Letter Requesting Extension for the Comment Period on OSHA's Advanced Notice of Proposed Rulemaking on Heat Injury and Illness Prevention
The Coalition for Workplace Safety (“CWS”) respectfully requests an extension to the comment period on the Occupational Safety and Health Administration’s (“OSHA”) Advanced Notice of Proposed Rulemaking (“ANPRM”), Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings, which was published in the Federal Register on October 27, 2021. CWS and many of its member associations intend to comment on the ANPRM. OSHA’s current comment period, however, poses challenges for stakeholders seeking to provide thoughtful, accurate responses to the numerous questions posed in the ANPRM. Consequently, while CWS appreciates OSHA’s extension to January 26th, we ask that you consider extending the comment period by an additional 30 days, through February 2022, to give stakeholders time to provide thoughtful responses to the ANPRM. CWS is a coalition of trade associations and companies focused on establishing reasonable and responsible workplace safety standards across the country. We base our efforts on five key principles – cooperation among all parties, assistance from OSHA to educate the employer community on workplace safety, transparency from OSHA on the data, science, and studies used to develop its safety regulations, clarity within safety regulations to best ensure compliance, and accountability among all stakeholders for their roles in protecting the workforce.