Comment from Paul Kaplan, Keefe Kaplan Maritime, Inc.

Document ID: WCPO-2010-0003-0008
Document Type: Public Submission
Agency: Workers Compensation Programs Office
Received Date: October 18 2010, at 12:00 AM Eastern Daylight Time
Date Posted: November 1 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: October 15 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: November 17 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b721ea
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I am a partner in a company that provides service to vessels ranging from 20 to 100’. Our company, like most in the maritime industry has been significantly impacted by the frail economy we’ve been faced with since mid-2008. The community where we are located ranks amongst the highest in terms of unemployment for the entire county. We are writing to express our concerns and utter disappointment that certain legislation that was passed in 2009 intended to help our industry may be changed in such a way that it will negatively impact our business. As if it shouldn’t be necessary to say, but ANYTHING you or your colleagues can do to lessen the impact to our industry would be greatly appreciated. Our company has gone from nearly 60 employees to just over 30. In order to get any form of business in the door we’ve reduced the prices on every product and service we provide. This year has been worse than last year both in terms of volume and profitability. Every one of our employees is covered by our health plan as well as workman’s compensation insurance. We have a safety program that is designed to keep our employees healthy and productive. While we do work on some commercial vessels most of them are smaller and if we are required to provide the more expensive L&H coverage this will only translate into higher costs for our customers and lessen their ability to operate profitably. We request this matter not go forward as outlined and the exclusion of L&H from smaller vessels become implemented, as it is desperately needed. Thank you very much for your attention to this matter.

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