This is a very broad statement. Privacy issues could arise if records about individual employees are shared. I want to bring to your attention the increasing use of performance standards for training requirements. Moreover, OSHA is under tremendous pressure as a result of the Paperwork Reduction Act to decrease recordkeeping requirements. The agency will be hard pressed to justify new broad sweeping requirements for training paperwork.
Subcontract arrangements vary tremendously in the industry.
As the committee has heard over and over, a large commercial site can have completely different industry practices than a residential project. The right regulation for one project could be totally unsuitable for another. The language put forth by Charlie Darnell of the National Construction Safety Executives is an improvement over the latest draft language. However, I would reiterate that OSHA is entering new territory and should tread cautiously. This industry is dominated by the smallest firms.