From:  
Rick Marshall  
To:  
MIOSHA-Standards  
Subject:  
Date:  
Administrative Rules for Part 25. Concrete Construction Rule Set 2024-51 LE  
Friday, February 20, 2026 11:58:01 AM  
Attachments:  
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MIOSHA.pdf  
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Heather Albert or Amber Sweeney,  
Good day. Please accept our attached comments for the proposed language for MIOSHA  
Administrative Rules for Part 25. Concrete Construction Rule Set 2024-51 LE. I will  
th  
unfortunately not be able to appear in person at the March 4 public hearing in Lansing, so  
we are submitting them electronically.  
We appreciate the opportunity to participate in rulemaking which will improve the safety and  
health of those workers employed in the deep foundation industry.  
Thank You.  
Richard Marshall, CHST  
Director of Safety  
513-609-1010  
rmarshall@adsc-iafd.com  
www.adsc-iafd.com  
From:  
To:  
Cc:  
Eric Medley  
Sweeney, Amber (LEO); Albert, Heather (LEO)  
Marc Arthur  
Subject:  
Date:  
Part 25 - Concrete Construction Questions/Clarification  
Wednesday, March 4, 2026 3:25:09 PM  
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Good Afternoon.  
Please see my questions below regarding the Part 25 – Concrete Construction standard  
changes.  
Rule 408.42529  
1. A route designated as a means of access or egress across reinforcing steel for general  
traffic with a walkway. What defines an adequate walkway?  
Rule 408.42531  
2. In part 2 of this rule it states “A competent person shall inspect the stressing equipment  
for damage or defects before stressing operations begin, and periodically during the  
stressing operations” but in part 6 it states “An employee shall not stand in the line of,  
in back of, over the jacking equipment, or above or alongside the full length of the  
tendons during tensioning operations”. These two rules seem to conflict with one  
another, please clarify how this work can be completed and comply with this rule.  
3. Once the ruling becomes law, can ongoing projects be grandfathered in if they have  
already started?  
4. An employer shall ensure there is an adequate safe work platform of a minimum of 3  
feet measured from the end of the floor slab to the platform toeboard, such as an  
extension of the formwork, for stressing tendons, cutting tendon tails, and grouting  
where tensioning operations are above grade. In the event a 3’ adequate safe work  
platform cannot be maintained due to site restrictions (i.e. property line / building  
clearances), what does this deviation process look like?  
5. An employer shall ensure stressing equipment is secured to prevent accidental  
displacement during operation. Is this just per the manufacturers recommendations for  
the equipment or will there be other measures that need to be taken into consideration?  
Rule 408.42534  
6. Training Requirements. Employers shall ensure and document that each employee has  
been provided training and evaluation by a qualified person for the work and avoidance  
of hazards specific to the activities involved with, and related to concrete placement,  
precast placement, reinforcing steel activities, post-tensioning rigging, placement of  
shores and reshores, formwork, and handling of chemicals such as cement, concrete,  
and form-oils. What is the criterial for this training? For example, completed by a 3-  
party? Is it just a review of the hazards and mitigations associated with the work taking  
place at the time? Does a Daily Pre-Task Plan review and sign-off fulfill this criteria?  
Thanks,  
Eric Medley | Interim Safety Director  
GRANGER|ADVANCE THE ART OF BUILDING  
6267 Aurelius Road  
Lansing, MI 48911  
office 734.773.1139  
cell 734.755.9010  
grangerconstruction.com  
From:  
To:  
Kathleen Dobson  
MIOSHA-Standards  
Subject:  
Date:  
Comment - Part 25 - Concrete Construction - Attention Heather Albert & Amber Sweeney  
Wednesday, March 4, 2026 1:06:27 PM  
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I was a member of the advisory group that met last January 2025 to revise the Michigan  
Standard Construction part 25 - Concrete Construction.  
This comment is made by me, as a private citizen of the State of Michigan and as a  
member of the national A10 standards committee.  
For reference, I serve on the A10 - Safety Requirements for Construction & Demolition  
Operations committee as a consultant member.  
My comment:  
In R 408.42502, Adoption of standards, listed is the Adopted by Reference (a) American  
National Standard Institute ANSI A10.9, "Concrete Construction and Masonry Work,"  
1983 edition.  
The current ANSI/ASSP A10.9 standard was last reaffirmed in 2018. I recommend the  
Department of Labor and Economic Opportunity MIOSHA, Standards and FOIA Section  
adopt the ANSI/ASSP 2018 A10.9 standard, which is 35 years more current than the 1983  
standard in the current and proposed Department of Labor & Economic Opportunity  
Construction Standard Part 25, Concrete Construction.  
Respectfully,  
Kathleen Dobson  
525 Sturdevant Rd  
Smiths Creek, MI 48074  
(810) 523-5362  
Kathi Dobson  
[email protected]  
810 523-5362 (mobile)  
810 434-1127 (office/home)  
;