July 8, 1996
Joseph A. Dear
Assistant Secretary
Department of Labor
200 Constitution Avenue, N.W.
Washington, D.C. 20210
Dear Assistant Secretary:
Thank you for extending the deadline for comments on the Occupational Safety and Health Administration's proposed "Guidelines for Workplace Violence Prevention Programs for Night Retail Establishments." By changing the deadline to September 30, a more thoughtful review of this guidance will result.
We also appreciate your effort to expand the dissemination of this document by issuing a press release on its availability. Night retail establishments are predominantly small businesses, and we were concerned that many were not aware of the proposal. New obligations will result from this guidance, and the affected parties should have every opportunity to present comments.
Input from small businesses on this draft guidance should be particularly valuable for OSHA. If we can be of any assistance, please contact me or Anita Drummond of my staff at (202) 205- 6533.
Sincerely,
Jere W. Glover Chief
Counsel for Advocacy
June 27, 1996
Joseph A. Dear
Assistant Secretary
Department of Labor
200 Constitution Avenue, N.W.
Washington, D.C. 20210
Dear Assistant Secretary:
This letter is to request a meaningful extension of the deadline for public review of the Occupational Safety and Health Administration's proposed "Guidelines for Workplace Violence Prevention Programs for Night Retail Establishments." In addition, the Office of Advocacy recommends that the document be distributed more widely to the small business organizations.
The Directorate of Compliance Programs released the draft in April. It was mailed to some small business organizations and made available through the internet. Some affected parties only discovered it by chance. Because this document is such a significant initiative, it needs wide spread exposure before it is finalized. Moreover, while this document has potential benefits in the form of safer workplaces, it also has potential liabilities due to insufficient guidance. In addition, businesses that do not comply with the document are vulnerable to OSHA citations under the general duty clause. Because of these reasons, we believe the draft document should be distributed to a broader range of small business organizations for review, and the comment deadline should be extended.
If you agree to an extension, all stakeholders currently reviewing the document should be contacted immediately, so they can continue their review judiciously. We recommend an announcement about the availability of the proposed guidelines through a press release and other means. The Office of Advocacy will alert those on our list of associations contacts about its availability for review.
Please let me know if we can be of further assistance. If you or your staff have any questions, please contact me or Anita Drummond at (202) 205-6533. We look forward to your response.
Sincerely,
Jere W. Glover
Chief Counsel for Advocacy