Filling Your 2012 Conference Calendar 

Three of the year's big trade shows take place in Denver, Indianapolis, and Orlando. It's not too early to make plans or to register for some of them and for other must-attend events.

So many of the best U.S. safety and health conferences of 2012 are packed into June and October. April also will be busy. It's not too early to make plans and reservations for some of them; registration is already available for the AIHA and ASSE meetings.

AIHA's, the 2012 American Occupational Health Conference & Expo, is taking place after ASSE's Safety 2012 - apparently a first. New wrinkles introduced at this event include the Ignite sessions from 2-5 p.m. on June 19. These are five-minute presentations for which AIHA is still taking suggestions. AIHce also is debuting a mobile app at this event, and there are IH Mysteries Workshops set for June 18 and June 19.

"All kinds of ideas work," according to AIHA's description of the Ignite sessions. "A wide range of topics and concepts can be incorporated into an Ignite talk. These are not 20 minute technical abstract presentations that follow the scientific approach. They are quite the opposite, in fact. Presenters get creative and share their professional and/or personal passions, causes, or meaningful moments. Sometimes an Ignite talk can be a blend of both personal and professional. Essentially – Ignite talks are a story and everyone has stories to tell."

Ignite session speakers will "share their professional and personal passions using 20 slides that auto advance every 15 seconds," according to AIHA. To present one, contact Carol Tobin at ctobin@aiha.org or 703-846-0745.

Registration will open in May 2012 for this year's National Safety Congress & Expo, which will take place Oct. 21-26 in Orlando as the host National Safety Council celebrates its centennial. For the second year in a row, a panel of experts from the International Safety Equipment Association will discuss hot topics in the world of PPE during a 2-3:30 p.m. session Nov. 1 in the exhibit hall. Two Executive Edge workshops and a related panel discussion are new additions to the Congress program this year.

Health conferences are leading off the year. "Business Dimensions of Occupational Nursing" is the theme for the American Association of Occupational Health Nurses Inc.'s 2012 national conference, which takes place April 22-25 at the Gaylord Opryland Resort in Nashville.

Not far behind the NSC, the American College of Occupational and Environmental Medicine, ACOEM, is nearing its centennial year. ACOEM was founded in 1916 and will open its 97th Annual Meeting, the 2012 American Occupational Health Conference, on April 29 in Los Angeles. The event's theme is "Scripting Worker and Environmental Health: Spotlighting What You Need to Know."

Another important public health meeting is set for Oct. 27-31 at San Francisco's Moscone Center. It's the 140th Annual Meeting & Exposition of the American Public Health Association, with more than 13,000 health professionals expected to attend.

The 56th Annual Meeting of the Human Factors and Ergonomics Society (HFES) and the NSC Congress are two highlights occurring simultaneously in October. The following month, this year's National Ergonomics Conference and Expo returns to Caesar's Palace in Las Vegas (Nov. 27-30).

Here's the list in brief:

• AAOHN 2012 national conference: April 22-25, Gaylord Opryland Resort, Nashville, www.aaohn.org
• American Occupational Health Conference: April 29-May 2, Hyatt Regency Century Plaza, Los Angeles,www.acoem.org
• ASSE's Safety 2012: June 3-5, Colorado Convention Center, Denver, www.safety2012.org
• NFPA 2012 Conference & Expo: June 11-14, Mandalay Bay Convention Center, Las Vegas, www.nfpa.org
• AIHce 2012: June 16-21, Indiana Convention Center, Indianapolis, http://aihce2012.org/
• NSC 2012 Safety Congress & Expo: Oct. 21-26, Orange County Convention Center, Orlando, www.nsc.org
• HFES 56th Annual Meeting: Oct. 22-26, Westin Boston Waterfront, Boston, www.hfes.org
• APHA 140th Annual Meeting & Exposition: Oct. 27-31, Moscone Center, San Francisco, www.apha.org
• National Ergonomics Conference and Expo: Nov. 27-30, Caesar’s Palace, Las Vegas, www.ergoexpo.com

Exercise Regime Constitutes Medical Treatment for OSHA Recordability 

Following its recent interpretation that "therapeutic exercise" constitutes medical treatment for OSHA recordability purposes, OSHA has now stated that an exercise regime recommended by a Certified Athletic Trainer for an employee who exhibits any signs or symptoms of a work-related injury involves medical treatment and is a recordable case. OSHA made this interpretation in a letter recently posted on its website.

In the same letter, OSHA also provided guidance on whether specific types of exercise constitutes medical treatment. OSHA states that if a Certified Athletic Trainer "utilizes stretching" to relieve symptoms of a work-related injury or illness, the "stretching" constitutes medical treatment. OSHA also states that a written home exercise program provided by a Certified Athletic Trainer for signs or symptoms of a work-related injury or illness constitutes medical treatment for recordkeeping purposes.

OSHA's interpretation is particularly important for musculoskeletal disorders (MSDs), as MSDs are often managed, in part, through exercise regimes. OSHA does note in the letter that exercise given as a purely precautionary measure (i.e., before the onsite of signs or symptoms) would not qualify for recordability. However, if an employee experiences any signs or symptoms of a work-related injury or illness - even very early signs or symptoms - exercise given to manage those signs or symptoms would constitute medical treatment for recordability purposes.

Employers should take note of this new interpretation and adjust their recordkeeping practices accordingly.

OSHA Issues Alert on Engulfment and Suffocation Hazards in Grain Storage Bins 

OSHA issued a Hazard Alert about the deadly dangers to workers of engulfment and suffocation while working inside grain storage bins. Grain bins are used to store bulk raw agricultural commodities such as corn, wheat and oats. Workers who enter bins can be engulfed and suffocated if they stand on moving or flowing grain, which can act like "quicksand" and pull a worker under; if they stand on or below "bridged" grain, which can collapse and bury workers; or if they try to loosen grain, which can cave in on workers.

The Hazard Alert describes how workers may become engulfed in grain bins and lists the precautions that employers must take under OSHA's Grain Handling Facility standard to protect workers. These include disconnecting equipment that presents a danger; prohibiting workers from walking on the grain to make it flow; providing workers with personal protective and rescue equipment; and requiring an observer outside the bin who can perform rescue operations. A fact sheet and wallet-sized card on preventing grain bin suffocations are also available from OSHA's Publications Web page.

A center grain unloading auger draws grain from the top center and the grain forms a cone as the bin is emptied. (Illustration: John A. Kramer, Safety Measures in Handling Stored Grain, Kansas State University.)

Grain Elevator Company Pleads Guilty in Teen Worker's Death 

Tempel Grain Elevators LLP pled guilty August 5 to violating OSHA regulations resulting in the death of 17-year-old Cody Rigsby, who suffocated after being engulfed in a grain bin in Haswell, Colo. The company was also sentenced to five years probation. Under a plea agreement with prosecutors, the company must pay Rigsby's family $500,000 for his 2009 death and must pay fines to OSHA. The company must also implement safety provisions that include providing safety training and refresher training to its employees, and developing a procedure that includes harnesses and lanyards or similar safety equipment in anticipation of bin entry at any of its grain elevators. If Tempel Grain violates any of the terms or conditions of probation they would be potentially liable for up to another $500,000 fine.

"This is a terrible tragedy that should never have happened," said OSHA Assistant Secretary David Michaels. "We are pleased to reach this agreement. Money won't bring back this young man's life, but we can make every effort to ensure that these terrible tragedies don't happen again. We will use any means - from tough enforcement to aggressive outreach efforts - to put this industry on notice that we will not tolerate risking workers lives in hazardous situations that are entirely preventable."

For more information see the news release: http://www.justice.gov/usao/co/press_releases/2011/August2011/8_5_11.html

OSHA May Regulate Tandem Container Lifts 

A federal court has ruled the Occupational Safety and Health Administration (OSHA) may regulate so-called "vertical tandem lifts" (VTLs) of containers or flat racks, where more than one container or flat rack is lifted at a time. But in a decision handed down earlier this month, the U.S. Court of Appeals for the District of Columbia Circuit agreed with the National Maritime Safety Association (NMSA) that some of the OSHA rules on vertical tandem lifts were not feasible. NMSA members include trade organizations such as the Pacific Maritime Association, United States Maritime Alliance and New York Shipping Association which negotiate contracts with dockworker unions in the United States and Canada. The court turned back some of NMSA’s more general challenges to the OSHA regulations, saying the government had established there is a significant risk to tandem lifts.

OSHA has estimated tandem lifts have been performed probably 1 million times since 1986 without any injury occurring, but it has also found evidence of at least nine incidents when containers have separated during vertical tandem lifts in the past 15 years. There was also testimony from longshoremen and container manufacturers that connectors between the corner castings of containers, when lifted in tandem, "can frequently detach or not attach in the first place."

While the court denied the NMSA petition for a review of the rule regulating VTLs, it agreed with NMSA that some aspects of the OSHA regulation were not feasible, and remanded them to OSHA. These include a requirement to inspect the connections between containers that are going to be lifted in tandem from a ship to shore. While the court said inspecting such connections when moving boxes from a terminal to the ship was feasible, doing so in the other direction was not. The association argued it would not be safe to require employees to inspect containers that are "in a stack between other containers sitting 80 feet above the ship's deck and twice that distance above the water and dock," potentially exposing longshoremen to the hazard of falling.

The court also found there was not substantial evidence to support OSHA’s feasibility determination with regard to its total ban on vertical tandem lifts of flat racks or platform containers. NMSA argued that the total ban on vertical tandem lifts of platform containers can make it unfeasible to unload cargo from a ship because platform containers are often stacked and interconnected overseas and therefore cannot always be separated or chained together before lifting. "If that occurs, a domestic marine terminal operator must either lift the platform containers as a unit-and thus violate the standard - or leave the containers - and any containers beneath them - onboard," the court noted. It also noted that when the rule was proposed by OSHA, it would have allowed the movement of empty platform containers with their end panels folded, so companies or organizations commenting on the regulation had no notice of the standard's total ban and therefore did not address the infeasibility of the ban. Without a record of whether the rule was feasible, the court said it could not conclude that substantial evidence supports OSHA's feasibility determination.

The court rejected an argument by NMSA that since terminals establish a safe work zone around container operations, employees will not face any additional danger from tandem lifts. But the court said "while the safe work zone requirement adequately protects employees located on the ground, it does not necessarily protect the crane operator who moves the containers. If a container were to separate during a VTL, the separation could jar the crane and injure the operator."

OSHA Proposed Rule Changes Reporting Timeframes for Fatalities, Amputations and In-Patient Hospitalizations 

The new proposed reporting requirements revised OSHA's current regulation that requires an employer to report to OSHA, within eight hours, all work-related fatalities and in-patient hospitalizations of three or more employees. (Under the revised proposal, employers would be required to report to OSHA any work-related fatalities and all in-patient hospitalizations within eight hours, and work-related amputations within 24 hours. Reporting amputations is not required under the current regulation).

Other observations from the proposed rule include:

• OSHA estimates that the additional reporting burden to be an average of only 15 minutes per reported incident.
• In-patient hospitalization is defined as when a person is "formally admitted" to a hospital or clinic for at least one overnight stay.
• The proposed reporting requirements would apply only to work-related deaths, in-patient hospitalizations, and amputations occurring within 30 days of a work-related incident.
• A reportable amputation under the proposed rule would include those that occur at the workplace as well as those that occur in a hospital as a result of a work-related event.

Comments are due on September 20, 2011.

OSHA updated its Recordkeeping Web page to include answers to frequently asked questions regarding the proposed rule. A link to the proposed rule itself also is available on the page.

OSHA Final Rule Affects Shipyard Employment Standards 

OSHA has issued a final rule (http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=22094) aimed at streamlining and simplifying various standards, including those affecting the shipbuilding and repair industry. This effort was directed by President Obama's initiative and Executive Memo on reducing employer regulatory burdens and a periodic Agency review.

The new rule will result in several changes affecting 1915, Safety & Health Standards for Shipbuilding. The relevant excerpts from the Final Rule are below:

• In subpart I, OSHA is deleting requirements that employers prepare and maintain written training certification records. OSHA does not believe that the training certification records required by the four standards provide a safety or health benefit to employees, nor are the burden hours and cost to employers justified. These standards are the general industry Personal Protective Equipment (PPE) standard (Sec. 1910.132); the shipyard employment PPE standard (Sec.1915.152); and the general industry and construction Cadmium standards (Sec. Sec. 1910.1027 and 1926.1127).
• There are seven revisions to the Respiratory Protection standard at Sec.1910.134. One revision clarifies which breathing-gas containers employers must provide pursuant to the standard (Sec. 1910.134(i)(9)). To provide additional clarification, OSHA is revising language in Appendix C of Sec. 1910.134, and updating the language of the DOT regulations referenced in Sec. 1910.134(i)(4)(i). OSHA also deleted duplicative and inconsistent statements in Appendix D of Sec. 1910.134, and also in the Asbestos standard for shipyards (Sec.1915.1001).
• OSHA is updating its standards regulating slings for general industry (Sec. 1910.184); shipyard employment (Sec. Sec. 1915.112,1915.113, and 1915.118), and construction (Sec. 1926.251). Modifications to these standards include removing previous load- capacity tables (Sec. 1910.184, tables N-184-1, N-184-3 through N-184- 22; and G-1 through G-5, G-7, G-8, and G-10) and references to these tables (Sec. 1915.112; Sec. 1915.113; and Sec. 1926.251; tables H-1 and H-3 through H-19). Employers now must use slings with permanently affixed identification markings that depict the maximum load capacity. The final rule provides similar protection for shackles in Sec. Sec.1915.113 and 1926.251.

No-Defects Filing for Intermodal Equipment to End 

The Federal Motor Carrier Safety Administration's change means that drivers returning cargo containers to the equipment provider won't have to file a written report if they found no defects in that equipment.

A simple rule change, at least in the context of federal rulemaking, will eliminate the requirement that drivers must file a written report when they return cargo containers to the equipment provider, even if they found nothing wrong with the equipment. The Federal Motor Carrier Safety Administration has published a proposal to change that so a written report won't be required if the driver found no defects.

The requirement dates to 2006; the Ocean Carrier Equipment Management Association and the Institute of International Container jointly petitioned for this change in March 2010. They said 96 percent of all submitted reports would show no defects, and the estimated 38,491,440 no-defect reports per year might overwhelm 1,603,810 reports with defects -- along with costing about $770,000 to retrieve U.S. DOT numbers for the equipment that has no defects. Assuming truck drivers take three minutes to fill out each report, they also estimated drivers lose 1,924,572 hours annually completing reports of no defects. (Their numbers were based on a sampling of industry data from 2007-2009.)

FMCSA granted the petition on July 30, 2010; the compliance date for the final rule was extended to June 30, 2011.

FMCSA's change will put this provision into place:

Sec. 396.12, Procedures for intermodal equipment providers to accept reports required by Sec. 390.42 (b) of this chapter.

• (b)(4) All damage, defects, or deficiencies of the intermodal equipment must be reported to the equipment provider by the motor carrier or its driver. If no defect or deficiency in the intermodal equipment is discovered by or reported to the driver, no written report is required.

New Injury and Illness Prevention Programs Webpage 

OSHA has a new Injury and Illness Prevention Programs webpage to provide easy to use, informative and useful guidance on how to implement an effective system for finding and fixing workplace safety and health hazards. Injury and Illness Prevention Programs, known by a variety of names, are universal interventions that can substantially reduce the number and severity of workplace injuries and alleviate the associated financial burdens on U.S. workplaces.

Webpage features include:

• A list of OSHA documents that require or recommend safety and health programs.
• Examples of effective Injury and Illness Prevention Programs.
• Resources available for building Injury and Illness Prevention Programs.

Water, Rest and Shade: Protecting Workers from Heat-Related Illness 

OSHA has initiated a national outreach campaign to educate workers and their employers about the hazards of working outdoors in the heat. OSHA is leveraging relationships with other state and local partners, employers, trade organizations, unions, community groups, educational institutions and healthcare professionals to disseminate training materials across the country with a very simple message: "water, rest and shade."

OSHA's new Heat Illness Campaign Web page provides educational materials in English and Spanish, as well as a curriculum to be used for workplace training. Multiple copies of publications can be ordered from OSHA's Web site.

Additionally, OSHA is partnering with the National Oceanic and Atmospheric Administration on weather service alerts that will incorporate worker safety precautions when heat alerts are issued across the United States. NOAA is also including pertinent worker safety information on its Heat Watch Web page.

OSHA Recordkeeping Advisor 

The U.S. Department of Labor has issued the OSHA Recordkeeping Advisor (http://www.dol.gov/elaws/OSHARecordkeeping.htm), a new Web tool to help employers understand their responsibilities to report and record work-related injuries and illnesses.

The OSHA Recordkeeping Advisor helps employers quickly determine whether an injury or illness is work-related, whether a work-related injury or illness needs to be recorded, and which provisions of the regulations apply when recording a work-related injury or illness. The Advisor is written in plain language to help employers, especially small business employers, understand OSHA’s recordkeeping requirements.

The Advisor is not, however, a substitute for compliance with the OSHA's recordkeeping regulations. For more information, see OSHA's Recordkeeping Web page.

OSHA Administrative Penalty Information Bulletin 

OSHA is implementing several changes to its administrative penalty calculation system. Many of the agency's current penalty adjustment factors have been in place since the early 1970's, resulting in penalties which are often too low to have an adequate deterrent effect. Administrative penalty adjustments will therefore be made to several factors which impact the final penalty issued to employers. These factors include:

1. History Reduction
2. History Increase
3. Repeat Violations
4. Severe Violator Enforcement Program
5. Gravity-Based Penalty (GBP)
6. Size Reduction
7. Good Faith
8. Minimum Penalties
9. Additional Administrative Modifications to the Penalty Calculation Policy

A brief description of each penalty adjustment factor and planned changes are provided below:

1. History Reduction

The time frame for considering an employer's history of violations will expand from three years to five. An employer who has been inspected by OSHA within the previous five years and has not been issued any serious, willful, repeat, or failure-to-abate citations will receive a 10 percent reduction for history.

2. History Increase

An employer that has been cited by OSHA for any high gravity serious, willful, repeat, or failure-to-abate violation within the previous five years will receive a 10 percent increase in their penalty, up to the statutory maximum. Employers who have not been inspected and those who have received citations for serious violations that were not high gravity will receive neither a reduction nor an increase for history.

3. Repeat Violations

The time period for considering the classification of repeated violations will be increased from three to five years.

4. Severe Violator Enforcement Program

Where circumstances warrant, at the discretion of the Area Director, high gravity serious violations related to standards and hazards identified in the SVEP will not normally be grouped or combined, and may be cited as separate violations, with individual proposed penalties.

5. Gravity-Based Penalty (GBP)

The gravity of a violation is the primary consideration in calculating penalties and is established by assessing the severity of the injury/illness which could result from a hazard and the probability that an injury or illness could occur. OSHA is adopting a gravity-based penalty structure for serious citations which will range from $3,000 to $7,000.

6. Size Reduction

OSHA will be amending its penalty reduction structure based on the size of employers, allowing for a penalty reduction between 10 and 40 percent for those with less than 250 employees. No size reduction will be applied for employers with 251 or more employees.

7. Good Faith

The current good faith procedures in the Field Operations Manual will be retained. A penalty reduction is permitted in recognition of an employer's effort to implement an effective workplace safety and health program. Employers must have a safety and health program in place to get any good faith reduction. Good faith reductions are not allowed in the cases of high gravity serious, willful, repeat, or failure-to-abate violations.

The 15% Quick-Fix reduction, which is currently allowed as an abatement incentive program to encourage employers to immediately abate hazards identified during inspections, remains unchanged. However, the 10% reduction for employers with a strategic partnership agreement will be eliminated.

8. Minimum Penalties

The minimum proposed penalty for a serious violation will be increased to $500. When the proposed penalty for a serious violation would amount to less than $500, a $500 penalty will be proposed for that violation. The proposed minimum penalty for a posting violation will increase to $250 if the company was previously provided a poster by OSHA.

The current maximum penalty for a serious violation, one capable of causing death or serious physical harm, is only $7,000 and the maximum penalty for a willful violation is $70,000. The average penalty for a serious violation will increase from about $1,000 to an average $3,000 to $4,000. Monetary penalties for violations of the OSH Act have been increased only once in 40 years despite inflation. The Protecting America's Workers Act would raise these penalties, for the first time since 1990, to 12,000 and $250,000, respectively. Future penalty increases would also be tied to inflation. In the meantime, OSHA will focus on outreach in preparation of implementing this new penalty policy. For more information on the penalty policy, visit http://www.osha.gov/dep/administrative-penalty.html.

9. Additional Administrative Modifications to the Penalty Calculation Policy

Final penalties will be calculated serially, unlike the current practice where all penalty reductions are added and the total percentage of reductions is then multiplied by the gravity-based penalty to arrive at the proposed penalty. All penalty adjustment factors will be applied serially.

These changes will establish general agency policy and do not preclude the agency from assessing a different penalty, where appropriate under the Act, in light of all circumstances in a particular case.

Table 6-1: Maximum Amounts for Civil Penalties

Table 6-2: Serious Violations

Table 6-3: Other-Than-Serious Violations

OSHA Inspectors Get New Field Manual: Severe Violator, Maritime Sections Added 

The latest version of the Field Operations Manual, used by Occupational Safety and Health Administration inspectors, which has recently been released, incorporates changes related to the maritime industry and provides information on the Severe Violators Enforcement Program, the agency said.

The 380-page handbook sets out inspection procedures and priorities, how to determine penalties and the conduct of post-inspection activities such as conferences with cited employers.

This latest Field Operations Manual (CPL 02-00-150) took effect April 22 and replaces the previous manual (CPL 02-00-148) in use since November 2009, the first issued after the Obama administration took office (39 OSHR 280, 4/9/09).

The new manual does not alter OSHA regulations or penalties, agency spokesman Enrique Chaurand told BNA May 3. Instead, the changes integrate new programs into the manual, such as the Severe Violator Enforcement Program, and consolidate information that had been scattered across sections of the old manual.

There are three major changes in the new edition:

• A 33-page "maritime industry" section was added, outlining the rules and laws OSHA enforces in a wide range of marine functions from ship construction to handling cargo. The section also delineates where OSHA's authority ends and inspections by the Coast Guard and other agencies begin. The previous manual covered maritime inspections, but the information was spread among several chapters. The aim is to help inspectors by consolidating regulations and references, Chaurand said. The section "does not change enforcement or conduct of OSHA inspections."
• The manual includes new information on the Severe Violator Enforcement Program, with notes throughout the manual on when to use SVEP and how the program replaces the Enhanced Enforcement Program. Chaurand said the revision was "purely an administrative change" and does not alter SVEP itself.
• A new chapter covering OSHA's regulation of federal workplaces is presented. The 39-page addition details how OSHA should work with federal agencies and processes that are different from dealing with private industries. "The chapter explains that besides not having financial penalties for federal agencies, OSHA also has different procedures for how a federal agency may appeal an OSHA violation," Chaurand said. As part of the update, the manual canceled the 1996 OSHA instruction for inspecting federal workplaces, Federal Agency Safety and Health Programs (FAP 01-00-003).

By Bruce Rolfsen

The new Field Operations Manual is available at: http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-150.pdf

Final Subpart F Rule: General Working Conditions in Shipyard Employment 

OSHA published the final Subpart F Rule: General Working Conditions in Shipyard Employment. The rule becomes effective and enforceable on August 1, 2011, except for the provisions in § 1915.89 (Lockout/Tagout), which become effective and enforceable on October 31, 2011.

Find the new rule here: http://edocket.access.gpo.gov/2011/pdf/2011-9567.pdf

OSHA has released a list of frequently asked questions on the newly released Subpart F. While this is not an extensive list it may provide some information as we review and implement the new standard.

Find the FAQs here: http://www.osha.gov/dts/maritime/standards/general_working_conditions_faqs.html

New Safety Guide for Rigging 

OSHA has released a new safety guide for rigging. The "Safety and Health Injury Prevention Sheets" - or SHIPS for short - includes written guidance, analysis of fatal accidents, illustrations, video animations of dangerous situations, and posters. The guide goes beyond connecting cables or ropes to loads and addresses falls, avoiding electrical shocks, and where to not stand when working near heavy equipment such cranes and hoists.

http://www.osha.gov/dts/maritime/sltc/ships/rigging/index.html

Stainless Steel Scrap (Sintered Cake) 

The file contains photos below of an incident at the port of Montreal involving a product described as "stainless steel scrap (sintered cake)". This material is normally not regulated as dangerous goods. However, under certain conditions it may be subject to an exothermic reaction, i.e. self-heating, resulting in the evolution of extreme heat, fire and/or smoldering.

Stainless Steel Scrap (Sintered Cake)

National Maritime Safety Association Safety Videos 

To access the National Maritime Safety Association Safety Videos:

1. Go the National Maritime Safety Association website (http://www.nmsa.us/).
2. Click "Information" on the main menu.
3. Click "Safety Videos" on the Information submenu.

Fire Extinguisher Failure 

Learn the results of an investigation about fire extinguisher failures on mobile equipment and what you can do to prevent them.

Fire Extinguisher Failure

Whistleblowers.gov Offers Quick Worker Access to Whistleblower Protection Information 

Workers who "blow the whistle" on prohibited or unlawful practices in the workplace as well as safety and health discrimination play an important role in assuring compliance with federal laws. Today, OSHA unveils a dedicated Web address for its whistleblower protection program - www.whistleblowers.gov. The site is designed to provide workers, employers, and the public with easily accessible information about the 18 federal whistleblower protection statutes that OSHA currently administers.

The Web page will provide information about worker rights and provisions under each of the whistleblower statutes and regulations that OSHA enforces. Additionally, program fact sheets and information are available that discuss how one can file a retaliation complaint with OSHA. This Web page will continue to be accessible through OSHA's Web site, www.osha.gov, by clicking on the "Whistleblower Protection" link.

Under Section 11(c) of the Occupational Safety and Health Act (the OSH Act), workers may file discrimination complaints with OSHA if they believe their employer has retaliated against them for exercising a broad range of rights protected by the OSH Act. These rights include filing safety or health complaints with OSHA and seeking an OSHA inspection, participating in an OSHA inspection, participating or testifying in any proceeding related to occupational safety or health, or reporting an injury or illness to their employer.

"OSHA doesn't work unless workers feel secure in exercising their rights," said Assistant Secretary of Labor for OSHA David Michaels. "This Web page is part of OSHA's promise to stand by those workers who have the courage to come forward when they know their employer is cutting corners on safety and health."

Workers may also file whistleblower complaints with OSHA if they believe their employer has retaliated against them for engaging in protected activities related to air carrier safety, asbestos in schools, commercial motor carrier safety or security, corporate fraud, environmental, nuclear safety, pipeline safety, public transportation agency, rail safety or security, and several other statutes. For each of the statutes covered by OSHA, the Web page will provide workers with information on timeframes for filing, the complaint investigation process, case settlement, reinstatement, pay back wages, restoration of benefits, and other possible remedies to ensure justice for the worker.

Fall Protection Anchorage Using Water 

ecoAnchor Brochure

OSHA QuickCards Focus on Safety in Marine Cargo Handling Operations 

The Occupational Safety and Health Administration recently developed three QuickCards addressing worker safety topics in marine cargo handling operations.

Gangway Safety in Marine Cargo Handling lists safety requirements for preventing falls from gangways, the walkways used for boarding and departing vessels. First Aid in Marine Cargo Handling explains workplace requirements such as assuring at least one person with a valid first-aid certificate is available at the terminal to provide medical assistance. Additionally, Lifesaving Facilities in Marine Cargo Handling lists safety requirements for lifesaving equipment such as personal flotation devices and stokes basket stretchers, among other equipment.

"Too many workers are getting injured on the job," said Assistant Secretary of Labor for OSHA David Michaels. "OSHA is providing these QuickCards to ensure that employers and workers know the best way to prevent workplace injuries. These educational fact sheets are part of OSHA's ongoing goal of promoting prevention through education."

Industry operations covered in these Quick Cards include the transfer of cargo between ships, trucks, pipelines and other modes of transportation, and the operation and maintenance of piers, docks and associated buildings and facilities.

QuickCards are pocket-sized, laminated cards developed by OSHA to provide brief, plain language safety and health information for workers.

Waterfront and Container Safety Guidelines 

The following general guidelines are distributed by Australia for the ISN World program:

• Working Safely on the Waterfront
• Working Safely on the Waterfront - Checklist
• Working Safely with Containers
• Working Safely with Containers - Checklist
• Working Safely with General Cargo - Steel Products
• Working Safely with General Cargo - Steel Products - Checklist

Recordkeeping is focus of new National Emphasis Program  

OSHA launched a National Emphasis Program on recordkeeping to determine the accuracy of injury and illness data recorded by employers. The NEP involves inspecting occupational injury and illness records prepared by businesses and enforcing regulatory requirements when employers are found to be under-recording injuries and illnesses. See the directive for more information.

The Directive Number 09-08 (CPL 02) can be found
here: http://www.osha.gov/OshDoc/Directive_pdf/CPL_02_09-08.pdf
or download: Injury and Illness Recordkeeping National Emphasis Program (RK NEP)

USFA Releases Report on Maritime Preparedness  

A new U.S. Fire Administration report offers several recommendations to improve fire department preparedness for incidents in maritime areas.

Released August 20 as part of USFA's ongoing Technical Report Series, the report (.pdf file) examined the waterway preparedness and response planning of three major port cities, identified common experiences found in each, and highlighted the issues and risks that exist in smaller venues.

USFA recommends:

• Port communities ensure emergency plans adequately address disaster response protocols for a wide range of scenarios, and consider forming a task force with various agencies on the local, state and federal levels.
• Develop a written formal agreement defining roles, responsibilities, finances and command for each entity in the consortium.
• Perform drills and exercises on a regular basis.

New Federal Flu Guidelines Out for Employers  

Three cabinet secretaries, including HHS' Kathleen Sebelius, today urged businesses to plan for absences, encourage employees to be vaccinated, and ensure critical operations are not interrupted.

Three secretaries of federal cabinet departments, HHS' Kathleen Sebelius, Commerce's Gary Locke, and DHS's Janet Napolitano, announced the release of new federal pandemic flu guidelines for businesses today and urged employers to prepare without delay. "The health care system very likely will be stress during this year's flu season," Locke said, adding that companies should be planning now for continuity of operations with a depleted workforce, including cross-training and making preparations for telecommuting, taking steps to reduce face-to-face meetings, and possibly reducing travel.

Sebelius mentioned the H1N1 vaccines now in development should be available beginning around Oct. 15. She asked employers to focus on hands and home - hand cleanliness, in the first instance, and also going home or staying home if you exhibit flu-like symptoms. All three secretaries noted seasonal flu is also a concern this fall, and they urged employers to encourage their workers to be vaccinated.

Sebelius listed five H1N1 "target population groups" for whom vaccination is particularly important: adults with underlying medical conditions, pregnant women, young people up to age 24, health care workers, and parents and guardians of infants.

"Protection from the flu is a shared responsibility," Napolitano said. "From a business perspective, planning is essential. Think through this: It's not just seasonal flu. We are proactive at the [federal government] level where we are at, but we're asking the business community to be proactive, too."

Guidance Document Focuses on Combustible Dust Hazards  

OSHA published a new document titled "Hazard Communication Guidance for Combustible Dusts" that helps chemical manufacturers and importers recognize the potential for dust explosions, identify appropriate protective measures, and fulfill the requirements for disseminating this information on material safety data sheets and labels.

A PDF of the guidance can be found
here: http://www.osha.gov/Publications/3371combustible-dust.pdf
or download: Hazard Communication Guidance for Combustible Dusts

Avoiding Heat Stress on the Job  

The stress of working in hot weather is a concern for many as summer approaches. For the thousands of workers exposed to the oftentimes lethal combination of heat, humidity and physical labor, a few precautions can go a long way to preventing many heat-related injuries or deaths.

OSHA's Heat Stress QuickCard offers a good first step in acquiring prevention information. The card is also available on-line in Spanish. Copies of the laminated card can be ordered, at no cost, through the agency's publications page or by calling 202-693-1888.

Visit OSHA's Safety and Health Topics page on heat stress to learn more about this hazard and ways to avoid it.

Three More OSHA Standards Added to Revised Shipyard Industry Document  

Fire Protection in Shipyard Employment, contamination issues related to Hexavalent Chromium and Employer Payment for Personal Protective Equipment are three additions to OSHA's "Shipyard Industry Standards" guidance document. This new resource revises the existing "Shipyard Industry Digest" and incorporates new shipyard employment requirements that have been finalized since the booklet was last published.

A PDF of the guidance can be found
here: http://www.osha.gov/Publications/OSHA_shipyard_industry.pdf
or download: Shipyard Industry Standards

Mandatory Respirator Selection Provisions Added to Existing Respiratory Protection Standard  

Assigned Protection Factors, a new guidance document, provides employers with information for selecting respirators for employees exposed to contaminants in the air.

A limited number of copies are available for ordering from OSHA's publications page or by calling 202-693-1888.

A PDF of the guidance can be found
here: http://www.osha.gov/Publications/3352-APF-respirators.pdf
or download: 3352-APF-respirators.pdf

OSHA Publishes New Deck Barge Safety Guidance Document and Spud Barge Fact Sheet  

Slips, trips and falls, fire and falling overboard are among the major safety topics addressed in two new Occupational Safety and Health Administration (OSHA) online publications designed to protect maritime industry employees.

The Deck Barge Safety Guidance Document was developed to educate employers and employees on preventing injuries and illnesses from hazards associated with deck barges. Other topics mentioned in the document are machinery and equipment, confined or enclosed spaces and training. The Spud Barge Safety Fact Sheet lists three methods that can prevent the spuds, which are vertical steel shafts that hold deck barges in place, from accidentally dropping or slipping. The fact sheet also offers safety measures for employers and employees working on barges and towing vessels. Both publications were produced as a result of a 2006 barge-related accident that caused five fatalities.

Deck Barge Safety Guidance Document

Spud Barge Safety Fact Sheet

Final Rule Clarifies "per-employee" Violations on PPE and Training  

OSHA issued a final rule on December 12 on employer responsibility for providing workers with personal protective equipment and training.

The agency said the rule, effective January 12, makes it "unmistakably clear" that each covered employee must receive PPE and training, and that each instance of noncompliance may be considered a separate violation subject to a separate penalty.

OSHA said the action does not add any new compliance obligations, and was taken in response to recent decisions of the Occupational Safety and Health Review Commission that questioned differences in wording among various OSHA PPE and training provisions. Acting OSHA administrator Thomas M. Stohler described the rule as a "technical correction."

Report Urges New Culture for DOL and OSHA  

The Center for American Progress, a Washington liberal think tank, is calling for a "change of culture" at the Department of Labor and OSHA following eight years of conservative stewardship under the Bush administration.

The organization is headed by John Podesta, co-chair of the Obama-Biden transition team and a former chief of staff for President Bill Clinton. It issued a report (.pdf file) offering five strategies for President-Elect Barack Obama:

• Use penalties to create a culture of accountability among employers, especially in cases of willful, repeat or high-hazard violations.
• Increase OSHA enforcement staff and assist enforcement initiatives through partnerships with community organizations, industry associations, state worker protection agencies and labor unions.
• Target high-violation industry sectors with strategic initiatives backed by sound data.
• Use thorough recordkeeping to drive enforcement priorities and improve performance evaluations.
• Strengthen immigrant worker protections.

  FMCSA Issues Rule to Improve the Safety of Equipment Used in the Transportation of Intermodal Containers

New rules will significantly strengthen safety requirements for intermodal container chassis, the special trailers that hold cargo containers when they are transferred from ship or rail to truck for final delivery, announced John H. Hill, administrator of the Federal Motor Carrier Safety Administration (FMCSA).

"We want to ensure that every piece of equipment traveling on our highways is operating safely," said FMCSA Administrator John H. Hill. "These new rules will bring new safety and enforcement focus on the chassis and equipment used to haul goods on our nation’s roads every day," Hill said.

The new regulations make intermodal equipment providers subject to the Federal Motor Carrier Safety Regulations (FMCSRs) for the first time, and establish shared safety responsibility among intermodal equipment providers, motor carriers, and drivers.

Beginning in December 2009, intermodal equipment providers must have in effect regular and systematic inspection, repair, and maintenance programs for intermodal chassis; they will also need to track defects reported and repairs made. By December 2010, each intermodal provider is required to identify its equipment with a USDOT number. FMCSA's final rule also outlines inspection requirements for motor carriers and drivers operating intermodal equipment.

Intermodal equipment providers will be subject to on-site reviews to ensure compliance with the new rules. Penalties for violating these rules range from civil fines to a prohibition on providing or operating intermodal equipment found to pose an imminent hazard.

The final rule on this Intermodal Chassis is available for review at www.fmcsa.dot.gov/rules-regulations/administration/rulemakings/rule-programs/rule_making_details.asp?ruleid=257&year=2008&cat=final

IMO Publishes New IMDG Code (2008 Edition)  

A new edition of the International Maritime Dangerous Goods (IMDG) Code, the standard guide to all aspects of handling dangerous goods and marine pollutants in sea transport, has been published by the International Maritime Organization (IMO) in hard copy, as a download and as an internet subscription. The new edition includes the changes in Amendment 34-08, adopted by the Maritime Safety Committee (MSC) in May 2008.

Although the information in the Code is directed primarily at the mariner, its provisions are essential for a whole range of industries and services. Manufacturers, packers, shippers, feeder services such as road and rail, and port authorities will find reliable advice on terminology, packing, labelling, classification, stowage, segregation, and emergency response action.

The new amendments to the Code are mandatory as from January 1, 2010 but may be applied by Administrations voluntarily from January 1, 2009.

The many detailed changes introduced by Amendment 34-08 include:

• in the Dangerous Goods List, there are 12 new UN numbers going up to 3481, with explosives going up to 0508;
• there are also 5 UN numbers which were previously not listed in the IMDG Code because they were not regulated under it;
• appropriate training for shore-side staff involved with dangerous goods is now mandatory instead of just recommended, and may be audited by the competent authority.

Persons not yet trained may only operate under the direct supervision of a trained person; and additional changes concerning marine pollutants, IMO tank instructions, excepted quantities, limited quantities and radioactive materials of class 7.

The products listed above are available from authorized distributors of IMO publications and via IMO's online bookshop.

Customers wishing to be informed about the availability of new IMO titles can register online.

OSHA Clarifies Electrical Standard  

OSHA recently issued a clarification to a revision made on its electrical installation standard for general industry.

The revision - 29 CFR part 1910, subpart S (72 FR 7136) - went into effect Aug. 13, 2007, and has since received questions regarding one of the provisions: 29 CFR 1910.304 (b)(3)(ii).

Members of the Maritime Advisory Committee on Occupational Safety and Health questioned the extent of the application of the provision to shipyard employment, as the provision's text refers to "construction-like activities."

In addition to rewording the text of the provision to better match the agency's intent, OSHA also stressed that "construction-like activities" entail work that, while not construction, involves hazards typically found in construction work. Thus, the provision applies to shipyard work that is not covered by the shipyard standards and involves tasks that pose electrical hazards similar to those found at a construction site.

The new text now reads:

"The following requirements apply to temporary wiring installations that are used during construction-like activities, including certain maintenance, remodeling, or repair activities, involving buildings, structures or equipment."

Canadian Agency Launches Online Safety Community  

The Canadian Center for Occupational Health and Safety (CCOHS) has launched Workscape; an online discussion board where people interested in health and safety can exchange ideas and information to help make workplaces healthy and safe.

Free to join, Workscape was created primarily as a resource for the Canadian health and safety community; however anyone around the world with an interest in occupational health and safety can participate. Workscape members can share their experiences as well as post information, comments and questions on various topics including chemical safety, ergonomics, healthy workplaces, legislations and compliance, and training and education. Users can also find and post messages about job opportunities, seminars, and conferences. Workscape also features informal areas where members can introduce themselves and network with other health and safety professionals across the country.

CCOHS has a history of implementing technological tools to better serve Canadians. Workscape was established to offer a more interactive and dynamic platform for the sharing and exchange of workplace health and safety information among members of the workplace health and safety community.

For more information on Workscape, or to join the online community, visit www.workscape.ca

Checklist for Incident Investigations  

Guide for Indentifying Casual Factors and Corrective Actions

New Construction Equipment Visibility Topic Page  

NIOSH has added a new safety and health topic page on blind areas around construction equipment for safety personnel and instructors to raise awareness on the hazards of working around construction vehicles and equipment.

Blind area diagrams for 38 types of construction equipment are available for download or print. A blind area diagram is a detailed visual representation of the area around a vehicle or piece of equipment that cannot be seen from the operator's position.

The NIOSH Safety and Health Topic: Highway Work Zone Safety, Construction Equipment Visibility can be found at http://www.cdc.gov/niosh/topics/highwayworkzones/BAD/default.html

Shipfitting  

http://www.osha.gov/dts/maritime/sltc/ships/shipfitting/index.html

Shipfitting is a physically demanding job. Shipfitters construct entirely new vessels, sections of vessels, overhaul vessels, and repair damaged vessels. This includes work on the hull as well as the interior bulkheads and hatches. Wherever they work, they may be handling heavy materials, lifting, climbing, fitting, and sometimes working high above the ground. Specific tasks may include: laying out, positioning, aligning and securing sections; welding steel material together, and cutting steel. Shipfitters are routinely being exposed to hazards that may result in falls, burns, shocks, traumatic or acute injuries, eye injuries and heat stress. Shipfitters often perform tasks that exposes them to more than one type of hazard.

Electrocution and Shock Hazards in Shipyard Employment  

Electrocution and Shock Hazards in Shipyard Employment

The Safety Alert provides useful tips and reminders about what potentially hazardous situations to look for; and also lists instructions on preventing and eliminating electrical safety and shock hazards. In addition, the Alert illustrates examples of dangerous situations.

This Safety Alert is a product of the Alliances that OSHA signed with the American Industrial Hygiene Association, the American Society of Safety Engineers, the American Shipbuilding Association, the National Shipbuilding Research Program, and the Shipbuilders Council of America.

OSHA Resources on Combustible Dust  

http://www.osha.gov/dsg/combustibledust/index.html

Any combustible material (and some materials normally considered noncombustible) can burn rapidly when in a finely divided form. If such a dust is suspended in air in the right concentration, it can become explosive. The force from such an explosion can cause employee deaths, injuries, and destruction of entire buildings. Such incidents have killed scores of employees and injured hundreds over the past few decades.

Materials that may form combustible dust include metals (such as aluminum and magnesium), wood, coal, plastics, biosolids, sugar, paper, soap, dried blood, and certain textiles. In many accidents, employers and employees were unaware that a hazard even existed.

A combustible dust explosion hazard may exist in a variety of industries, including: food (e.g., candy, sugar, spice, starch, flour, feed), grain, tobacco, plastics, wood, paper, pulp, rubber, furniture, textiles, pesticides, pharmaceuticals, dyes, coal, metals (e.g., aluminum, chromium, iron, magnesium, and zinc), and fossil fuel power generation.

Ergonomics for the Prevention of Musculoskeletal Disorders: Guidelines for Shipyards  

PDF Version         Online Version

OSHA has recently released Ergonomics for the Prevention of Musculoskeletal Disorders: Guidelines for Shipyards, an industry-specific guidance document that provides practical recommendations to help employers and employees reduce the number and severity of musculoskeletal disorders in the workplace.

The guidelines emphasize various solutions that have been effectively implemented by shipyards across the country to decrease work-related musculoskeletal disorders. An "Implementing Solutions" section offers examples of ergonomic solutions that may be used to control exposure to ergonomics-related risk factors in shipyards.

OSHA Maritime Outreach Training Program  

http://www.osha.gov/dcsp/ote/outreach/maritime/index.html

OSHA has developed an OSHA Outreach Training Program for the Maritime industry. This new program builds on OSHA's successful Outreach Training Program platform to extend safety and health training to employees and employers in the maritime industry.

Through the program, individuals who complete a one-week OSHA Maritime trainer course are authorized to teach 10-hour or 30-hour safety and health hazard recognition and prevention classes in Shipyard Employment (including ship repairing, shipbuilding, and shipbreaking), Marine Terminals, and Longshoring. Authorized trainers can receive OSHA course completion cards for their students. The Maritime 10- and 30-hour student cards will expire in five years.

The Maritime Outreach Training Program is voluntary. OSHA does not require participation in this program.

OSHA Establishes a New National Emphasis Program on Silica  

On February 1st, OSHA announced a new National Emphasis Program (NEP) to target worksites where employees are at risk for developing silicosis.

"Exposure to silica threatens nearly two million American employees annually," said Assistant Secretary of Labor for OSHA Edwin G. Foulke, Jr. "Under this program, OSHA will work diligently to maximize the protection of employees and eliminate workplace exposures to silica-related hazards."

The NEP compliance directive builds on policies and procedures instituted in the 1996 Special Emphasis Program and includes an updated list of industries commonly known to have overexposures to silica; detailed information on potential hazards linked to silica and about current research regarding silica exposure hazards; guidance on calculating the Permissible Exposure Limits (PELs) for dust containing respirable crystalline silica in the construction and maritime industries; and guidance on conducting silica-related inspections.

Two additional elements included in the directive are an evaluation procedure for recording reductions of employee exposures to silica, as well as information on outreach programs, partnerships and alliances with employers to share resources and training to reduce employee exposures.

Silicosis is a disabling, nonreversible and sometimes fatal lung disease caused by breathing in a large amount of crystalline silica. Visit www.osha.gov for more information on hazard recognition and possible solutions to silica exposure.

OSHA Publishes Instruction on Hexavalent Chromium Standards  

OSHA Jan. 24 published an instruction (.pdf file) on enforcement procedures for its hexavalent chromium standards that went into effect in 2006.

The instruction establishes uniform inspection and compliance procedures for the hexavalent chromium standards 29 CFR 1910.1026, 29 CFR 1926.1126 and 29 CFR 1915.1026. The standards specify permissible exposure limits for general industry, construction and shipyards.

NIOSH Web Resource on MRSA and Recommended Ways to Prevent Risks of Infections  

A new NIOSH Topic Page, http://www.cdc.gov/niosh/topics/mrsa offers recommendations for preventing the spread of MRSA, Methicillin-resistant Staphylococcus aureus, in the workplace. The Topic Page provides practical information on good, basic health practices which workplaces can tailor for their individual needs.

Europe Leads Box Security Research  
by Janet Porter Lloyd's List

European scientists believe they are ahead of their opposite numbers in the US in developing a device that would satisfy Washington's quest to check every container arriving in the country, while also cracking down on cargo theft.

No system can be fully effective until a global standard is agreed, but here too events are moving quickly.

Thales Research Technology (UK) is heading a consortium that hopes to publish its proposal on the standardisation of readers for suitably adapted containers next month, once permission has been given by the European Commission, which is sponsoring and partially financing the project.

The recommendations will then be submitted to the International Organisation for Standardisation for validation.

However, Thales R&T has already produced a small and easily fitted device that is ready to go into production, and which would allow cargo owners and other authorised parties to monitor a container from the moment contents are loaded until the point of delivery.

Michael Naylor, technical manger at Thales R&T, believes this could go a long way towards meeting proposed requirements for screening 100% of US-bound containers with a minimum of disruption and without the need for massive manpower resources.

Instead of scanning a container at various points during a door-to-door delivery - particularly if it is transhipped - the box would only have to be screened once, for example, at the load port.

Following that, regular interrogation of the sensors during the journey would quickly spot anything irregular. Otherwise, the container could be discharged without the need for any further security checks.

The container alert is able to generate warnings if, for example, container doors are opened unexpectedly, there is a break-in through the side walls or roof, a deviation from the planned route, cargo tampering, or if the box has been moved into an unauthorised area.

It is also able to distinguish between different types of motion or noises and send a signal in the case of some unexplained event. At times when the container is known to be in a safe environment, the sensors can remain dormant so as to conserve battery power.

If the container is transitting a high-risk area, the device could be programmed to transmit status reports every few minutes.

Thales R&T, part of the Paris-based multinational defence, aerospace and security systems group Thales, is already discussing trials with some shippers of high value merchandise or perishables.

The company is also in contact with shipping lines and container leasing companies about fitting the container alert device, which could cost as little as €30 apiece and, unlike an electronic seal, is re-usable. Each time, it would be rearmed with a unique number.

Exactly how much is stolen from containers is hard to establish, given the lack of collated data, but one figure cited puts the value at many billions of dollars a year, according to Gary Jordan, a senior engineer at Thales R&T.

Containers are also used by organised crime for smuggling illicit goods across borders and, potentially, by terrorists.

"The container is the weakest point in the supply chain," Mr Jordan told a presentation on the Thales R&T technology, which has been developed in collaboration with a number of other companies and organisations, including HM Revenue Customs and Imperial College in London.

The next step, however, is to agree common standards for a data reader, such as worldwide radio frequencies.

The time taken to be accepted by the ISO would depend very much on the extent of international support for a global standard, but could be reached within a couple of years.

What Thales R&T hopes to unveil next month, if given the green light by Brussels, is a standardised goods data device that would enable trade interests, handlers such as ports or transport companies, and law enforcement agencies, to check on any suspicious activity involving the box and its contents during the entire journey.

The time and location of events like a door opening, large shocks or periods without movement would be recorded, so that responsibilities for such activities can be ascertained.

Once the European Commission has allowed the proposals submitted for its Secure Container Data Device Standardisation project to be published, Thales plans to present its recommended interface to a conference in Dubai in November.