Remarks by Tim Hammonds, President and CEO, Food Marketing Institute, Informal Hearing on OSHA Docket No. S-777, Ergonomics Program Standard, U.S. Department of Labor, Washington, DC My name is Tim Hammonds and I am President and CEO of the Food Marketing Institute. I am here today to express the strong opposition of our members — our nation’s food retailers and wholesalers — to the proposed ergonomics program standard. FMI’s domestic member companies operate approximately 21,000 retail food stores with combined annual sales of $300 billion. More than half of our members own just one store. The grocery industry is an integral part of every community in the country, providing our nation’s consumers with a wide variety of safe and nutritious foods at the lowest possible prices. It employs more than 3.5 million Americans, providing them and their families with safe, good-paying, high-quality jobs that contribute to the well-being of towns and cities throughout the country. Our members are committed to providing a safe and healthy work environment for their employees and customers and they are continually striving to improve all aspects of the workplace. The reaction of FMI’s members to this proposal has been unprecedented. More than 500 food retailers and wholesalers and their state associations have filed comments in this docket, condemning the proposed rule. This reaction, I think, is based on two fundamental concerns. First, the proposal just doesn’t make sense to them. They are outraged that OSHA would propose one of the most complex and costly regulations ever conceived when the injuries addressed are already being reduced at a faster rate than the rule would bring about, according to agency’s own projections. However, if this rule is implemented, perhaps OSHA’s projected rate would be right after all. We believe diverting resources to deal with the mountain of bureaucratic red tape created by this regulation would dramatically slow the rate of progress food distributors are already making voluntarily. The second factor that has led to our industry’s massive response to this proposal is sheer frustration over its vagueness. The food industry is already highly regulated. Our members are used to complying with comprehensive and complicated regulatory schemes at the federal, state and local levels. These include rules governing food safety, labeling, wage and hour limits and many other practices. In all these instances, our members can understand the specific requirements of the rule and know how to comply. But not with this proposed standard. Almost every provision of the proposal leaves room for doubt and argument. I refer you to FMI’s written comments for many of the specifics on the vagueness of the rule. But the most fundamental problem is the requirement that employers “fix” jobs so that MSDs are eliminated. If another MSD occurs in that job category, further changes must be made. The result will be a never-ending cycle of activity aimed at achieving a mythical, perfect environment. This is completely unreasonable. It leaves our members in the untenable position of striving for perfection in an imperfect world. We are convinced that if this proposed rule is adopted, it will dramatically change the way food and grocery products are distributed to consumers. These changes would cost jobs, reduce customer service and increase consumer prices. OSHA’s Own Figures Document the Prohibitive Cost of Compliance Turning now to the cost issues, OSHA’s estimated compliance costs for grocery retailers and wholesalers are grossly unreliable and incomplete. They reflect a complete lack of understanding of the real-world consequences of this proposal. We believe they are so inadequate that any neutral observer would question the credibility of OSHA’s overall conclusions. OSHA estimates that the total first-year costs will be approximately $334 million for grocery stores and $158 million for grocery wholesalers. Then it estimates that the annual ongoing costs will be $195 million for stores and $73 million for wholesalers. Even these costs — though vastly underestimated — would have a huge impact on the industry and our nation’s shoppers. Grocery retailing is a highly competitive, low-margin business with net, after-tax profits of a little more than a penny on the dollar. In other words, for every dollar of sales, the store makes one penny. In order to recoup $300 million in costs, the grocery industry would have to sell an additional $30 billion of groceries — or raise prices to cover the increased costs. If OSHA truly believes that this level of cost could simply be absorbed, the agency lacks any real understanding of a competitive economy. In reality, the effect on food distribution would be much greater. The short comment period has prevented us from doing an in-depth analysis of OSHA’s estimates because the industry-specific information is not published in the Federal Register. Instead, it is buried in the 55,000 pages of supporting material in the docket, which have not been available to FMI members. Even a cursory review, however, reveals serious flaws in OSHA’s methods and conclusions. For example, OSHA estimates that of the 130,000 grocery stores in the country only 30,000 have manual-handling jobs and only 75,000 would be covered in the first year. How can that be? Every single grocery store in the country has jobs that involve manual handling as the proposal defines it. Under the proposal, every employer with manual-handling jobs must immediately comply with the regulation, so clearly every grocery store will be covered. Thus, the estimated first year costs need to be increased to reflect the additional 55,000 stores that would be covered. Based on OSHA’s cost estimates, an additional 55,000 stores would increase the first-year estimates alone by $245 million — bringing the total implementation cost to $579 million. This figure puts the increased cost to consumers in the $60 billion range. Similarly, OSHA concludes that only three-quarters of grocery warehouses have manual-handling jobs. Since grocery warehouses are in the business of handling cases of products, it is hard to imagine how any would not be covered by the rule. Frankly, we believe that OSHA’s failure to recognize that this rule will affect every food distribution business raises serious questions about the quality of the agency’s analysis. The True Cost of Compliance In addition to the failure to appreciate just who will be covered by the rule, OSHA’s cost estimates are equally flawed. To determine the true cost of implementing this regulation, FMI asked a member company that operates 12 distribution centers to estimate the cost to bring its facilities into compliance with the proposed standard. The company estimated that its worst-case costs would be $518,140,000; under the best-case, costs would be $129,200,000. Thus, the true cost for a single company to comply with this rule is comparable to OSHA’s estimate for the entire industry. Moreover, this company estimated that operating under the proposed rule would reduce productivity by 25 percent and would severely impact customer service. Compliance Costs Would Devastate Small, Family-Owned Supermarkets The cost burden on small family-owned supermarkets will be particularly devastating. As mentioned above, retail grocery stores typically operate on a profit margin of about 1 percent. Small companies must be particularly efficient, cost-effective and customer-friendly to compete successfully. OSHA estimates that 31,000 small firms in the grocery industry will be “affected” by the rule. 64 Fed. Reg. at 66024 (Table VIII-5). For the reasons previously noted, we believe this is a gross underestimate of the scope of this rule; they would all be affected. OSHA estimates that the annual costs of the proposed standard for those 31,000 grocery stores will be 35.70 percent of their profits. In other words, on average, more than one-third of these small stores’ profits will be consumed by compliance costs. If that is the average, more than half of these 31,000 stores will suffer even greater losses. This astonishing statistic is OSHA’s own, and apparently it has been dismissed as unimportant. In reality, these costs would mean that many family-owned grocery stores would be forced to close their doors as a direct result of this rule. The result will be less competition, fewer shopping choices for consumers and lost jobs. FMI has received copies of numerous comment letters filed with OSHA from independently owned supermarkets throughout the country concerned about the cost impact and what it will mean for the future of their businesses and their customers. We strongly urge that OSHA more closely consider the impact this regulation will have on these businesses, their employees and the communities they serve. The Job ‘Fixes’ Are Out of Touch With Reality The most significant compliance costs will come from the ergonomic job interventions or job “fixes.” While we have trouble understanding exactly how these costs have been estimated, it appears that OSHA and its consultants have arbitrarily determined an average cost for job interventions for specific occupational groups and then in some fashion converted those costs into industry totals. It is obvious that the estimates for job “fixes” in our industry bear little relationship to reality. Because just about every single job in grocery retailing and wholesaling involves risk factors, we believe every job will need to be “fixed.” And the jobs will need to be “fixed” repeatedly because there is almost no likelihood that MSDs, as defined by OSHA, will be completely eliminated in any job category. Therefore, OSHA’s cost estimates, which are based on one “fix” per problem job, are in reality ongoing costs that would need to be multiplied many times over, year after year. In estimating the costs of job “fixes”, OSHA relies on the cost estimates and productivity effects of scenarios described in its chapter on Technological Feasibility. Although OSHA’s Expert Ergonomics Panel believes those scenarios would overstate costs and understate labor savings, our review of the scenarios that apply to the food distribution industry leads us to exactly the opposite conclusion. The costs are ludicrously underestimated and the savings are a fantasy. The suggestions in some cases are totally impractical. Scenario No. MH-69 addresses baggers in grocery stores. OSHA suggests two controls to reduce MSD hazards: raise the bagging stand and limit the weight of bags to 15 pounds. The scenario suggests each control would cost $50 — for a total of $100 per checkstand. There are approximately 300,000 checkstands in supermarkets around the nation. Assuming that OSHA’s cost estimates are accurate, the industrywide costs would be $30 million simply for these two controls for one job category. Although it’s not specified in the scenario, we hope this cost estimate includes the installation of new scales at the bagging stations of all 300,000 checkstands because that would be required for compliance. The scenario estimates that these changes would increase worker productivity by 7.5 percent because of reduced fatigue. This number is naively optimistic, and it is impossible to determine how it was developed. In reality, the 15-pound weight limit on bags would reduce productivity considerably which would slow customer service in turn. A Regulatory Dilemma: How to Pack a 20 lb. Turkey in a 15 lb. Bag How would these changes affect consumers? Will lines slow down as baggers weigh items as they go into bags? Will alarms go off when bags get too heavy? How much time will it take to unload overweight bags, and how much will that slow down the speed of checkout lines? What will baggers do with a 20-pound turkey or a 30-pound box of cat litter? We believe some stores would conclude that the lost efficiency, the hassle and the potential for fines would not be worth it, and they would have customers bag their own groceries. If you remember the furor over OSHA’s proposal to inspect in-home offices, you can imagine what will happen when shoppers find out they now have to bag their own groceries because of yet another ill-conceived OSHA regulation. Should you consider this analysis speculative, FMI requested specific feedback from our member companies on MH-69. Following is one typical response: “It’s likely [that] raising the bag stand would require raising the entire checkstand, which would not be favorable to the customer, nor would this comply with the ADA (Americans with Disabilities Act). Since the product is gravity-fed to the bagging accumulation area, it would be necessary to raise the front belt. The front belt is at a comfortable height for the customer at the present time. Replacement of the checkstand would likely be necessary. The estimated cost per workstation is understated. If replacement is required, the cost could be as much as $3,000 per workstation plus installation costs.” (Emphasis added) Let’s take another example, Scenario No. MH-71 for front-end checkers in food stores. It also suggests two controls to reduce MSD hazards — one to raise checkstands and place keyboards on adjustable pedestals, and the other to install adjustable grocery bag wells. OSHA suggests the first control will cost $500 and the second $250 — for a total of $750 per checkstand. Again assuming for sake of argument that these estimates are accurate, the total industry cost for these modifications would be $225 million (300,000 checkstands times $750). Together with the controls suggested in the bagging scenario, the total industry costs for these so-called “modest” changes to checkstands are $255 million. Remember, that OSHA estimates total grocery store compliance costs for the entire rule to be only $195 million per year. Beyond the costs, these changes might not even be feasible in the real world. How would raising checkstands affect our customers, especially disabled individuals? The ADA requires that counters be accessible to customers in wheelchairs. Would these modifications run afoul of the ADA? Taking yet another example, Scenario No. MH-29 would limit the forceful exertions of selectors in grocery warehouses by replacing heavy wooden pallets with lightweight composite or plastic ones. One FMI member company that made that change in 1996-97 found that it increased MSD injuries. The company discovered that plastic pallets do not offer the traction of wood pallets. As a result, cases tend to slip off the pallets causing increased repetition and risk factors as cases have to be restacked. Pallet jack operators tend to look back at their load more often while moving because of reduced stability, and this causes more accidents. In one case an operator lost five toes because of such an accident. Water tends to accumulate in the plastic pedestals, causing water to accumulate on the floor, resulting in additional accidents. Additional engineering controls were required to dry the pallets. Increased food debris from the plastic resulted in particulate matter getting into operators’ eyes. Operators’ hands were cut more frequently by the plastic pallets. Wood pallet repair technician jobs were eliminated. Drivers were forced to restack pallets because of the instability leading to a significant increase in shoulder, elbow and back injuries. Conclusion The examples presented here are typical illustrations of OSHA’s lack of understanding of the consequences of this proposed regulation. A realistic analysis of this rule would likely produce results similar to the ones cited in my remarks for every single proposal. Taken to its logical conclusion, this proposed regulation would require the complete revamping of our nation’s grocery distribution system. A study done for the Food Distributors International (FDI) estimates that the cost to restructure its wholesaler members’ distribution centers could be as much as $26 billion. The cost to remodel the distribution centers run by supermarket chains and the stores themselves would be far greater. And the costs to consumers would be intolerable. In sum, compliance with this proposed rule is not feasible for our industry or for our nation’s consumers who would pay most dearly for OSHA’s costly mistake. For all of the reasons presented in our testimony, we believe the only sensible course for the agency is to withdraw this proposal just as it withdrew the equally ill-conceived but far less costly proposal to inspect home offices. Thank you for the opportunity to present our views.
Remarks by Tim Hammonds, President and CEO, Food Marketing Institute, Informal Hearing on OSHA Docket No. S-777, Ergonomics Program Standard, U.S. Department of Labor, Washington, DC
My name is Tim Hammonds and I am President and CEO of the Food Marketing Institute. I am here today to express the strong opposition of our members — our nation’s food retailers and wholesalers — to the proposed ergonomics program standard. FMI’s domestic member companies operate approximately 21,000 retail food stores with combined annual sales of $300 billion. More than half of our members own just one store.
The grocery industry is an integral part of every community in the country, providing our nation’s consumers with a wide variety of safe and nutritious foods at the lowest possible prices. It employs more than 3.5 million Americans, providing them and their families with safe, good-paying, high-quality jobs that contribute to the well-being of towns and cities throughout the country. Our members are committed to providing a safe and healthy work environment for their employees and customers and they are continually striving to improve all aspects of the workplace.
The reaction of FMI’s members to this proposal has been unprecedented. More than 500 food retailers and wholesalers and their state associations have filed comments in this docket, condemning the proposed rule. This reaction, I think, is based on two fundamental concerns.
First, the proposal just doesn’t make sense to them. They are outraged that OSHA would propose one of the most complex and costly regulations ever conceived when the injuries addressed are already being reduced at a faster rate than the rule would bring about, according to agency’s own projections. However, if this rule is implemented, perhaps OSHA’s projected rate would be right after all. We believe diverting resources to deal with the mountain of bureaucratic red tape created by this regulation would dramatically slow the rate of progress food distributors are already making voluntarily.
The second factor that has led to our industry’s massive response to this proposal is sheer frustration over its vagueness. The food industry is already highly regulated. Our members are used to complying with comprehensive and complicated regulatory schemes at the federal, state and local levels. These include rules governing food safety, labeling, wage and hour limits and many other practices. In all these instances, our members can understand the specific requirements of the rule and know how to comply.
But not with this proposed standard. Almost every provision of the proposal leaves room for doubt and argument. I refer you to FMI’s written comments for many of the specifics on the vagueness of the rule. But the most fundamental problem is the requirement that employers “fix” jobs so that MSDs are eliminated. If another MSD occurs in that job category, further changes must be made. The result will be a never-ending cycle of activity aimed at achieving a mythical, perfect environment. This is completely unreasonable. It leaves our members in the untenable position of striving for perfection in an imperfect world.
We are convinced that if this proposed rule is adopted, it will dramatically change the way food and grocery products are distributed to consumers. These changes would cost jobs, reduce customer service and increase consumer prices.
OSHA’s Own Figures Document the Prohibitive Cost of Compliance Turning now to the cost issues, OSHA’s estimated compliance costs for grocery retailers and wholesalers are grossly unreliable and incomplete. They reflect a complete lack of understanding of the real-world consequences of this proposal. We believe they are so inadequate that any neutral observer would question the credibility of OSHA’s overall conclusions.
OSHA estimates that the total first-year costs will be approximately $334 million for grocery stores and $158 million for grocery wholesalers. Then it estimates that the annual ongoing costs will be $195 million for stores and $73 million for wholesalers. Even these costs — though vastly underestimated — would have a huge impact on the industry and our nation’s shoppers. Grocery retailing is a highly competitive, low-margin business with net, after-tax profits of a little more than a penny on the dollar. In other words, for every dollar of sales, the store makes one penny. In order to recoup $300 million in costs, the grocery industry would have to sell an additional $30 billion of groceries — or raise prices to cover the increased costs. If OSHA truly believes that this level of cost could simply be absorbed, the agency lacks any real understanding of a competitive economy.
In reality, the effect on food distribution would be much greater. The short comment period has prevented us from doing an in-depth analysis of OSHA’s estimates because the industry-specific information is not published in the Federal Register. Instead, it is buried in the 55,000 pages of supporting material in the docket, which have not been available to FMI members. Even a cursory review, however, reveals serious flaws in OSHA’s methods and conclusions.
For example, OSHA estimates that of the 130,000 grocery stores in the country only 30,000 have manual-handling jobs and only 75,000 would be covered in the first year. How can that be? Every single grocery store in the country has jobs that involve manual handling as the proposal defines it. Under the proposal, every employer with manual-handling jobs must immediately comply with the regulation, so clearly every grocery store will be covered. Thus, the estimated first year costs need to be increased to reflect the additional 55,000 stores that would be covered. Based on OSHA’s cost estimates, an additional 55,000 stores would increase the first-year estimates alone by $245 million — bringing the total implementation cost to $579 million. This figure puts the increased cost to consumers in the $60 billion range.
Similarly, OSHA concludes that only three-quarters of grocery warehouses have manual-handling jobs. Since grocery warehouses are in the business of handling cases of products, it is hard to imagine how any would not be covered by the rule. Frankly, we believe that OSHA’s failure to recognize that this rule will affect every food distribution business raises serious questions about the quality of the agency’s analysis.
The True Cost of Compliance In addition to the failure to appreciate just who will be covered by the rule, OSHA’s cost estimates are equally flawed. To determine the true cost of implementing this regulation, FMI asked a member company that operates 12 distribution centers to estimate the cost to bring its facilities into compliance with the proposed standard. The company estimated that its worst-case costs would be $518,140,000; under the best-case, costs would be $129,200,000. Thus, the true cost for a single company to comply with this rule is comparable to OSHA’s estimate for the entire industry.
Moreover, this company estimated that operating under the proposed rule would reduce productivity by 25 percent and would severely impact customer service.
Compliance Costs Would Devastate Small, Family-Owned Supermarkets The cost burden on small family-owned supermarkets will be particularly devastating. As mentioned above, retail grocery stores typically operate on a profit margin of about 1 percent. Small companies must be particularly efficient, cost-effective and customer-friendly to compete successfully. OSHA estimates that 31,000 small firms in the grocery industry will be “affected” by the rule. 64 Fed. Reg. at 66024 (Table VIII-5). For the reasons previously noted, we believe this is a gross underestimate of the scope of this rule; they would all be affected. OSHA estimates that the annual costs of the proposed standard for those 31,000 grocery stores will be 35.70 percent of their profits. In other words, on average, more than one-third of these small stores’ profits will be consumed by compliance costs. If that is the average, more than half of these 31,000 stores will suffer even greater losses. This astonishing statistic is OSHA’s own, and apparently it has been dismissed as unimportant. In reality, these costs would mean that many family-owned grocery stores would be forced to close their doors as a direct result of this rule. The result will be less competition, fewer shopping choices for consumers and lost jobs.
FMI has received copies of numerous comment letters filed with OSHA from independently owned supermarkets throughout the country concerned about the cost impact and what it will mean for the future of their businesses and their customers. We strongly urge that OSHA more closely consider the impact this regulation will have on these businesses, their employees and the communities they serve.
The Job ‘Fixes’ Are Out of Touch With Reality The most significant compliance costs will come from the ergonomic job interventions or job “fixes.” While we have trouble understanding exactly how these costs have been estimated, it appears that OSHA and its consultants have arbitrarily determined an average cost for job interventions for specific occupational groups and then in some fashion converted those costs into industry totals.
It is obvious that the estimates for job “fixes” in our industry bear little relationship to reality. Because just about every single job in grocery retailing and wholesaling involves risk factors, we believe every job will need to be “fixed.” And the jobs will need to be “fixed” repeatedly because there is almost no likelihood that MSDs, as defined by OSHA, will be completely eliminated in any job category. Therefore, OSHA’s cost estimates, which are based on one “fix” per problem job, are in reality ongoing costs that would need to be multiplied many times over, year after year.
In estimating the costs of job “fixes”, OSHA relies on the cost estimates and productivity effects of scenarios described in its chapter on Technological Feasibility. Although OSHA’s Expert Ergonomics Panel believes those scenarios would overstate costs and understate labor savings, our review of the scenarios that apply to the food distribution industry leads us to exactly the opposite conclusion. The costs are ludicrously underestimated and the savings are a fantasy. The suggestions in some cases are totally impractical.
Scenario No. MH-69 addresses baggers in grocery stores. OSHA suggests two controls to reduce MSD hazards: raise the bagging stand and limit the weight of bags to 15 pounds. The scenario suggests each control would cost $50 — for a total of $100 per checkstand. There are approximately 300,000 checkstands in supermarkets around the nation. Assuming that OSHA’s cost estimates are accurate, the industrywide costs would be $30 million simply for these two controls for one job category. Although it’s not specified in the scenario, we hope this cost estimate includes the installation of new scales at the bagging stations of all 300,000 checkstands because that would be required for compliance.
The scenario estimates that these changes would increase worker productivity by 7.5 percent because of reduced fatigue. This number is naively optimistic, and it is impossible to determine how it was developed. In reality, the 15-pound weight limit on bags would reduce productivity considerably which would slow customer service in turn.
A Regulatory Dilemma: How to Pack a 20 lb. Turkey in a 15 lb. Bag How would these changes affect consumers? Will lines slow down as baggers weigh items as they go into bags? Will alarms go off when bags get too heavy? How much time will it take to unload overweight bags, and how much will that slow down the speed of checkout lines? What will baggers do with a 20-pound turkey or a 30-pound box of cat litter? We believe some stores would conclude that the lost efficiency, the hassle and the potential for fines would not be worth it, and they would have customers bag their own groceries.
If you remember the furor over OSHA’s proposal to inspect in-home offices, you can imagine what will happen when shoppers find out they now have to bag their own groceries because of yet another ill-conceived OSHA regulation.
Should you consider this analysis speculative, FMI requested specific feedback from our member companies on MH-69. Following is one typical response:
“It’s likely [that] raising the bag stand would require raising the entire checkstand, which would not be favorable to the customer, nor would this comply with the ADA (Americans with Disabilities Act). Since the product is gravity-fed to the bagging accumulation area, it would be necessary to raise the front belt. The front belt is at a comfortable height for the customer at the present time. Replacement of the checkstand would likely be necessary. The estimated cost per workstation is understated. If replacement is required, the cost could be as much as $3,000 per workstation plus installation costs.” (Emphasis added)
Let’s take another example, Scenario No. MH-71 for front-end checkers in food stores. It also suggests two controls to reduce MSD hazards — one to raise checkstands and place keyboards on adjustable pedestals, and the other to install adjustable grocery bag wells. OSHA suggests the first control will cost $500 and the second $250 — for a total of $750 per checkstand. Again assuming for sake of argument that these estimates are accurate, the total industry cost for these modifications would be $225 million (300,000 checkstands times $750). Together with the controls suggested in the bagging scenario, the total industry costs for these so-called “modest” changes to checkstands are $255 million. Remember, that OSHA estimates total grocery store compliance costs for the entire rule to be only $195 million per year. Beyond the costs, these changes might not even be feasible in the real world. How would raising checkstands affect our customers, especially disabled individuals? The ADA requires that counters be accessible to customers in wheelchairs. Would these modifications run afoul of the ADA?
Taking yet another example, Scenario No. MH-29 would limit the forceful exertions of selectors in grocery warehouses by replacing heavy wooden pallets with lightweight composite or plastic ones. One FMI member company that made that change in 1996-97 found that it increased MSD injuries.
The company discovered that plastic pallets do not offer the traction of wood pallets. As a result, cases tend to slip off the pallets causing increased repetition and risk factors as cases have to be restacked. Pallet jack operators tend to look back at their load more often while moving because of reduced stability, and this causes more accidents. In one case an operator lost five toes because of such an accident.
Water tends to accumulate in the plastic pedestals, causing water to accumulate on the floor, resulting in additional accidents. Additional engineering controls were required to dry the pallets. Increased food debris from the plastic resulted in particulate matter getting into operators’ eyes. Operators’ hands were cut more frequently by the plastic pallets. Wood pallet repair technician jobs were eliminated. Drivers were forced to restack pallets because of the instability leading to a significant increase in shoulder, elbow and back injuries.
Conclusion The examples presented here are typical illustrations of OSHA’s lack of understanding of the consequences of this proposed regulation. A realistic analysis of this rule would likely produce results similar to the ones cited in my remarks for every single proposal.
Taken to its logical conclusion, this proposed regulation would require the complete revamping of our nation’s grocery distribution system. A study done for the Food Distributors International (FDI) estimates that the cost to restructure its wholesaler members’ distribution centers could be as much as $26 billion. The cost to remodel the distribution centers run by supermarket chains and the stores themselves would be far greater. And the costs to consumers would be intolerable. In sum, compliance with this proposed rule is not feasible for our industry or for our nation’s consumers who would pay most dearly for OSHA’s costly mistake.
For all of the reasons presented in our testimony, we believe the only sensible course for the agency is to withdraw this proposal just as it withdrew the equally ill-conceived but far less costly proposal to inspect home offices.
Thank you for the opportunity to present our views.
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