Comment Submitted by: Camille Villanova

This is in response to an OSHA proposal, in the Federal Register, Volume 72, Number 240, dated December 14, 2007, to delete the present incorporation of ANSI A10.3-1970 in 29 CFR Subpart P 1910.243(d) by direct final rule. Deletion by direct final rule will result in injury to employers, users, and by-standers. Many of the referenced standards have been updated by industry representatives, workers, the general public, and others in the nationally recognized consensus standards process utilized by ANSI. The industry and the consensus standards process must be recognized by OSHA as the most current safe practices. A responsible approach, following A-119, would be for OSHA to update the language of the consensus standard to the most current nationally recognized consensus standards. Camille Villanova