Comment from Woeppel, Patrice; UAW, NWU, Local 1981

1. Toxic chemicals need to be classified and categorized for review by OSHA – NOT a review of chemicals one at a time, as is done now. 2. Regulate chemicals for toxicity at any point along the chain of manufacture, use and disposal. 3. Need to focus on alternatives to dangerous chemicals. 4. OSHA must begin to hold employers accountable to abate violations immediately upon discovery, not wait until after closure, the latter of which can take years. 5. Holistic thinking – tear down the wall between risks to workers and risks to community. 6. Focus on build-up of chemicals in the environment and impact thereof. 7. End of life (for a chemical) considerations - up front. 8. Development of safer products, chemical substitutions. 9. Re-examine who handles what, i.e., OSHA, EPA, Food and Drug Admin, Agriculture, etc. and how agencies work together to best accomplish the goals. One example of failure in this regard: the pathogenic sludge from feedlot cattle that ends up on soil and in rivers. 10. Meaningful fines, tort liability and criminal liability: Only when corporations are hit meaningfully in the pocketbook will meaningful change occur. Sources for some of the above: Geiser, K, Tickner, J., Torrie, Y. Reforming State-level chemicals management policies in the US: Status, Challenges and Opportunities. New Solutions, Vol. 19, No. 1, 2009, and Monforton, Celeste for 4. above. A conservatively estimated 50,000 - 60,000 deaths occur in our country each year due to occupational toxic chemical exposures and other occupational illnesses.(Leigh, et al, 2000; NIOSH; Steenland, et al, 2003). This is a disaster of monumental proportions that goes largely unrecorded. It is a major and costly labor issue – costly in lives, and costly in dollars. Finally, OSHA has an obligation to be responsible and honorable in the information that is presented to the public. The sum total of worker fatalities in 2008 was not 5214. That figure, devastating though it is, is the sum of the worker injury fatalities that were recorded to have occurred in that year; and does not include occupational illness fatalities, conservatively estimated to be ten times that number