Establishing Indicators to Determine Whether State Plan Operations are At Least as Effective as Federal OSHA: Stakeholder Meeting

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 comments on Establishing Indicators to Determine Whether State Plan Operations Are at Least as Effective as Federal OSHA that was noticed in the Federal Register on June 19, 2012 (77 Federal Register 36579-36580). Because NAHB members are constructing homes in all twenty-six states that administer their own occupational safety and health plans (State Plans), we are very interested in how Federal OSHA intends on determining whether OSHA-approved state plans are at least as effective as the Federal OSHA program, as any determination could have a substantial impact on home builders in these states. Comment letter attached.