American Chemistry Council filed 2 comments on this docket between Mar 5, 2014 and Jul 13, 2017. 344 other organizations filed here. The comment window closed 2860d ago.
The American Chemistry Council (ACC) is pleased to respond to the U.S. Department of Labor's (DOL) Occupational Safety and Health Administration (OSHA) notice of proposed rulemaking (NPRM), Docket No. OSHA-2013-0023, published in the Federal Register on June 28, 2017 at 82 Federal Register 29261-29263.
Dear Assistant Secretary Michaels: The American Chemistry Council (ACC) is pleased to respond to the U.S. Department of Labor's (DOL) Occupational Safety and Health Administration (OSHA) notice of proposed rulemaking (NPRM), Docket No. OSHA-2013-0023, published in the Federal Register on November 8, 2013 at 78 Federal Register 67254. ACC members place a high value on creating safe and secure workplaces for their employees, contractors working on site and visitors. Through Responsible Care®, the industry's comprehensive environment, health, safety and security performance initiative, ACC members are committed to the goals of no injuries, no incidents and no harm to the environment. ACC member companies had an aggregate worker injury and illness rate of 0.75 per 100 full-time employees (FTEs) in 2012, which is five times better than the average for all of U.S. manufacturing. In addition to employee injury and illness rates, ACC companies report on contractor safety data as part of their Responsible Care obligations. In 2012, the aggregate contactor injury and illness rate for individuals working at ACC facilities was 0.65. Members report their worker and contractor safety data annually to ACC as part of their Responsible Care metrics and this information is available to the public on the ACC's website. ACC supports OSHA's goal of improving worker health and safety. However, we strongly urge OSHA to reconsider this proposed rule, as it raises many concerns for ACC and its members, as outlined in the appended comments. We hope that OSHA will find our contribution helpful. Should you have questions about our input, please contact me by phone at (202) 249-6426 or by e-mail at Rachel_meidl@americanchemistry.com Respectfully submitted, Rachel A. Meidl Director, Regulatory & Technical Affairs American Chemistry Council 700 Second Street, NE Washington, DC 20002
Notice of proposed rulemaking on improving the tracking of workplace injuries and illnesses
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