Public Comment Submitted by Norbert Dickmann

June 11, 2007 To: OSHA Docket Office Docket No. OSHA-2007-0003 U.S. Department of Labor Room N-2625 200 Constitution Avenue, NW. Washington, DC 20210 By Fax @ (202) 693-1648 From: Norb Dickmann Manager of EHS Services Energy Conversion Systems Dunn, NC 28334 Please consider these comments about section 1910.217(g) of the Mechanical Power Press standard, which requires employers to report within 30 days, in writing, to OSHA any point of operation injury to operators or other employees. Should OSHA eliminate this requirement? OSHA should eliminate this inconsistent, exceptional reporting requirement for injuries involving mechanical power presses. 1) Mechanical power presses are the only type of equipment or operation singled out by OSHA for a special injury reporting procedure. Why are injuries associated with mechanical power presses more interesting to OSHA than injuries associated with band saws, lawn mowers, motor vehicles or grinders? There doesn?t seem to be a reason to single out mechanical power presses. 2) The injury reporting requirement in the Mechanical Power Press standard is inconsistent with the OSHA recordkeeping and reporting standard found in Part 1904, Recording and Reporting Occupational Injuries and Illness. According to Part 1904, workplace injuries must be recorded on the OSHA 300 Log of occupational injuries and illnesses. Injuries are required to be reported directly to OSHA at the time of the injury only when the accident results in a fatality or multiple hospitalizations. This is true for every type of workplace injury, except injuries incurred while working with a mechanical power press. Why maintain an inconsistent, exceptional injury reporting requirement for mechanical power presses? 3) This inconsistency can easily result in inadvertent failures to report, by employers who rely on the plain language of Part 1904 (and associated guidance documents published by OSHA). Please refer, for example, to the OSHA Recordkeeping Handbook meant by OSHA to cover ?The Regulation and Related Interpretations for Recording and Reporting Occupational Injuries and Illnesses?. Also refer to OSHA?s Recordkeeping Policies and Procedures Manual (CPL 02-00- 135). Neither that handbook nor that manual reference the injury reporting requirement found in the Mechanical Power Press standard. If there is some over- riding reason to maintain an inconsistent reporting regulation for mechanical power presses, OSHA should at least make reference to it in Part 104 and in OSHA guidance documents. 4) I have asked OSHA and NCOSH representatives on several occasions whether they actually compile statistics or other information from any mechanical power press injury reports that have been submitted. They tell me that they do not. OSHA should only continue this exceptional reporting requirement if there is a clear intention to use the information for something useful. If OSHA decides to continue this exceptional reporting requirement, please describe in the preamble to the final rule how that information will be compiled and used. 5) About 15 years ago, I called OSHA and found a long-time employee who was involved in the original development of the Mechanical Power Press standard. He told me that the reporting requirement in this standard was an artifact from the influence of a faction within OSHA in the 1970s who wanted all injuries to be reported in writing to OSHA within 30 days. The reporting requirement for mechanical power presses was not meant to be exceptional (because of special concerns about mechanical power presses) ? all injuries were meant to be similarly reported (at least according to the individuals who inserted this language into this standard). OSHA decided long ago to follow a different direction for injury recording and reporting. It?s long past time to eliminate this artifact. Norb Dickmann, Energy Conversion Systems, fax also received