Comment Submitted by: Thomas J O'Shea for Entek Engineering PLLC

Document ID: OSHA-2007-0062-0006
Document Type: Public Submission
Agency: Occupational Safety And Health Administration
Received Date: December 04 2007, at 02:09 PM Eastern Standard Time
Date Posted: December 4 2007, at 12:00 AM Eastern Standard Time
Comment Start Date: October 5 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: December 4 2007, at 11:59 PM Eastern Standard Time
Tracking Number: 8036ffef
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As a consultant in the field of facade maintenance and window washing for high rise buildings, I object to weakening this standard by reducing the required reporting, planning, and paperwork. It is important in this high risk work area to do everything possible to make Owners and building managers have proper and adequate records, training responsibilities, and emergency action plans, in order to keep their facilities standards compliant and safe. These proposed changes will dilute the responsibilities of these individuals. Thomas J O'Shea, Entek Engineering PLLC

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