Comment from Miller, Todd; 56377

Like so many rules, it state what should happen but does not provide any means of readress if it doesn't. For example, what happens if the Assistant Secretary fails to meet the 60 day deadline. What happens if a party doesn't abide by the 15 day notice provision. OSHA has been severely criticized for having administrators who allow misjudgements about the validity of cases. The procedure again, has no means for a person to address such misjudgements or misperceptions. That is, the problem is OSHA operates under the false assumption that it's always right when history proves it's usually been wrong. The only way that will change is if you have a process that includes self-correction and correction by others when procedures fail, misunderstandings occur etc. ... OSHA should treat itself as if it is delivering a product as CPSIA with the same sort of self-correcting mechanisms that corporations are required to have as well as a regulatory administrators that make sure that OSHA is playing by its own rules. This idea of an honor system in this day and age is absurd.