Comment from Zahm, Marilyn, none

I have been an administrative law judge with the Social Security Administration for the past seventeen years. I am sending this comment in my individual capacity. For all of the reasons outlined by Judge Mark A. Brown in his comment of April 12, 2011 (under tracking number 80c23156), changes need to be made the to new security regulation. Individuals who have made threats are not the only ones who pose a "reasonable threat to the safety of our employees and other participants in the hearing." Those who have a history of threats or violent behavior are equally as likely to pose a reasonable threat. Because the regulation should provide some specificity with regard to who may pose a threat, so as to provide guidance to both the Hearing Office Chief Administrative Law Judge as well as claimants and their representatives, I suggest the following change to the language of the regulation in section (b)(1): "The Hearing Office chief Administrative Law Judge will find that a claimant or other individual poses a reasonable threat to the safety of our employees or other participants in the hearing when he or she determines that the individual has made a current threat or has a past history of threats, assaults, weapons violations, or destruction of property." Further, I support Judge Brown's suggested change to section (b)(2).