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OSHARulemakingOSHA-2021-0007

COVID-19 Vaccination and Testing Emergency Temporary Standard Rulemaking

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closed 1651d ago
National Association of Home Builders filings
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Activity

National Association of Home Builders filed 2 comments on this docket between Nov 18, 2021 and Jan 20, 2022. 290 other organizations filed here. The comment window closed 1651d ago.

What National Association of Home Builders filed (2)

Jan 20, 2022· Comment from National Association of Home Builders (NAHB)· OSHA-2021-0007-121408

SEE ATTACHED COMMENT LETTER. On behalf of the more than 140,000 members of the National Association of Home Builders of the United States (NAHB), I am pleased to submit comments on the Department of Labor's (DOL) Occupational Safety and Health Administration's (OSHA) Emergency Temporary Standard (ETS) on COVID–19 Vaccination and Testing that was published in the Federal Register on November 5, 2021 (86 Fed. Reg. 61,402) (Vaccination and Testing ETS). As an interested stakeholder in this regulatory activity, NAHB is concerned that the Vaccination and Testing ETS could have a significant impact on the residential construction industry (i.e., home building) and will affect the ability of our members to provide affordable housing in the country and push homeownership beyond the reach of thousands of Americans.

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Nov 18, 2021· Comment from Matuga, Robert; National Association of Home Builders (NAHB)· OSHA-2021-0007-0576

See attached letter. November 15, 2021 The Honorable Douglas L. Parker Assistant Secretary of Labor Occupational Safety and Health U.S. Department of Labor 200 Constitution Avenue, N.W. Washington, D.C. 20210 RE: Docket No. OSHA–2021–0007 [RIN 1218–AD42], COVID–19 Vaccination and Testing; Emergency Temporary Standard: Request for Extension of Comment Period Dear Assistant Secretary Parker: On behalf of the National Association of Home Builders of the United States (NAHB), I respectfully request a sixty (60) day extension of the current deadline for submitting written comments in response to the Occupational Safety and Health Administration's (OSHA) Emergency Temporary Standard (ETS) on COVID–19 Vaccination and Testing that was published in the Federal Register on November 5, 2021 (86 Fed. Reg. 61402). NAHB believes that providing only 30 days to submit comments to the ETS does not provide the residential construction industry adequate time to provide meaningful comments to OSHA. NAHB is a Washington, D.C.-based trade association whose members are involved in home building, remodeling, multifamily construction, property management, subcontracting, design, housing finance, building product manufacturing and other aspects of residential and light commercial construction. NAHB's builder members construct about 80 percent of the new housing units each year, making housing a large engine of economic growth nationally. NAHB believes that additional time is necessary to respond to this rulemaking for the following reasons: •The ETS requires thoughtful analysis on a number of wide-ranging issues in order to understand the possible ramifications. The 30-day comment period is not sufficient to review the 154-page rule and preamble, analyze it, and carefully review and discuss with NAHB's members including home builders and specialty trade contractors. The number of matters that must be considered and input obtained from NAHB's diverse membership cannot be completed in a short, 30-day comment period. •Because OSHA has elected to use the ETS process for this rule, the agency has not sought any input from impacted stakeholders. Section 6 of Executive Order 12866, Regulatory Planning and Review states: "…each agency should afford the public a meaningful opportunity to comment on any proposed regulation, which in most cases should include a comment period of not less than 60 days." (emphasis added) The very short 30-day comment period does not meet the spirit and intent of EO 12866 for seeking meaningful response from stakeholders. •The current comment period ends on December 5, 2021. Given where the comment period falls on the calendar shortly after a major federal government holiday—Thanksgiving—it will be extremely difficult to obtain important feedback from home builders. For these reasons, we believe an extension of time for submitting comments is necessary and appropriate. Offering meaningful comments on this ETS 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) 266-8507 if you have any questions or require any additional information. Regards, Robert Matuga cc: OSHA Docket Office

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Abstract

This docket is for a rule to protect workers from the grave danger of COVID-19 by strongly encouraging vaccination and limiting the presence of COVID-19 positive workers in the workplace through testing.

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COVID-19 Vaccination and Testing Emergency Temporary Standard Rulemaking (OSHA) — National Association of Home Builders | OpenPolis