Jan 5, 2017· Comment from Matuga, Robert; National Association of Home Builders (NAHB)· OSHA-2012-0007-0747
On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), I am submitting comments on the Occupational Safety and Health Administration's (OSHA or Agency) Notice of Proposed Rulemaking (NPRM) on the Standards Improvement ProjectPhase IV (SIP-IV), that was published in the Federal Register on October 4, 2016. NAHB thanks OSHA for granting stakeholders an additional period of time to submit comments in this important matter. (see attached letter)
Nov 16, 2016· Comment from Watson, Felicia; National Association of Home Builders (NAHB)· OSHA-2012-0007-0576
November 14, 2016
The Honorable Dr. David Michaels
Assistant Secretary of Labor
Occupational Safety and Health Administration
U.S. Department of Labor
Room S-2002
200 Constitution Avenue, NW
Washington, D.C. 20210
RE: Docket No. OSHA-2012-0007 Standards Improvement ProjectPhase IV: Request for Extension of Time for Submitting Comments
Dear Assistant Secretary Michaels:
On behalf of its more than 140,000 members, the National Association of Home Builders (NAHB) respectfully requests a forty-five (45) day extension of the current deadline for submitting written comments in response to the Occupational Safety and Health Administration's (OSHA) Proposed Rule on Standards Improvement ProjectPhase IV, that was published in the Federal Register on October 4, 2016 (81 Fed. Reg.68504- 68685).
As an interested stakeholder in this regulatory activity, NAHB is concerned that OSHA's proposed changes in the Standards Improvement ProjectPhase IV will have a substantial impact on regulated employers and small businesses, including home builders and specialty trade contractors. The issues surrounding changes to the existing standards in its recordkeeping, general industry, maritime, and construction standards require wide-ranging analysis, consideration, and input from NAHB's diverse membership, which cannot be completed in a short, 60 day comment period.
Specifically, NAHB believes that additional time is needed to respond to OSHA's Standards Improvement ProjectPhase IV proposal for the following reasons:
OSHA has proposed changes to eighteen (18) separate existing standards, mostly construction, which requires careful review and discussion by home builders and specialty trade contractors in order to understand the possible ramifications of the changes and their application.
Historically, the Standards Improvement Project proposal is intended to be non-substantive and non-controversial actions that improve and streamline OSHA standards. However, NAHB believes it has identified several substantive changes in OSHA's proposal and the current comment periods does not allow adequate time for builders to focus on each proposal separately and provide the in-depth and meaningful input.
The current comment period ends on December 5, 2016. Given where the review period falls on the calendara week after the Thanksgiving holidayit will be extremely difficult to obtain feedback from home builders.
An extension of the comment period does not create a hardship for the Agency as there is no urgency behind the Standards Improvement Project proposalit does not respond to either a Congressional mandate, or an unprotected hazard.
For these reasons, we believe an extension of time of 45 additional days for submitting comments is necessary and appropriate. Offering meaningful comments on this proposal is extremely important to NAHB's members. Accordingly, NAHB urges OSHA to grant all interested stakeholders this extension.
Thank you, in advance, for your consideration in this request. Please call me at (202) 266-8229 if you have any questions or require any additional information.
Sincerely,
Felicia Watson
Senior Counsel
Feb 5, 2013· Comment from Matuga, Robert; National Association of Home Builders (NAHB)· OSHA-2012-0007-0019
On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), I am pleased to submit these comments on the Occupational Safety and Health Administration's (OSHA) Request for Information (RFI) on its Standards Improvement Project—Phase IV that was published in the Federal Register on December 6, 2012 (77 Federal Register 72781-72783). As an interested stakeholder in this regulatory activity, NAHB has several recommendations for existing OSHA construction standards that should be revised, which will reduce the regulatory burden on the residential construction industry while still maintaining, and even improve, workers safety and health.