Clarification on Submission of OSHA Post Hear Comments From Individual Departments
Hello Everyone,
I hope you are all doing well.
I have received some emails with questions about the submission of post hearing comments from individual departments for OSHA’s proposed Emergency Response Standard and I want to clarify any confusion.
Just like the comment period that ran from February 5 to July 22 we are asking individuals, departments and state associations to submit their own post hearing public comments. Just like the prior comment period, anyone can submit comments. The attached PDF, which you all were emailed last month, contains everything an individual would need to know to submit their post hearing comments, including a link of where to submit the comments. Here is that link in long form: https://www.regulations.gov/commenton/OSHA-2007-0073-4425.
I really need your help to share the attached PDF as widely as possible and to encourage the submission of public comments before the January 17 deadline.
My understanding is Joe Maruca has sent, or is going to send, an email to directors with best practices for state associations who’d like to collect comments from departments and submit them on their behalf.
The only post hearing public comments I am personally submitting to OSHA are the NVFC’s own post hearing comments and the NVFC’s own post hearing legal comments.
General FYI on Regulatory Process: Each time the public comment period on OSHA’s proposed Emergency Response Standard (ERS) has reopened or been extended I have received questions on where to submit public comments. Here is a good rule of thumb to assist. Across the Federal Government’s regulatory process each iteration of public comments on a specific proposed regulation, like the ERS, are submitted via the same docket. In the ERS’s case the docket number is OSHA-2007-0073. Almost all dockets relating to a proposed rule will have a webpage, like this one for the ERS. Generally, these docket webpages are one stop shopping for the proposed regulation. They contain searchable databases for all previous public comments submitted (sometimes there is a lag in comment submission and posting due to the review process) and all documents associated with the proposed regulation (press releases, hearing transcripts, committee/panel reports). They also contain links to text of the proposed regulation, and pertinent information regarding the proposed regulation like when it is open for comment. If a proposed regulation is open for comment there will usually be link to post these comment on the docket webpage. I understand that this isn’t intuitive if you don’t do it on a daily basis and that is why I email you this information when relevant. But I hope this information can help you anticipate where to find anything related to any proposed federal regulation going forward.
Ryan
Ryan Woodward
Chief of Legislative & Regulatory Affairs
National Volunteer Fire Council
712 H Street, NE, Ste. 1478
Washington, DC 20002
P: 202.887.5700
E: Ryan@nvfc.org