Comment submitted by Bill Watson, Signs Manufacturing Corporation

Document ID: EPA-HQ-OAR-2005-0526-0052
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: October 02 2007, at 12:34 PM Eastern Daylight Time
Date Posted: October 3 2007, at 12:00 AM Eastern Standard Time
Comment Start Date: September 17 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: November 1 2007, at 11:59 PM Eastern Standard Time
Tracking Number: 802f4473
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Sign manufacturers with a classification of 33995 print on paper, cardboard, and other materials, make rubber stamps, letter materials with computer-cut self- adhesive tapes, paint wooden signs with household latex paint, make and apply graphics to race cars and trucks, etc. As a sign manufacturer making electric signs we manufacture using virgin materials; we do not refinish. Many of our materials are prefinished. Of the approximately 40 people who work here, 1 paints part-time. We have machine operators, design personnel, assemblers, maintenance, installers, janitorial, office, etc. Relatively little painting is done in the sign industry any more. Also, sign companies such as us hire many temporary and part-time people. For instance, when Southwestern Bell changed its name to AT&T the industry needed many more people, temporarily. Are these people going to have to be trained before they can work for us for a month or two? If this rule is good when applied to automobile refinishers, apply it to automobile refinishers. Write a specific rule that applies to sign companies; please don't turn us into automobile refinishers! If everyone but office personnel are going to have to be trained in the use of a product we do not use, this rule is punative.

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