GWO Memo for US - DBR October 2018

California Delaware Illinois New Jersey New York Pennsylvania Texas Washington D.C.

MEMORANDUM

Ralph Savage, Global Wind Organisation, Head of Communication

TO:

Mark G. Maser, Esq.

FROM:

DATE: October 3, 2018 SUBJECT: BACKGROUND INFORMATION ON GWO AND OSHA SAFETY TRAINING STANDARDS This memorandum † is comprised of five parts. • Part I describes the Global Wind Organisation (“GWO”) and its safety training standards. • Part II provides an explanation of the mandate for U.S. employers to comply with the United States Occupational Safety and Health Administration’s (“OSHA”) requirements for employee safety training. • Part III discusses why and how the GWO’s safety training standards are relevant instruments that employers can use to aid in their compliance with certain OSHA- mandated requirements for training employees who work in the wind power industry. • Part IV explains how industry consensus standards may be used to create legally enforceable job safety requirements in the United States. • Part V examines how liability for deficient safety training may be assessed against employers, third-party trainers, and providers of trainer certifications. I. WHAT IS GWO, AND WHAT TYPES OF SAFETY TRAINING STANDARDS DOES IT PROMULGATE? GWO is a non-profit body founded by leading wind turbine manufacturers and operators in 2012. Safety is the number one priority for companies in the wind power industry and the GWO functions to create a safer and more productive workplace. GWO members strive for an injury free work environment in the wind turbine industry, setting common standards for safety training and emergency procedures.

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