|Draft Letter to OMHS&T|
|Friday - September 07, 2012|
WVCA Senior Vice President Chris Hamilton has drafted a letter to C.A. Phillips, director of the OMHS&T related to HB 4351, a set of proposed revisions to the state’s electrical certification standards under Administrative Rules Title 48, Series 7 and the State Rules Governing Assessments of Health & Safety Violations under Title 56, Series 12. This draft letter has been forwarded to WVCA members for review.
There are several areas of the comprehensive legislation which have been misread or misapplied by the agency which we’ll attempt to rectify. In short, the proposed changes to the electrical rule primarily affect the manner by which the experience of apprentices is maintained and verified. Heretofore, the mine operator and apprentice mine electrician are responsible for recording electrical work performed by apprentices. The draft revision would additionally require supervising mine electricians to verify the time devoted to electrical work by apprentice electricians under their supervision. The proposed changes also extend the validity of Apprentice Mine Electrician Certification from one year to eighteen (18) months.
The “draft” Emergency Standards for Assessing Health & Safety Violation Penalties is in response to the passage of HB 4351. We have previously objected and will continue to oppose this rule (see attached letter to Director Phillips).
Both sets of rules are in draft form and have not been officially proposed for public comment. Please review the specific provisions within both sets of rules and provide me with your thoughts or comments at your earliest convenience.