Notice of Intent to Appear from Novak, Catherine; Eastern Oil Company on behalf of the Independent Lubricant Manufacturers Association (ILMA)

This serves as a notice of intent for Catherine C. Novak to appear at the March 2, 2010 Informal Public Hearing regarding Docket Number OSHA-H022k-2006-0062 and to present testimony on behalf of the Independent Lubricant Manufacturers Association (ILMA). Requested Contact Information: Catherine C. Novak cnovak@easternoil.com Eastern Oil Company 590 S. Paddock Pontiac, MI 48341-3236 248/333-1333 Ms. Novak is the Metalworking Fluid Product Manager for Eastern Oil Company and the President of ILMA. Hearing Location: Washington, D.C. Time required at hearing: 10 minutes. Summary of Position on Proposed Rule and Issues to be Raised: 1) ILMA generally endorses the proposed rule; 2) ILMA believes the proposed rule's effective date must be tiered so that downstream substance formulators will have sufficient time to comply; and 3) With respect to lubricant manufacturing, ILMA believes that OSHA significantly underestimated costs to comply with the proposed rule. Summary of Documentary Evidence to be Presented: Summary discussion of ILMA's member survey regarding anticipated compliance tasks and associated expenses. Thank you for the opportunity to attend and present at the hearing.