Silver Bay Seafoods – Southeast, LLC. May 28, 2025 Mitch Wallace, Chief of Consultation and Training Occupational Safety and Health Enforcement Department of Labor and Workforce Development 1251 Muldoon Road, Suite 109 Anchorage, AK 99504 Email: mitch.wallace@alaska.gov Re: Request for Permanent Variances – Craig, False Pass, Petersburg, Sitka, and Ketchikan Employee Bunkhouses Request for Interim Orders Ex Parte Dear Chief Wallace: 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, please allow these letters to serve as the applicant's request for a permanent variance. The grounds for this request, are set forth in greater detail below. Applicant Companies and Authorized Representative Silver Bay Seafoods – Southeast, LLC ("Silver Bay") respectfully requests a permanent variance from the safety and health standard prescribed in 8 AAC 61.1040(a), regarding the size of rooms used for sleeping purposes in employee bunkhouses in the five sites: Craig, False Pass, Petersburg, Sitka, and Ketchikan. Tiffany Lake, Director of Compliance for Silver Bay Seafoods, LLC, manager for Silver Bay Seafoods – Southeast, LLC, is headquartered at 208 Lake Street, Suite 2E, Craig, Alaska 99835. Telephone number: (907-966-3110). Grounds for Variance Request Specifically, Silver Bay seeks relief from the 60-feet-per-occupant threshold in 8 AAC 61.1040(a), which in turn relies on 29 C.F.R. 1910.142(b)(2), as amended and revised. Silver Bay Entities are fishermen-owned and bought the facility in Craig in 2009, at which time they also built worker housing inside the plant and Atcos adjacent to the facility. In 2012, they expanded production which required an additional Bunkhouse on the property to be built. As Silver Bay's operations have expanded, Silver Bay has aggressively acquired and built additional bunkhouses to ensure employees have safe and healthy living quarters. With the high cost of living, remote locations, and seasonal nature of salmon processing, housing options are limited and bunkhouses are essential to Silver Bay's employees and operations. To address the square footage allegations mentioned in AKOSH Inspection Nos. 1679252 and 1760883, Silver Bay has reduced the number of occupants in some bunkhouse units. Silver Bay will also designate certain units for limited occupancy to meet the 60-consecutive-day-vacancy-in-a-year allowance. Finally, Silver Bay will supply rooms with a HEPA air purifier. Collectively, the reduced number of occupants and slight differences in floor-space areas should remedy any concerns about the health and safety of Silver Bay's housed employees. 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 obtained 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 pends, the Silver Bay requests that an interim order be issued pursuant to 8 AAC 61.340(c). Should you have any questions regarding the foregoing, please do not hesitate to contact me. Sincerely, Tiffany Lake, Director of Compliance Silver Bay Seafoods, LLC Manager for Silver Bay Seafoods – LLC Pub: Sept. 10, 2025