administrative burdens - open consensus process - unobstructive to international trade

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Page 1: 6.1 ISO 14000 ENVIRONMENTAL MANAGEMENT American issues.pdf · - Evaluation of environmental performance (ISO 14031) It is important to understand that there are major differences

10th Construction Equipment Joint Technical MeetingCECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMA

2000 May 22, 232000 May 22, 232000 May 22, 232000 May 22, 23Versailles, FranceVersailles, FranceVersailles, FranceVersailles, France

6.1    ISO 14000 ENVIRONMENTAL MANAGEMENT

The following comment is taken from a press release by ISO.

“More than 80 percent of 500 companies surveyed on their experiences withimplementation of environmental management systems (EMS) found them to be costeffective. Sixty percent of the companies quoted payback periods on their investments ofless than 12 months.”

The aforementioned statement was quoted from ISO (International Organization forStandardization) in the publication ENVIRONMENTAL MANAGEMENT AND ISO 14000(ISBN 92-67-10280-X) based on a survey of European companies. This publication wasprepared by a panel of authors from ISO/TC207, the technical committee responsible for ISO14000.

There are two key areas for off-highway equipment manufacturers; Environmental Labeling andLife Cycle Assessment.

Environmental Labeling is covered in the series 14020-25 and is a work in progress;

14020 General Principles1402114022 Self Declared Environmental Labels – Type II1402314024 Principles and Procedures – Type I14025 Guiding Principles and Procedures – Type III

Environmental Labeling is categorized into categories.

TYPE I - requires analysis of the products environmental attributes andcommunicates them through a single label (Green Seal, White Swan, BlueAngel, etc.)

TYPE II - are self assertions or claims made about a product by the manufacturer ona particular feature – if it is recyclable, or made from recyclable material.

TYPE III - lists the environmental effects of a product similar to nutrition labeling.

The most significant aspect of labeling is the level of integrity in the claim and the extentof its applicability to local, regional, or global markets. Further aims of the series are;

- limited administrative burdens- open consensus process- unobstructive to international trade

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- will not inhibit innovation that could improve environmental performance.

At this point the TYPE I labeling requirements are so strict that manufacturers can notcompletely meet them.

Life Cycle Assessment is covered in the series 14040-43 and is also a work in progress;

14040 Principles and Framework14041 Inventory Analysis14042 Impact Assessment14043 Interpretation

Only 14040 has been published as a standard. The Inventory Analysis 14041 is in the final draftstage (FDIS) while both 14042 and 14043 are in the draft stage (DIS).

ISO 14040 provides the following points;- Introduction to Life Cycle Analysis (LCA)- Phases of LCA- Methodology Framework- Goals and Scope- LCA Inventory Analysis- LCA Impact Statement- Interpretation- Reporting- Critical Review

ISO 14041 (FDIS) provides the following points;- Covers the first two phases of LCA

- Definition of scope- Object of study- Inventory and technical requirements of that phase

- An engineering based mass balance equation providing initial plans forconducting an LCA.

ISO 14042 (DIS) provides the following points;- Mass energy inputs and outputs- Significance of systems

- Resource depletion- Emissions- Wastes

- Identification and characterization of significant potential environmental loadingfor evaluation of system opportunities.

- Comparison between products and services systems- Prioritization from LCA findings from ISO 14042 Life Cycle Impact Assessment.

ISO 14043 (DIS) provides the following points;

- Illustrates links between LCA and other environmental management techniques;- Labeling (ISO14024)

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- Management evaluation (ISO 14001)- Evaluation of environmental performance (ISO 14031)

It is important to understand that there are major differences between ISO 9000 and ISO 14000that reflect differently on manufacturers;

- ISO 9000 is a quality standard based on consistency- ISO 14000 is management standard based on improvement (change)- Manufacturers, businesses, and industries were not involved in ISO 9000

development.

Attachment “A” is a list of the participating (P) members, observing (O) members, and liaison(L) organizations. This list is dynamic in as much as members are being added as well asmoving from one status to another. Incorporated in the lists are the national or regionalorganizations participating in TC207.

Attachment “B” is a table of the 1400 series standards with the status in 1999.

Attachment “C” is the organization of ISO/TC207.

Attachment “D” is the scope statement for activity within ISO/TC207.

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ATTACHMENT A

“P” members“P” members represent countries who wish to vote, participate actively in discussionsand have access to all relevant documentation. The following is an annually updatedlisting of TC2007 “P” members (May 1998):

Algeria (INAPI Argentina (IRAM)Australia (SAA) Austria (ON)Bangladesh (BSTI) Belgium (IBN)Brazil (ABNT) Canada (SCC)Chile (INN) China (CSBTS)Colombia (ICONTEC) Costa Rica (INTECO)Cuba (NC) Czech Republic (CSNI)Denmark (DS) Ecuador (INEN)Egypt (EOS) Finland (SFS)France (AFNOR) Germany (DIN)Ghana (GSB) India (BIS)Indonesia (BSN) Ireland (NSAI)Israel (SII) Italy (UNI)Jamaica (JBS) Japan (JISC)Korea (Republic of) (KNITQ) Malaysia (DSM)Mauritius (MSB) Mexico (DGN)Mongolia (MNCSM) Netherlands (NNI)New Zealand (SNZ) Norway (NAS)Philippines (BPS) Poland (PKNRomania (IRS) Russian Federation (GOST R)Singapore (PSB) South Africa (SABS)Spain (AENOR) Sri Lanka (SLSI)Sweden (SIS) Switzerland (SNV)Tanzania (TBS) Thailand (TISI)Trinidad/Tobago (TTBS) Turkey (TSE)Ukraine (DSTU) United Kingdom (BSI)Uruguay (UNIT) USA (ANSI)Venezuela (COVENIN) Zimbabwe (SAZ)

“O” member“O” members represent countries not wishing to vote, but rather only to participate indiscussions and receive all relevant information. The following is an annually updatedlisting of TC 207 “O” members (May 1998):

Barbados (BNSI) Bostwana (BOBS)Croatia (DZNM) Estonia (EVS)Ethiopia (ESA) Greece (ELOT)Hong Kong (HKG) Iceland (STRI)Libyan Arab Jamahiriya (LNCSM) Lithuania (LST)Moldova (Republic of) (MOLDST) Portugal (IPQ)Slovakia (UNMS) Slovenia (SMIS)

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Viet Nam (TCVN) Yugoslavia (SZS)“L” organizationsRepresentatives from “L” organizations (international or broadly based regionalorganizations) are invited to take part in discussions and are permitted to receive allinformation from the TC but are not granted voting status. The following is an annuallyupdated listing of TC207 “L” organizations (May 1998):

APO (Asian Productivity Organization)CEFIC (European Chemical Industry Council)CEPI (Confederation of European Paper Industries) ( Temp)CI (Consumers International)EC (European Commission) (Temporary)EDF (Environmental Defense Fund)EEB (European Environmental Bureau)EUMEPS (European Manufacturers of Expanded Polystyrene) (Temp)EURATEX (European Apparel and Textile Association)FoEI (Friends of the Earth)FIDIC (International Federation of Consulting Engineers) (Temp)FSC (Forest Stewardship Council)GEN (Global Ecolabelling Network)IAQ (International Academy for Quality) (Temp)ICC (International Chamber of Commerce)ICME (International Council on Metals & the Environment)IFOAM (IFOAM Accreditation Programme)IISD (International Institute for Sustainable Development)IISI (International Iron & Steel Institute)IMA (Industrial Minerals Association – Europe)INEM (International Network for Environmental Management)IPAI (International Primary Aluminum Institute)ITC (International Trade Centre)NWF (National Wildlife Federation)OECD (Organization for Economic Cooperation and Development)Sierra Club (Temp)UNCTAD (United Nations Conference on Trade and Development)UNDP (United Nations Private Sector Development Programme)UNEP (United Nations Environment Programme)WFSGI (World Federation of the Sporting Goods Industry) ( Temp)World Stewardship Institute (Temp)WTO-OMC (World Trade Organization)WWF (World Wide Fund for Nature)IEC/TC 75, Classification of Env. ConditionsISO/TC 45, Rubber and Rubber ProductsISO/TC 61, PlasticsISO/TC 91ISO/TC 176, Quality ManagementISO/TC 197, Hydrogen Energy TechnologyISO/TC 203, Technical Energy Systems

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Attachment B

Standard Title Status

ISO 14001 Environmental management systems –Specification with guidance for use

PublishedSeptember 1996

ISO 14004 Environmental management systems –General guidelines on principles, systems andsupporting techniques.

PublishedSeptember 1996

ISO 14010 Guidelines for environmental auditing –General principles

PublishedOctober 1996

ISO 14011 Guidelines for environmental auditing –Audit procedures –Auditing of environmental management systems

PublishedOctober 1996

ISO 14012 Guidelines for environmental auditing –Qualification criteria for environmental auditors.

PublishedOctober 1996

ISO/WD14015

Environmental assessment of sites and entities First working draftSeptember 1997

ISO 14020 Environmental labels and declarations –General principles

PublishedAugust 1998

ISO/DIS14021

Environmental labels and declarations –Environmental labeling –Self declared environmental claims

Target publicationdate early 1999

ISO/FDIS14024

Environmental labels and declarations –TYPE I environmental labeling –Principles and procedures

To be publishedearly 1999

ISO/WD/TR14025

Environmental labels and declarations –TYPE II environmental declarations –Guiding principles and procedures

Type 2 – TechnicalReport inpreparation

ISO/DIS14031

Environmental management –Environmental performance evaluation –Guidelines

To be publishedmid 1999

ISO/TR14032

Environmental management –Environmental performance evaluation –Case studies illustrating the use of ISO 14031

To be publishedearly 1999

ISO 14040 Environmental management – Life cycle assessment –Principles and framework

PublishedJune 1997

ISO 14041 Environmental management – Goal and scope definitionand inventory analysis

PublishedOctober 1998

ISO/CD14042

Environmental management – Life cycle assessment –Life cycle impact assessment

To be publishedearly 1999

ISO/DIS14043

Environmental management – Life cycle assessment –Life cycle assessment interpretation

To be publishedearly 1999

ISO/TR14048

Environmental management – Life cycle assessment –Life cycle assessment data documentation format

To be publishedearly 1999

ISO-TR14049

Environmental management-Life cycle assessment – Examples for the application ofISO 14041

First draft sinceNovember 1997

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Standard Title Status

ISO 14050 Environmental management – Vocabulary PublishedMay 1998

ISO/TR14061

Information to assist forestry organizations in the use ofthe Environmental Management System standards ISO14001 and ISO 14004

To be publishedend 1998

ISO Guide 64 Guide for the inclusion of environmental aspects inproduct standards

PublishedMarch 1997

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ATTACHMENT C

ORGANIZATION OF ISO/TC 207

ISO/TC 207 Environmental Management CanadaScope Standardization in the field of environmental management tools and systemsISO/TC 207/SC 1 Environmental Management Systems United Kingdom (Chair, Secretary)Scope Standardization in the field of environmental management systemsISO/TC 207/SC 2 Environmental Auditing and related Environmental Investigations Netherland (Chair, Secretary)Scope Standardization in the field of environmental auditing and related

environmental investigationsISO/TC 207/SC 3 Environmental Labeling Australia (Chairman, Secretary)Scope Standardization in the field of environmental labeling, including first-party

practices (self-declaration/claims), and guiding principles for third-partycertification programs (private and government).

ISO/TC 207/SC 4 Environmental Performance Evaluation USA (Chairman, Secretary)Scope Standardization in the field of environmental performance evaluation for use

by organizations to measure, assess and communicate their environmentalperformance for appropriate management purposes.

ISO/TC 207/SC 5 Life Cycle Assessment Chairman: Germany;Secretary: France

Scope Standardization in the field of life cycle assessment as a tool forenvironmental management of product and service systems. It encompassesthe assessment of impacts on the environment from the extraction of rawmaterials to the final disposal of waste.

ISO/TC 207/SC 6 Terms and Definitions Norway (Chairman, Secretary)Scope Coordination of terms and definitions between ISO/TC 207 subcommittees

and other committees and relevant organizations. Development of acomprehensive international standard on terms and definitions withinenvironmental management.

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ATTACHMENT D

TC 207 CAGTitle: Chairman’s Advisory Group

Scope: The ISO/TC 207 CAG will advise the Chairman as to recommendations that should be put to ISO/TC 207 for consideration andpossible decision.

TC 207 WG1Title: Environmental Aspects of Product Standards (EAPS)

Scope: Development of an ISO Guide on the inclusion of environmental aspects in product standards.TC 207 WG2

Title: Forestry ManagementScope: To prepare a report describing informative reference material for the implementation of ISO 14001 and the use of ISO 14004 by

forest organizations.TC 207 SC1

Title: Environmental Management Systems (EMS)Scope: Standardization in the field of environmental management systems.

TC 207 SC2Title: Environmental Auditing and elated environmental investigations

Scope: Standardization in the field of environmental auditing and related environmental investigations.TC 207 SC3

Title: Environmental LabelingScope: Standardization in the field of environmental labeling, including first-party practices (self-declaration/claims), and guiding principles

for third-party certification programs (private and government).TC 207 SC4

Title: Environmental Performance EvaluationScope: Standardization in the field of environmental performance evaluation for use by organizations to measure, assess, and communicate

their environmental performance for appropriate management purposes.TC 207 SC5

Title: Life Cycle AssessmentScope: Standardization in the field of life cycle assessment as a tool for environmental management of product and service systems. It

encompasses the assessment of impacts on the environment from the extraction of raw materials to the final disposal of waste.TC 207 SC6

Title: Terms and DefinitionsScope: Coordination of terms and definitions between ISO/TC subcommittees and other committees and relevant organizations.

Development of a comprehensive international standard on terms and definitions within environmental management.US/TAG

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Scope: The US/TAG for ISO/TC 207 is a consensus committee accredited by ANSI to develop USA positions on the documents beingdeveloped by ISO/TC 207.

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10th Construction Equipment Joint Technical MeetingCECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMA

2000 May 22, 232000 May 22, 232000 May 22, 232000 May 22, 23Versailles, FranceVersailles, FranceVersailles, FranceVersailles, France

6.2.1     ANSI Activities - Laboratory Accreditation

ANSI provides several accreditation services. It conducts a product certifier accreditationprogram that enables manufacturers of specific product types to utilize the services of acertification body for certification of products to the specific requirements. This program hasbeen limited primarily to building products. Below is a list of the various types of programs thathave been established at the ANSI Website - http://web.ansi.org/public/ca/ca_1.html

The American National Standards Institute (ANSI) provides accreditation for certificationprograms to ensure that the marketplace, including buyers, sellers, and public agencies can relyon the competence of ANSI accredited certification bodies for their activities related to products,processes, services, and personnel. The scope of the ANSI program extends to certifiers ofproducts, processes, personnel, and services. ANSI has accredited certification programs in thefollowing areas:

Windows and doors Sealed insulating glass Treated wood Drinking water additives Drinking water treatment units Swimming pools, spas and components Plastic piping systems and components Class II biohazard cabinetry Wastewater treatment units Food service equipment Bottled water and packaged ice Gas appliances and accessories Electric appliances and accessories Electrical products Sanitation products Solar energy Plumbing products Manufactured products and recreational vehicle plumbing products Personal protective and safety equipment Automotive lifting devices Building and institutional furniture

The American National Standards Institute (ANSI) and the Registrar Accreditation Board (RAB)established the National Accreditation Program (NAP) for registrars of Quality ManagementSystems to ensure that the marketplace, including buyers, sellers, and public, can rely on thecompetence of ANSI-RAB accredited bodies for their activities related to Quality Management

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Systems. The program also accredits QMS auditor training course providers. Currently there are41 registrars accredited. The program's policies and procedures follow ISO/IEC Guide 61 "General requirements forassessment and accreditation of certification/registration bodies". The Joint Oversight Board(JOB), whose members are appointed equally by ANSI and by RAB, oversees all aspects of theNAP. The JOB has delegated to the QMS Council (the "Council") responsibility for theoperational aspects of ANSI-RAB's QMS accreditation programs and related activities.

The American National Standards Institute (ANSI) and the Registrar Accreditation Board (RAB)established the National Accreditation Program (NAP) for registrars of EnvironmentalManagement Systems to ensure that the marketplace, including buyers, sellers, public agenciesand public interest organizations, can rely on the competence of ANSI-RAB accredited bodiesfor their activities related to Environmental Management Systems. The program also accreditsEMS auditor training course providers. There are currently 19 registrars accredited.

The Joint Oversight Board (JOB), whose members are appointed equally by ANSI and by RAB, oversees all aspects of the NAP. The JOB has delegated to the EMS Council(the "Council") responsibility for the operational aspects of ANSI-RAB's EMSaccreditation programs and related activities.

The final program involves the recognition of a laboratory accreditation program. For many ofthe same national and international considerations leading to ANSI's role in accreditationprograms for certification and registration, the Institute's instructed the Board Committee onConformity Assessment (BCCA) to initiate an effort to bring focus and coordination to the manyU.S. based laboratory accreditation programs. Joining with other interested parties, ANSI is afounding member of the National Cooperation for Laboratory Accreditation. Incorporated in1998, NACLA has as its mission to bring efficiency and economy to laboratory accreditation inthe U.S. ANSI is committed to support this effort.

Gerald Ritterbusch2 May 2000

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10th Construction Equipment Joint Technical MeetingCECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMA

2000 May 22, 232000 May 22, 232000 May 22, 232000 May 22, 23Versailles, FranceVersailles, FranceVersailles, FranceVersailles, France

6.3.1    ISO Standards Adopted as J/ISO:

2860 Minimum Access Dimensions2867 Access Systems3449 FOPS3450 Wheeled Machines Brakes5010 Rubber Tired Machines Steering6393 Acoustics-Measurement of Airborne Noise6394 Measurement of Noise-Operators6395 Acoustics-Measurement of Airborne Noise6396 Measurement of Airborne Noise6483 Dumper Bodies-Volumetric Rating6484 Elevating Scrapers- Volumetric Rating6746/1 Def of Dim & Symbols - Base Machine7132 Dumpers-Terminology & Commercial Specs7133 Tractor Scrapers-Terminology & Commercial Specs7134 Graders-Terminology & Commercial Specs7135 Excavators-Terminology & Commercial Specs7451 Hyd Excav-Volumetric Rating for Hoe Type Buckets7546 Loader Buckets-Volumetric Rating8813 Lift Capacity of Pipelayers9244 Safety Signs & Hazard Pictorials10265 Crawler Machines-Brake System Test10533 Lift Arm Support Device10567 Hyd Excavator-Lift Capacity10570 Articulated Frame Lock11169 Forestry-Wheeled Special Machines11512 Forestry-Performance Criteria for Brake Systems13200 Cranes-Safety Signs and Hazard Pictorials13333 Dump Body & Tilt Cab Support Device

Three SAE standards will be dual designated when 14397 is adoptedISO 3411 is being dual designatedControls document 10968 will be adopted when the revised version is publishedSeat belt 6683 will be adopted when needed additional technical content is addedISO 3457 will be adopted when the revision is publishedISO 5353 will be dual designated with an explanation for SIP with suspension travelISO 7096 will be adopted when a seat damping problem for backhoe loaders is resolvedISO 7130 and 8152 are under consideration for adoption on operator precautions

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In addition to the 28 ISO standards that have been dual designated; forty seven SAEstandards are in the process of being harmonized. Some standards are being reassigned inan effort to provide needed manpower to get the work completed.

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10th Construction Equipment Joint Technical MeetingCECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMA

2000 May 22, 232000 May 22, 232000 May 22, 232000 May 22, 23Versailles, FranceVersailles, FranceVersailles, FranceVersailles, France

6.3.2     SAE Activities - Implementation of USA standards strategy in CE sector

The USA standards strategy is that to have a process whereby USA technology is captured andbrought forward into the ISO standards development process. In order for this process to beeffective, technology experts work under the SAE organizational structure to develop theirinformation into either new work item proposals for the USA Technical Advisory Group for theISO Committee or prepare the needed standards for product under the SAE process. The intendedgoal is to provide the input into the ISO standards development process whenever that can beaccomplished.

The second part of the strategy is to have the right experts organized to review and comment onstandards developed by the ISO Committees such that an eventual standard contain the USAtechnology.

The third part of the strategy is that once an ISO standard has been established, it will be reviewedand as possible approved as a dual-designated SAE/ISO standard for implementation as the USAnational standard. Currently 33 ISO TC 127 standards have been approved as dual-designatedstandards and approximately 50 additional standards are being reviewed. Within the next yearmost of this work will be completed. Only in rare instances will the USA experts find an ISOstandard to be inadequate. The current review process has already identified a number of ISOstandards that need to be improved. This has resulted in a number of new work items beingproposed to update the ISO standards to the latest technology.

Gerald Ritterbusch2 May 2000

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10th Construction Equipment Joint Technical MeetingCECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMACECE, CIMA, EMI and CEMA

2000 May 22, 232000 May 22, 232000 May 22, 232000 May 22, 23Versailles, FranceVersailles, FranceVersailles, FranceVersailles, France

6.4.1.1. Expansion of application of forklift operator training rule

With increasing frequency, manufacturers are being asked questions regarding theapplicability of the newly revised OSHA Powered Industrial Truck Operator Trainingrule (1910.178 and 1926.602) to skid-steer loaders. The forklift requirements went intoeffect last year and require that after December 1, 1999, an employer must providetraining (classroom and field-testing) prior to an employee operating a forklift.

Confusion regarding the applicability of the rule to other products, especially skid steerloaders with pallet forks, has persisted despite very clear language in the rule exemptingequipment intended primarily for agricultural and construction uses.

As a result, EMI sent a letter last December to OSHA seeking to verify that skid steerloaders are exempt from the rule. In our letter we stated:

“Skid steer loaders are designed, built and primarily used to move earth. They are distinctlydifferent machines from powered industrial trucks, which comply with the ASME/ANSI B56series of standards. In fact, skid steer loaders are classified and defined as earthmoving machinesby SAE standards J1057 and J1116.”

On March 9, 2000, EMI received the following positive response:

Question. Does OSHA's Powered Industrial Truck Operator Training standard, §1910.178(1), apply to skidsteer loaders when pallet forks are either attached to or replace the bucket attachment on the loader? Response. Except as noted below, skid-steer loaders as defined by the Society of Automotive Engineers(SAE)J1057 are earth moving machinery and would not be covered under §1910.178(1). The preamble tothe December 1, 1998 Final Rule (Federal Register Volume 63, No. 230) states on page 66255 thatequipment that was designed to move earth but has been modified to accept forks is not covered b this finalrule. However, as you included in your letter, vertical mast skid-steer loaders would be classified as "roughterrain forklifts" as pictured in ASME B56.6 and would therefore be covered under §1910.178.(1).

Thank you for your interest in occupational safety and health. We hope you find this information helpful.Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification,amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future,should you wish to verify that the guidance provided herein remains current, you may consult OSHA'swebsite at http://www.osha/gov. If you have any further questions, please feel free to contact the Office ofGeneral Industry Compliance Assistance at (202)693-1850.

Sincerely,Richard E. Fairfax, DirectorDirectorate of Compliance Programs

D. Drollinger

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2000 May 22, 232000 May 22, 232000 May 22, 232000 May 22, 23Versailles, FranceVersailles, FranceVersailles, FranceVersailles, France

6.4.1.2. Ergonomics rule

The U.S. Occupational Safety and Health Administration (OSHA) published its proposedergonomics rulemaking in the November 1999 Federal Register. There were so manyerrors they published a lengthy amendment in December 1999.

The proposal calls for employers to establish ergonomics programs to prevent work-related musculoskeletal disorders (WMSDs). “Workers who must repeat the same motionthroughout their workday, who must do their work in an awkward position, who must usea great deal of force to perform their jobs, who must repeatedly lift heavy objects or whoface a combination of these risk factors are most likely to develop WMSDs.” Accordingto OSHA, “real solutions” have been demonstrated in workplaces of all sizes across abroad range of industries to reduce these injuries.

OSHA has identified the following critical elements: management leadership andemployee participation, hazard identification and information, job hazard analysis andcontrol, employee training, medical management and program evaluation. The agencyalso intends to include in the rule a grandfather clause for existing programs. Accordingto OSHA, “the keys to success are simple: reduce repeated motions, forceful handexertions, prolonged bending or working above shoulder height. Reduce vibration. Relyon equipment – not backs – for heavy or repetitive lifting. Provide "micro" breaks toallow muscles to recover.”

OSHA is conducting a series of “town hall” meetings on the rule to inform and gathercomments. They are targeting the end of calendar year 2000 to issue the final rule. Seethe OSHA website for more details:             http://www.osha-slc.gov/SLTC/ergonomics/index.html.

Manufacturers argue the rule will be costly and have little benefit:The National Association of Manufacturers (NAM) has conducted a survey of itsmembers and shown that the rule will cost small to medium sized manufacturers $781 peremployee in the first year alone. Despite OSHA’s claim to the contrary, NAM arguesthat the regulation would muddle effective ergonomics programs already in place. Morethan 130 NAM members signed a letter on 20 March urging OSHA to abandon therulemaking. The letter contends that the rule would:• Inappropriately divert resources and attention from other key health and safety

issues• Increase the paperwork burden on companies• Limit the flexibility needed to address employees’ safety and health needs.

See the NAM website for more details: www.nam.org/hrp

D. Drollinger

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2000 May 22, 232000 May 22, 232000 May 22, 232000 May 22, 23Versailles, FranceVersailles, FranceVersailles, FranceVersailles, France

6.4.1.3. Requirements for lifting of personnel

There is little new to report since the last meeting regarding the U.S. Occupational Safetyand Health Administration’s (OSHA) efforts to clarify ambiguous regulations pertainingto fall protection. EMI has authored an article offering guidance and clarifying whatconstitutes fall protection. OHSA initially indicated a willingness to use a similarapproach to clarifying the various subparts of section M in CFR1926.502. However, thelatest information we have received indicates they are rethinking this approach.Nevertheless, there seems to be a lower level of confusion in the industry than there wasa year ago.

Separately, and perhaps of broader significance are new training efforts. Under theANSI/SIA A92 standards (these are voluntary), manufacturers of aerial work platforms(AWP's) are required to provide operational, maintenance and instructional informationwith the equipment, and dealers and employers are required to provide training for AWPoperators. Specifically, the A92.6 -1999 standard language says "Manufacturers shalldevelop and offer training materials that will aid dealers, owners and users in meetingtheir responsibilities as outlined in the standard." The purpose of the standard is to helpprevent accidents that may result from untrained or inadequately trained operators.

To address this situation, certain manufacturers of AWP's being sold in the U.S. havedeveloped and distributed training materials, implemented train-the-trainer programsaimed at dealer and rental company personnel, and in some instances, provide operatortraining.

The Scaffold Industry Association (SIA) and the International Powered AccessFederation (IPAF), a U.K. based non-profit organization have entered into an agreementto create a U.S.-based, not-for-profit company to be known as Aerial Work PlatformTraining, Inc. (AWPT).

AWPT will be authorized by IPAF to market and administer the IPAF model of instructor,demonstrator and operator training, and "certification" or "proof of training" for AWP's,but initially will not include aerial devices (i.e. bucket trucks). The IPAF model,introduced in England in 1993, involves the appointment of certified training centers,which would train to AWPT standards using AWPT supplied materials. Thequalification for training center appointment and the materials used in the training wouldbe adapted from the IPAF materials, with modifications as required to address the U.S.standards and the marketplace. Upon successful completion of the training at theauthorized AWPT center, an AWPT "student" would be issued a "proof of training”certificate or card indicating qualification as a trainer, demonstrator or operator andspecifying the equipment--scissors, boom lift, etc.

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Candidates for training center operators would include AWP manufacturers, AWPdealers, rental companies, unions, training organizations and major users (i.e. airlines,contractors, utilities, etc.). To qualify as a training center operation, the location wouldbe required to have AWPT approved physical facilities, equipment and personnel.Qualification of training centers would include training of instructors to the AWPTstandards and follow-up audits by AWPT staff. The training materials would be genericand address common issues with various classes of equipment. Information and trainingfor specific equipment brands such as operator controls, unique features, etc. would beprovided by a rental company delivery person, distributor representative, etc. as requiredin the "familiarization" section of the recent A92.6 standard.

At the time present time, EMI is considering its level of involvement.

D. Drollinger

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6.4.2.1 MSHA SURFACE HAULAGE RULE

The US Mine Safety and Health Administration (MSHA), in the face of increasingfatality rates in surface mining, particularly in haulage operations, plans to propose a rulewhich would address three specific areas related to surface haulage machines which arebroadly defined to include wheel and crawler loaders and dozers, on and off-road trucks,dumpers, haulers, graders and scrapers. A respective “Advance Notice of ProposedRulemaking” was published in the Federal Register 30 July 98 and addresses in verygeneric terms considerations for future safety requirements for:

1. Operator restraint systems, especially failure to wear: Considering an interlocksystem to ensure that the operator fastens the seat belt and three- or four-pointrestraint systems.

2. Illumination of work site and machine/equipment: Floodlights and possiblyportable work lights on equipment for better visibility behind machine andtires and around a work site at night and on-machine “trouble lights” for pre-operation checks and service. It is unclear whether equipment lighting andmarking is also to be addressed.

3. Blind area visibility (emphasis is truck back-overs) through the use of mirrors,detectors and/or video cameras and monitors on machines.

Current Status:• No changes since our report to the 9th JTL meeting• Industry, Trade Associations and Union provided comments by closing date of

28 September 98.• Proposed rulemaking is in internal MSHA revision process including defining

more specific safety performance requirements.• Second notification to be published for further review and comments by

June/July 99.• Industry can request public hearing along with written comments.• MSHA is aware of the UK HSE demands for “Hazard Detection Systems”, on

certain machines and at dealer/customer level.• MSHA and NIOSH (National Institute of Occupational Safety and Health)

studies are not encouraging as to the acceptance of currently available HazardDetection Systems.

• For accident and regulations details see MSHA web site:http://www.msha.gov/

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6.4.2.2    MSHA Regulations Effective Nov. 25, 1999

The new regulations for mining health and safety are in two parts: engine emissions andmachine design and performance requirements.

To operate new or existing equipment in underground mines after 11/25/99 it is necessaryto comply with this regulation (30 CFR 75.1909). If certain portions of the requirementcan not be met the machine may be continue to be used without receiving MSHAcitations as long as 5/25/00 provided that purchase orders have been written for parts inthe areas of noncompliance.

Engines must be tested for air flow requirements and emissions per the regulation.Approved engines must be labeled, have an adequately sized air filter and an air filterservice indicator .

Other items required that are not equipped on many standard machines include thefollowing:-At least one portable multipurpose dry chemical type (ABC) fire extinguisher listed orapproved by a nationally recognized independent testing laboratory with a 10A:60B:C orhigher rating. It must be located within easy reach of the operator and protected fromdamage.-A fuel vent opening that maintains atmospheric pressure in the tank, and that is designedto prevent fuel from splashing out of the vent opening.-Fuel hoses and tank must not leak.-Fuel tank must be substantially constructed and protected from collision damage.-A self-closing filler cap on the fuel tank.-Fuel hoses, except the fuel fill hose and the return lines on the engine, must be SAE1527 Type A, SAE 1942 or UL 1114 Type A1.-Primary fuel hoses must be located so that leaks do not contact hot surfaces or electricalwiring.-Fuel hoses must be clamped to prevent movement (rubbing).-A manual shutoff valve must be installed in the fuel system as close as practicable to thetank.-A water separator and fuel filter must be provided.-Reflectors or warning lights must be mounted on the machine which can be readily seenin all directions.-Hydraulic hoses must be covered (but not clamped on the lower end) to prevent thespray from ruptured lines from being ignited by contact with exhaust system componentsurfaces.

Additional requirements for non permissible diesel powered machines (those withbuckets) include:

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-Neutral start feature which prevents motion while in neutral.-An audible warning device conveniently located the operator (horn).-Lights on both ends of the machine.-The positive cable from the battery to the starter must be protected against shorting by afuse placed as near as possible to the battery terminal(s).-The electrical system shall be equipped with a circuit-interrupting device by means ofwhich all power conductors can be de-energized.-each ungrounded conductor must have insulation compatible with the impressed voltage(may require insulation on alternator connections).-An automatic fire suppression system.-Supplemental braking system-Parking brake that don't depend on any nonmechanical energy source.-Reflectors or warning lights that can be seen from all directions.-Means to insure that stored energy won't cause articulation after shutdown.

Further details are available on the MSHA website:www.msha.gov/regdata/msha/75.1909htm.

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6.4.2.3     MSHA - Coal surge pile requirements

MSHA has recorded a number of instances where either machines or people have been on top ofa coal pile at a loading or stockpiling location, where a void developed in the pile and eithermachine or personnel have been entombed in the coal void as it collapsed. MSHA in workingwith the West Virginia State Mining Authorities have concluded that additional action iswarranted to alleviate as much as possible the hazards. They believe that a number ofadministrative and training actions on the coal pile site dealing with the design of the feeder andmarking, as well as increasing the glazing strength of the machines in coal surge pile applicationswill reduce the hazards and provide protect for the machine operator in the event that a coalsurge pile void collapses with a machine being sucked into the coal pile.

The glazing design that has been tested consists of 6 mm double thickness of glass with a 1 mmplastic sandwich layer. The intended capacity of this glazing is to achieve a resistance to 40 psiload. This will be a West Virginia requirement once sufficient lead-time is provided to allowmine operators to prepare machines with this configuration either as a retrofit or by acquiringnew machines with this glazing design.

Gerald Ritterbusch2 May 2000

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6.4.3     British Columbia Workers’ Compensation Board Rules

At the 28/29 April 1997 JTL meeting here in Paris, EMI reported on the proposedrevision of the Occupational Health and Safety Regulation – see report 6.5 of thatmeeting.

The were published with an effective date of 15 April 1998. Two sectionsmandate specific requirements for mobile machinery:

Section 16.14 calls for “Supplementary Steering” meeting ISO 5010 or SAE 1511as of April 1999 for rubber tires mobile machines with a travel speed over 20km/h .

Section 16.17 calls for an escape opening meeting ISO 2867 on all mobileequipment with a single door cab and manufactured after 1 January 2000.

On 30 Nov 99, an EMI delegation met with the staff of the BC Workers’Compensation Board to raise concerns with these sections, specifically:

• The lack of accident data supporting the justification forsupplementary steering, and

• The size of escape openings for compact machines unable to meet ISO2867, the max permissible force to open the escape and therequirement that the escape must be openable without tools from theouside.

EMI letter dated 20 December 99, requested to delay the enforcement of bothsections until remediation of these issues can be achieved.

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       6.4.4 California Department of Transportation – Operator Training

The California Department of Transportation’s (CALTRANS) permitting office hasinitiated action to require some type of proof of operator training and licensing forhorizontal directional drilling contractors working on California State right of ways.Proposed effective dates for proof of training of the operator(s) on the basic operation andsafety considerations of the machine is July 1, 2000 and for certification demonstratingthe contractors knowledge and exercise of good drilling practices is January 1, 2001. Theadministration and content of the program is yet to be determined.

Industry groups, including contractor associations and EMI, are working together andwith CALTRANS to structure the process. The path presently being pursued is to rely onthe equipment manufacturer or distributor to provide proof of training on the operation ofa particular machine and to develop 1) an industry wide guideline for good drillingpractices, 2) the contents of a standardized training program, and 3) the testing criteria forcertification of the contractor for good drilling practices.

It is foreseeable that similar requirements for operator/contractor certification couldspread to other states and to other types of equipment.

Stan MullinsCharles Machine Works

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6.4.5. Subsequent Information (after 6th Meeting in 1996) on Asphalt Fumes

Regulatory Status

The U. S. National Institute for Occupational Safety and Health (NIOSH) estimated that over500,000 workers were potentially exposed to asphalt fumes. A variety of health effects areattributed to asphalt fume exposure, including headache, skin rash, fatigue, throat and eyeirritation, and cough.

Studies have reported lung, stomach and skin cancer following exposure to asphalt fumes.However, those studies have been inconclusive and remain so to date.

The U. S. Occupational Safety & Health Administration (OSHA) does not have a standard inplace for asphalt fume exposure, although it proposed a 5 mg/m3 permissible exposure limit eightyears ago. Nonetheless, given that the known and potential health effects are serious, and a largenumber of workers are potentially exposed, OSHA has designated asphalt fume exposure as apriority. OSHA is developing an action plan to reduce worker exposure but is not initiatingregulations at this time.

NIOSH is developing a new Criteria Document for asphalt fumes and expects to makerecommendations on exposure limits within six months.

Guidelines – Engineering Controls for Asphalt FumesOn Large, Self-propelled Hot Mix Asphalt Pavers

These guidelines are the result of a cooperative research effort by manufacturers, users of largehot mix asphalt (HMA) pavers, labor and the U.S. government. That effort was initiated by theNational Asphalt Pavement Association (NAPA) and involved five paver manufacturers.NIOSH assisted the manufacturers with their designs and independently evaluated the equipmentperformance. Following that work, guidelines were drafted, published for public comments, andmodified to the following.

• Scope – applicable to all new HMA pavers weighing 7258 kg. (16,000 lb.) or more andmanufactured after July 1, 1997.

• Each model paver should be tested and certified to meet the capture efficiency (minimumcontrolled indoor capture efficiency of 80%) of the guidelines.

• •

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Page 26.4.5 Asphalt Fumes (continued)

• An indicating device will be installed on each paver so that the system flow rate can bedetermined, the device showing whether the exhaust ventilation system is operating withinthe design range.

• A plate will be attached to the paver showing system schematic and listing field maintenanceprocedures.

Certification of compliance with the NIOSH guidelines is provided to the machine purchaseralong with a system operation and maintenance manual.

Status – Engineering Controls

NIOSH stated its intent to address the application of asphalt fume engineering controls tonon highway-class pavers as well as retrofit of all pavers without these engineering controls at alater date. Those guidelines have not yet been issued.

OSHA has recognized the engineering controls.

Russell HutchisonCIMA

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6.4.6 Transport Canada Motor Vehicle Safety Regulations

The Canadian Motor Vehicle Safety Act (MVSA) was enacted on April 12, 1995 to decrease thenumber of fatalities and increase the general safety of roads. To further clarify the Act, as itapplies to truck and carrier mounted cranes, Road Safety Bulletin ASF-016 (copy attached, datedOct/20/98) was written by Transport Canada. It was received by CIMA on June 3, 1999, inresponse to an inquiry.

Mobile cranes manufactured before 1995, and as described by the old MVSA, were considered awork vehicle and were not subject to Canadian motor vehicle legislative standards. The newdefinition of vehicle, effective with the 1995 Act, requires their regulation and certification.Cranes mounted on off-road type carriers would not require certification under the Act.

The Act establishes regulations for documentation, emissions, labeling, lighting, mirrors, seats,seat belts, and door locks/hinges. Compliance with these issues may be possible by themanufacturers. Noise restrictions and Antilock Braking Systems, however, are major challenges,if they are even technically feasible.

Task force members, made up of representatives of CIMA’s Power Crane & Shovel AssociationCrane Technical Committee and CIMA staff, met with Transport Canada on March 22, 2000.The purpose of the meeting was to provide a venue for the manufacturers and Transport Canadato discuss the issues and voice their concerns. Transport Canada committed verbally that it willnot stop cranes at the border while discussions proceed.

Note: During the course of discussion, Transport Canada representatives stated that these rulesare not limited to mobile cranes, but will apply to all equipment capable of operating onCanadian highways at road speed. That equipment could, for example, include special chassisstreet sweepers, rubber tire mounted excavators, special chassis drills, etc.

In the future, Transport Canada committed to notifying manufacturers of any rulings orlegislation that may effect new equipment sold to Canadian customers.

Russell HutchisonCIMA

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6.5.1 EMI Product Safety Seminar

The EMI Product Safety Seminar is entering its eleventh year as the only industry eventdeveloped by, and specifically for, manufacturers of agricultural, construction, forestry,utility and materials-handling equipment. This two-day seminar utilizes a series ofconcurrent session to provide a wealth of information for anyone from a new employee toseasoned safety expert. The emphasis is on product safety not liability issues.

The seminar incorporates several types of learning environments, from an all-day“Fundamentals of a Product Safety Program” for new engineers (or as a refresher coursefor those with experienced) to a four-hour special focus session on electronic controlsystems to nine two-hour workshops/breakout sessions that provide “hands-on”opportunities to learn about a broad range of safety-related topics.

The tenth annual seminar, held in Minneapolis in October1999 drew a record crowd ofover 200 participants. The eleventh annual EMI Product Safety Seminar is scheduled for23-24 October 2000, in Orlando, Florida. The working title for the 2000 seminar is“Product Safety .... Doing the Right Thing.” Session topics to be included:

General Session

Fundamentals (4-Hour)Salability vs. Defendability ... Process, Policy Procedure

Special Focus• Designing Electronic Control Systems (4-Hour)

Workshops/Breakouts (2 Hours Each)• Emerging Issues• Depositions• Designing for Safety• Effective Leadership• Rental Market Issues/Training• Global Product Liability Considerations• Incident Reporting• Technical Communications• Case Study: Product Evolution (two types of equipment will be evaluated)

D. Drollinger

I:\Technical & Safety\Joint Technical Liaison (CECE, CEMA, CIMA, EMI)\2000 JointTechnical Meeting\PSS Report.doc

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6.5.2 CIMA Product Safety Seminar and Mock Trial

”Increase Safety: Reduce Product Liability II” was the title of this annual two-day conferencepresented in August 1999. The educational sessions were presented to technical and riskmanagement professionals, and enjoyed record attendance. Individual sessions covered topicsfrom hazard analysis and use of safety symbols to operator manual review and update on worksite regulations.

The second day of the conference included presentations of a mock trial based upon an actualproduct liability case, and was presented in conjunction with the Defense Research Institute, alarge trial lawyers professional association.

The conference concluded with a tour of the renowned Milwaukee School of Engineering RapidPrototyping Center.

The conference will again be presented in August 2000 with a full and stimulating two-dayschedule planned. It will open with a presentation on how to set up an effective corporateproduct safety program, move along to safety issues in written and video media, address timelytopics such as noise, ergonomics and the use of laser based construction equipment, and examineeffective communication by manufacturers with product users. Attendees will also learn how tosuccessfully respond to accidents involving their products and how to properly support theirlegal counsel when litigation occurs. It is anticipated that this year’s conference will againexperience record attendance.

Russell HutchisonCIMA

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6.6 Product Rating Guidelines for Hydraulic Breakers

The Hydraulic Breaker Manufacturers representing the worldwide industry had met duringINTERMAT 2000 and discussed the parameters of their updated ”Tool Energy Rating”, whichprovides machinery customers and users with enhanced performance data to make a moreinformed purchasing decision. The Tool Energy Ratings had been developed under the auspicesof the Construction Industry Manufacturers Association (CIMA) and its Mounted BreakerManufacturers Bureau (MBMB).

The “CIMA Measuring Guide for Tool Energy Rating for Hydraulic Breakers” provides auniform method for hydraulic breaker manufacturers to calculate, test and publish comparableperformance data to the equipment specifiers and purchasers of their single blow impact energydeveloped in the hydraulic breakers.

CIMA/MBMB completed a complex development of the “CIMA Measuring Guide” in 1997 thatestablished a reliable voluntary method for rating hydraulic breakers in reducing marketplaceconfusion caused by the use of non-standard rating criteria and test methods. To provide qualityassurance to customers, manufacturers as of July 1999, certify under the CIMA “Tool EnergyRating” program, can publish in company sales and technical literature the equipment test resultsobtained through a self-certification testing process using the CIMA Measuring Guide.

A hydraulic breaker manufacturer must have had successfully completed the test and auditprocess, required by the CIMA/MBMB tool energy program, to be allowed to affix an officialCIMA/MBMB “Manufacturers Certificate” decal to the equipment and display the tool energyrating that was calculated in accordance with the Measuring Guide.

To date all sixteen current MBMB member companies of hydraulic breakers have had theirhammers certified. They can display on their equipment the CIMA/MBMB ManufacturersCertificate and publish their certification on company literature and equipment specifications.

Russell HutchisonCIMA

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6.7 Work Zone Safety Handbook

Road construction work zone safety has become a subject of increased concern to safety officialsthroughout the U. S. due to recent increases in work zone fatalities. This increase is contrary tothe overall experience for workplace fatalities across the U.S. This official concern is furtherheightened because of the scheduled increase in highway repair/replacement in the coming years.

As one means of addressing work zone safety issues in the road building industry, federal, stateand local agencies along with interested associations have developed rugged, information packedpocket sized handbooks setting forth guidelines for work zone traffic control which supplementsbasic work zone safety training. The handbooks are based upon the standards for work zonesafety, and are intended to illustrate safety principles. The handbook itself is not a standard.Samples of the pocket handbook will be available at the Joint Technical Meeting.

Russell HutchisonCIMA

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6.8 Status of OSHA Rule Change for ROPS on Roller/Compactors

The U.S. Occupational Safety and Health Administration (OSHA) regulations on therequirement of roll over protective structure (ROPS) for rollers and compactors remainsunchanged. Current regulations do not specifically require ROPS on roller/compactors.

Note: Every major manufacturer or roller/compactors based in the U.S., as well as those foreignmanufacturers who are members of CIMA’s Bituminous and Aggregate Equipment Bureau(BAEB) are installing ROPS on their products.

CIMA has maintained an open dialogue with officials in OSHA’s Construction Directorate onbehalf of its BAEB members, who continue to urge OSHA to formally adopt a regulatoryrequirement for ROPS on roller/compactors. OSHA personnel are receptive to the change, butfor political or bureaucratic reasons the change has not received the priority that many believe itdeserves. CIMA will continue to maintain pressure on the Construction Directorate officials andwork with them in every way possible to advance this safety issue.

Russell HutchisonCIMA

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6.9. California Proposition 65 requirement for lead-acid batteries

A California law, commonly known as Proposition 65, will now apply to lead-acidbattery and battery related accessory manufacturers, distributors, retailers and OEMvehicle manufacturers and dealers doing business in California. Simply stated the lawrequires, among other things, that consumers (and workers) in California be warned if aproduct contains material that could present certain health risks. Penalties have beenlevied against violators of this law. Much of the information in this report came from aletter by East Penn Manufacturing (a battery manufacturer).

Several months ago, several lead-acid battery manufacturers, distributors and retailersof lead-acid batteries and battery related accessories, and manufacturers of vehicles andequipment that contain lead-acid batteries were sued under California Proposition 65for allegedly failing to warn consumers about the "hazards" of lead.

A group of lead-acid battery manufacturers entered into an agreement to settle this suitto avoid expensive and protracted litigation. The agreement includes the payment offines, penalties and legal fees. According to the settlement reached, others can beprotected under this agreement. The settlement cites a deadline date of 15 May date andlists the following requirements:

l. Nothing in the Consent Judgment is an admission of any wrongdoing by any party.

2. The agreement covers lead-acid batteries and battery accessories that contain lead.This includes all types of lead-acid batteries used in cars, trucks, UPS, telecom andsimilar standby power and other industrial applications.

3. The agreement also covers anything that uses lead acid batteries such as cars, trucks,motorcycles, watercraft, RVs, golf cars, forklift trucks, aerial lifts, floor scrubbers, etc.

4. In the case of new vehicles & equipment (cars, trucks, boats, motorcycles, HDequipment, lift trucks, etc.) sold in California, the agreement requires that specificwarning messages appear in the vehicle's owner's manual or an insert in the literaturethat is given to the buyer, to satisfy the requirements of Prop 65 and be released fromliability:

Or

Thebattery warning is in addition to the Proposition 65 warnings about engine emissions.

D. Drollinger

WARNING: Battery posts, terminals and related accessories contain lead andlead compounds. Wash hands after handling.

WARNING: Battery posts, terminals and related accessories contain lead andlead compounds, chemicals known to the State of California to cause cancerand birth defects or other reproductive harm. Wash hands after handling.