Comment from Lyons, Timothy; Hawaii Business League

August 6, 2012 David Michaels, Ph.D., MPH Assistant Secretary of Labor Occupational Safety and Health U.S. Department of Labor 200 Constitution Ave. NW Washington, D.C. RE: Docket Number 2012-0029 Dear Secretary Michaels: Hawaii Business League is a small business organization composed of all types of businesses and from all islands in our state. Our membership is quite diverse and includes business that have frequent interaction with HIOSH such as contractors, various types of subcontractors, pest control operators, and auto mechanics as well as those that have infrequent interaction such as small retailers and offices. While, as might be expected, we are not always in agreement with HIOSH's enforcement measures and programmed efforts, we wish to, nevertheless, offer our comments towards our long standing preference for the continuation of a state program for Hawaii. To the best of our knowledge the program's problems have been due to the lack of resources as opposed to any inherent program defiency. This can be rectified and I believe that the Department's Director (Department of Labor and Industrial Relations) is on record affirming the administration's committment addressing and restoring the program to proper levels. We have long been on record in favor of a locally administered program finely tuned to local time zones, local customs and local interpretations as long as that customization results in a safety program that is as least as effective as a federal program. Please consider then our favorable support for your initial approval of the state plan as means to move forward towards the total restoration of Hawaii's 18 (e) status. Sincerely, Tim Lyons, CAE President Hawaii Business League 1188 Bishop Street Stes 1003-1004 Honolulu, Hawaii 96813 808-533-6819