During the 2010-11 fiscal year, NRCA Associate Executive Director of Risk Management
Tom Shanahan continued as a member of the Occupational Safety and Health Administration's
(OSHA's) Advisory Committee for Construction Occupational Safety and Health (ACCOSH)—completing
the second of a two-year term—participating in national deliberations on safety
and health matters affecting construction safety and advocating for NRCA members
before the committee.
As part of ACCOSH, NRCA worked to resist OSHA's efforts to rescind the interim fall-protection
guidelines (slide guard rules) proposed in 2009 without supporting data or alternatives
for the roofing industry. NRCA also chaired the Silica, OSHA Training Institute
and Multilingual work groups. In December 2010, OSHA rescinded the interim guidelines
and, as a result, NRCA sued OSHA, saying it constituted a rule and OSHA would have
to go through the rulemaking process to make this move. The courts ruled against
NRCA. Since that time, risk management staff has been meeting regularly with OSHA
and union representatives to gain understanding of and answers to the hundreds of
compliance-related questions members are asking regarding the rescission.
The department helped members with requests for information in nearly 1,000 instances;
participated in the development of eight ANSI A10 standards related to construction
activity; developed and taught NRCA educational offering Profitability Through Effective
Safety Programs under an OSHA Susan Harwood grant and delivered the programs in
four cities throughout the U.S.; and taught the CERTA Train-the-trainer Authorization
and Reauthorization classes numerous times throughout the year. In addition, staff
completely updated the newly published Insurance Guide for Professional Roofing Contractors,
Third Edition.
NRCA staff made presentations addressing safety and health topics to several affiliate
and associate organizations; the National Roofing Legal Resource Center; and CNA,
Chicago, among others. It managed, administrated and executed two Future Executives
Institute (FEI) classes, including developing and teaching six classes in the FEI
program. Also, staff supported activities surrounding the establishment of a new
business education offering, the Executive Management Institute (EMI). EMI's aim
is to provide education for senior roofing executives by offering in-depth classroom
courses. The first program will be offered in the near future.
Additionally, NRCA finalized the development of an NRCA safety design document,
a fall-protection solutions document addressing elimination of fall hazards at the
building design phase; continued NRCA liaison responsibilities with CNA, Construction
Insurance Solutions, Mass Marketing Insurance Consultants and JLBG Health; and negotiated
an agreement with the Coca-Cola Bottlers Association to establish a captive national
health care program for NRCA members. Staff met with OSHA's assistant secretary
of labor regarding roofing safety issues; participated in the joint labor and management
safety committee hosted by the Building and Construction Trades Department of the
AFL-CIO; attended the 30th anniversary of the Regulatory Flexibility Act; participated
in and informed membership regarding national and international research and regulatory
activities surrounding occupational exposures to asphalt fumes; and facilitated
the translation and re-editing of the Asphalt Institute's tanker safety video into
French and Spanish.
In addition, staff developed and presented webinars addressing OSHA's new crane
standard and residential fall-protection changes in addition to the Environmental
Protection Agency's new lead-based paint rules. A five-part material handling video-based
compliance program development has begun and is expected to be released in fall
2011. Risk management staff also provided input and support to the new RISE Certified
Solar Roofing Professional™ designation program.