Comment from Williams, Aaron; USDA

Document ID: OSHA-2010-0019-0017
Document Type: Public Submission
Agency: Occupational Safety And Health Administration
Received Date: June 27 2011, at 12:00 AM Eastern Daylight Time
Date Posted: June 28 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 22 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: September 20 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80eb4432
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I understand the need to have oversight of hospitalizations and amputations in order to effectively target. However, why not work with the OWCP and State Workers Compensation programs to get that data? That paperwork already exists, this is redundant reporting. By changing the reporting requirements would require re-training of all HR and Safety professional. Remember how difficult it was to define a “First Aid Only” injury? The same can be said for “in-patient hospitalizations” (4 hr stay for monitoring or overnight stay?) and “amputations” (e.g. would the tip of a finger count?). Also, you’ll need more employees at OSHA’s end to take calls, questions, and crunch all the incoming data into something useful for your accident investigators in the field. As a Federal employee myself (on the west coast) I know how exceedingly difficult it is to get someone in Washington DC on the phone. With the pending Federal budget cut-backs I don’t think this is a sustainable plan.

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