"Therefore, OSHA has determined that it is appropriate to initiate further proceedings regarding Subpart M so that the Agency can re-evaluate what constitutes adequate fall protection for various construction operations. OSHA is moving expeditiously to develop an NPRM. In particular, further proceedings will provide an opportunity to update OSHA's information regarding the fall hazards to which residential construction workers are exposed. This, in turn, will enable the Agency to evaluate the alternative methods and procedures suggested by roofing contractors for residential roofing work." (STD 3.1, § G, emphasis added.)After the Directive was issued in 1995, NRCA worked hard to assist its members to comply with the 1994 Standard as modified by the Directive and continued NRCA's traditional role in developing and disseminating safety information, programs and materials for the roofing industry. In addition, NRCA has worked closely with OSHA and the United Union of Roofers, Waterproofers and Allied Workers (the Roofers Union) toward the common goal of improving worker safety and developed the Roofing Industry Partnership for Safety and Health (RIPPSH). In fact, RIPPSH is the first partnership that includes labor, government and management in the construction industry working jointly to promote and reward safety. NRCA's contractor members support and encourage the development of these safety-related programs. Roofing workers are vital to the industry's success and, unfortunately, there already is a serious industry labor shortage. The industry cannot spare even one worker and takes the well-being of all workers seriously.