National Association of Home Builders filed 7 comments on this docket between Dec 13, 2013 and Oct 1, 2018. 344 other organizations filed here. The comment window closed 2860d ago.
On behalf of the 140,000 members of the National Association of Home Builders of the United States (NAHB), NAHB respectfully submits these comments in response to the Occupational Safety and Health Administrations (OSHA) proposed rule entitled Tracking of Workplace Injuries and Illnesses (83 Fed. Reg. 36494 (July 30, 2018)). [See attached comments]
On behalf of the 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) proposed delay of the compliance date for the final rule to Improve Tracking of Workplace Injuries and Illnesses (Electronic Recordkeeping and Reporting Rule) that was published in the Federal Register on June 28, 2017 (82 Fed. Reg. 29261-29263). See attached letter.
On behalf of the National Association of Home Builders (NAHB), I am pleased to submit the attached comments on the Occupational Safety and Health Administrations (OSHA) Supplemental Notice of Proposed Rulemaking on Improved Tracking of Workplace Injuries and Illnesses that was published in the Federal Register on August 14, 2014 (79 Fed. Reg. 47605) (Supplemental NPRM). As an interested stakeholder in this regulatory activity, NAHB is concerned that the Supplemental NPRM would add provisions to the original proposed rule that would make it a violation for an employer to adopt any number of wide ranging practices that may discourage an employee from reporting work-related injuries and illnesses. NAHB believes that this Supplemental NPRM will have a substantial adverse impact on how regulated employers and small businesses, including home builders and specialty trade contractors, operate their occupational safety and health programs. It will also have unintended consequences by significantly impacting how employers and small businesses actually manage their businesses and employees. As explained in our comments on the original Notice of Proposed Rule Making (Electronic Recordkeeping NPRM), NAHB believes OSHAs plan to amend its recordkeeping regulations to add requirements for the electronic submission of injury and illness information to the agency is troublesome and problematic. Equally troubling is OSHAs Supplemental Notice of Proposed Rulemaking, which violates the Administrative Procedures Act (APA), impermissibly expands Section 11(c) of the Occupational Safety and Health Act of 1970 (OSH Act), interferes with state Workers Compensation Laws, and hinders implementation of employer safety and health programs. Because of these fundamental flaws in the Agencys proposal, NAHB reiterates its position that OSHA must withdraw both the Electronic Recordkeeping NPRM and the Supplemental NPRM. (please see attached comment letter)
On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), we respectfully request a 60 day extension of the current deadline for submitting written comments in response to the Occupational Safety and Health Administrations (OSHA) Supplemental Notice of Proposed Rulemaking (Supplemental NPRM) on Improved Tracking of Workplace Injuries and Illnesses that was published in the Federal Register on August 14, 2014 (79 Fed. Reg. 47,605). See attachment.
On behalf of the more than 140,000 members of the National Association of Home Builders (NAHB), I am pleased to submit the attached comments on the Occupational Safety and Health Administration's (OSHA) Notice of Proposed Rulemaking (NPRM) to Improve Tracking of Workplace Injuries and Illnesses that was published in the Federal Register on November 8, 2013 (78 Fed. Reg. 67254-67283) (Electronic Recordkeeping NPRM). As an interested stakeholder in this regulatory activity, NAHB is concerned that OSHA's proposed changes to the recordkeeping rule to add requirements for the electronic submission of injury and illness information will have a substantial adverse impact on regulated employers and small businesses, including home builders and specialty trade contractors. See attached comment letter.
On behalf of its more than 140,000 members, the National Association of Home Builders (NAHB) respectfully requests a ninety (90) day extension of the current deadline for submitting written comments in response to the Occupational Safety and Health Administration's (OSHA) Notice of Proposed Rulemaking (NPRM) on Improved Tracking of Workplace Injuries and Illnesses that was published in the Federal Register on November 8, 2013 (78 Fed. Reg.67254-67283) (Electronic Recordkeeping NPRM). NAHB also requests that OSHA delay the public meeting related to this rulemaking until after the comment period closes.
The National Association of Home Builders (NAHB) hereby files this Notice of Intention to attend and participate in the informal public meeting regarding the Occupational Safety and Health Administration's (OSHA) Proposed Improve Tracking of Workplace Injuries and Illnesses Rule, currently scheduled for January 9, 2014 in Washington, DC. Additionally, NAHB believes that OSHA's timing of the public meeting, which is a full month BEFORE the comment period closes, is misaligned, inappropriate, and does a disservice to the regulatory process. The regulatory process allowing public participation and input on proposed, new, or amended regulations ensures meaningful participation from those who will be subject to the regulations. Unfortunately, OSHA has scheduled the public meeting prior to the close of the comment period, which undermines the ability of the public and regulated community to fully prepare responses, identify possible areas of concern, and meaningfully participate in the regulatory process. Accordingly, NAHB requests that OSHA reschedule the public meeting to a date that falls after the current comment period deadline of February 6, 2014, and suggest this meeting be moved to at least 90 days after the comment period closes.
Notice of proposed rulemaking on improving the tracking of workplace injuries and illnesses
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