Communication Tower Safety: OSHA Request for Information (2420 Words)

The assignment is to write a policy paper to send to the federal government. This will come as a well-researched, well-written response to a call for comments on a proposed rule. The proposed rule can be on any topic for any part of the bureaucracy. You can find all proposed rules on regulations.gov. Your paper should be 8-10 pages (including the bibliography). You should have approximately 8-10 sources, although more is better. You are to take a position in response to the proposed rule and make your main point (your position on the proposed rule) in the intro paragraph. The rest of the paper should consist of supporting evidence for your position in a well-reasoned, logically-organized and fact/research-based way. Your conclusion should sum up your point/main position. Please be sure to use in-text citations for all information you pull from a source.

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Communication Tower Safety: OSHA Request for Information

Dear Mr.
I appreciate the recent proposal for the communication tower safety and the adjoining call for comments for the incorporation of the further measures to ensure the safety of the workers.
I, ___ with an engineering degree and possessing 25 years of experience in designing and construction of communication towers would like to share my input on this proposal.
In recent years there have been several fatalities in worker deaths. In 2013, a total number of 13 workers were killed at several communication tower worksites.
Unfortunately, this was more than the number of the workers killed in the previous two years combined. Also, within six weeks of the beginning of the year 2014, about 4 workers met with fatal on-site accidents.
This highlights the urgent preventive measures to overcome the accidental deaths of the workers. It is my strong belief that with a strict adoption of safety measures, “Every single of these tragedies was preventable.” (Michaels) Therefore, in my letter, I wish to point to shared responsibility of all the agencies involved to ensure the safety of the workers—ranging from the workers, tower owner, carrier company as well as OSHA.
Undoubtedly, “working on a tower involves coordinating and planning with numerous parties even before stepping up on the first rung. Involved groups include the carrier that is contracting the work, the tower owners, and other carrier.” (TESSCO)
Universal Standards: As acknowledged by the OSHA that so far, there is lack of federal or universal standards to comprehensively cover the range of activities that are involved in the communication tower construction activities. (OSHA p. 20187) So, the first and foremost requirement is that the OSHA develop a comprehensive standards operating procedures in this regard, that provide guidelines for the workers and the different agencies involved to adhere to, or face penalties.
There should be an increasing emphasis on application of penalties in the event of the failure of the adherence to the required standards. In the absence of specified penalties –legal or financial—the agencies can simply ignore the standards. Moreover, OSHA makes reference to standards imposed under other different regulations. There is need for comprehensive regulations under OSHA....