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Comment 2 for In-Use Off-Road Diesel-Fueled Fleets and Off-Road Large Spark Ignition Engine Fleet Requirements (on-offroad10) - 15-3.

First NameWilliam E
Last NameDavis
Email Addresswilliamedavis@cox.net
AffiliationSouthern California Contractors Assoc.
SubjectChange required to VDECS Safety Provisions
Comment
Starting with the provisions that begin "VDECS That Impairs Safe
Operation of Vehicle" you should strike all of the convoluted
requirements for Executive Officer hearings, etc., and simply
substitute "all VDECS installations shall comply with the
regulations of the California Occupational Health and Safety
Agency." 

This may be too simple for a regulatory agency, but, it reflects
the Cal/OSHA requirements and you can't possibly want to make a
responsible fleet owner jump through two sets of hoops on this
topic.

If this is not the appropriate place to make the necessary changes,
we can and will go before the Board to achieve this goal.

Thanks

Bill Davis
SCCA

Attachment
Original File Name
Date and Time Comment Was Submitted 2011-09-06 10:17:09

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