In light of the challenges being offered by the Ergonomics Standard and to 
ensure that each group within Enron understands the importance of the 
Grandfather requirements, we have scheduled a meeting on Thursday, November 
30, at 1 PM CST. Those of you who will be in Houston can get together in the 
Crisis Center (EB4554) and others can join in the meeting via conference call 
at 877 795-3687, Access Code 539773. Russ has told me the meeting may last an 
hour, depending on questions. He has also informed me that prior to our 
meeting we should all read the document attached in his memo below.

Thanks in advance for your participation.

Steve
---------------------- Forwarded by Stephen Allen/OTS/Enron on 11/27/2000 
02:55 PM ---------------------------

Russell Tucker

11/22/2000 03:57 PM

To: Stephen Allen/OTS/Enron@ENRON, abolars@enron.com, Herb Caballero/Enron 
Communications@Enron Communications, Paul Duplachan/ECF/Enron@ENRON, George 
Allen Orum/ECF/Enron@ENRON, Roger Raney/HOU/EES@EES, Scott 
Watson/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Ron E Wells/EFS/EES@EES, Donnie 
Willmann/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT
cc: Shelley Corman/ET&S/Enron@ENRON, Frank Smith/Corp/Enron@ENRON, Gary 
Allen/OTS/Enron@ENRON, Marc Phillips/OTS/Enron@ENRON, John 
Shafer/OTS/Enron@Enron, Michael Terraso/OTS/Enron@ENRON, Henry 
Van/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, edgar.zuleta@transredes.com, Kenneth 
Lovejoy/Corp/Enron@ENRON, Jeffrey Keeler/Corp/Enron@ENRON 

Subject: Revisions to Office Ergonomics Program Draft

Attached is the promised revisions to the last draft of the Office Ergonomics 
Program to bring it in line with the OSHA final rule for Grandfathering. As 
reports place each of you in different phases of modification of the last 
draft, I have left the corrections and additions in red so that you may 
easily see the areas needing changes. All are considered required changes 
except:

*The time to retain ergo related records other than program evaluations is 
not set under the Grandfather requirements. Most will want to know how long 
to keep records, and so this is established herein, but you may wish to 
modify the times.

*Appendix II and III is not required unless you do not Grandfather, but may 
be used anyway if you so desire. As some have not established a decision on 
Grandfathering, these attachments have been included in case they are needed. 
If used, you will need to fill in the name and phone number on the where to 
report MSD work related injuries in Appendix II. I can do this for you if you 
supply the name and number and desire or intend to distribute the appendixes 
in digital form.

Note that this version is set up for use by the Enron EH&S Group for Houston 
office employees, and should not be used without making the revisions to 
reflect your company operations and internal organization in the respective 
places in the text. Implementation does not mean you have to have completed 
all the requirements in the written program. You will have 11 months from 
November 14, 2000 to accomplish that, new hires notwithstanding. The final 
rule Preamble allows modifications until Jan. 16, 2001 for programs 
implemented prior to Nov. 14, 2000.

This is a written program intended for Grandfathering under 29 CFR 
1910.900(c), and if used as a written plan to meet other requirements of this 
Standard will need additional modification.

We are waiting on legal review by an outside attorney on some areas of the 
final rule which should be available in about a week. A Safety Notice will 
then be issued on this final rule. A revised compliance draft for the 
Field/Plant written program will be issued next week.

Regards,

Russ