Comment from Bender, Corey; Virginia Dept of Labor and Industry

Please consider the terrible economy and the impact of citation penalties on all employers, big and small but especially small businesses. The mandate from Federal OSHA seems to be higher penalties but the employers I inspect are open to correcting violations after becoming educated about them but they worry that the penalties will put them out of business. In case you havent noticed many employers are on life support surviving week to week. I dont think the current penalty system calibrates the "hidden cost" of abatement. These employers, most of whom have good intentions but lack the complete knowledge to be in full compliance, have the cost of corrective action ontop of the penalties assessed. As a compliance inspector for a State Plan, I understand that Federal OSHA is putting pressure on the State Plans to increase their penalties. BAD move in my opinion and in reality, FED OSHA and all of OSHA should be looking at reducing penalties and factoring in the cost of abatement.