Icy Strait Point, LLC

Erica Drahozal, Director of Sustainability

108 Cannery Road, Hoonah, Alaska 99829

In accordance with the variance procedures and standards set forth in Alaska OSH Program Directive No. 85-6, 8 AAC 61.340, and 29 CFR 1905.11, Icy Strait Point LLC requests a permanent variance. The grounds for this request are set forth in greater detail below.

Icy Strait Point LLC respectfully requests a permanent variance from the safety and health standard prescribed in 8 AAC 61.1040, amended from (a) 29 C.F.R. 1910.142(b)(2), and 1910.142(b)(7). All of which are in regard to the size of rooms and the window space used for sleeping purposes in three employee camp sites: Camp Yukon, Camp Turnagain, and Camp Maher.

 Icy Strait Point (ISP) operates a private cruise ship port in Hoonah, Alaska, located on Chichagof Island. The community is remote, with no road access to any major city or town, making logistical support and workforce recruitment uniquely challenging. When ISP opened in 2004, the business model anticipated a locally sourced workforce of approximately 120 employees. However, since the construction of a cruise ship dock and expanded facilities in 2015, and addition of two gondolas, mountain top operations, and significant visitor infrastructure in 2019, the demand for staff has steadily increased to over 300 during peak season. Due to the limited labor pool in Hoonah, ISP has invested heavily in seasonal worker housing to meet workforce needs.

Due to the high cost of additional housing, it is not presently feasible to comply fully with the state amended requirement of 60 square feet per resident (from the federal requirement of 50 square feet). Furthermore, a contractor provided an estimate of $105,600.00 to increase the window sizes in Camp Maher; however, labor availability may pose a challenge. The result would be 37 employees losing their jobs over room size and/or 42 employees losing their jobs over window size, meaning the shutdown of some of Icy Strait Point’s operations. Operations currently provide an economic impact to Hoonah by bringing in over $15 million per year to this remote village.

Given the financial constraints, substantial existing investments, geographic limitations, contractor availability, and significant economic implications, ISP respectfully requests a variance from the State of Alaska amendment for Additional Temporary Labor Camp Standards 8 AAC 61.1040, and OSHA’s Window Space Requirement 1910.142(b)(7).

Icy Strait Point LLC offers these proposed alternative means of protection:

1. Limit these specific housing units to seasonal use only (April – October)
2. Limit occupancy to 2 persons per room
3. Will not exceed recommended occupancy from supplier of housing units
4. Will meet or exceed Federal recommendations of at least 50 square feet per occupant in sleeping rooms and come close to the Alaska amended requirement of 60 square feet pr occupant. In addition, all rooms have a ceiling higher than 7 feet, adding to the air flow space.
5. Conduct regular housekeeping inspections and daily sanitation
6. Provide common areas, indoor and outdoor
7. Ensure all rooms have working windows and screens for ventilation
8. Educate employees in housing on the importance of ventilation and continue to educate all staff twice per year on transmissible illness prevention
9. Continue to maintain additional housing specifically for isolation from roommates when employees become ill.

In accordance with 8 AAC 61.340(b)(7), a summary of the application has been properly posted, and the summary specifies where a copy of the application may obtain and a statement of the employee’s right to a hearing on the application. A copy of the posted summary is attached, along with a signed certification. While this application is pending post interim order, Icy Strait Point requests that a permanent variance order be issued pursuant to 8 AAC 61.340(c).