Letter to Washington
| November 13, 2023

Coalition for Workplace Safety Comments to DOL on OSHA's Proposed Rulemaking Regarding the Worker Walkaround Representative Designation Process

These comments are submitted on behalf of the Coalition for Workplace Safety (“CWS”) and the 74 undersigned organizations (“the Commenters”), pursuant to the Occupational Safety and Health Administration’s Notice of Proposed Rulemaking regarding the Worker Walkaround Representative Designation Process under the OSH Act, 88 Fed. Reg. 59825 (Aug. 30, 2023) (“Proposed Rule”). For the reasons outlined below, the Commenters urge OSHA to withdraw the proposed rule entirely. OSHA should focus on its goal of promoting workplace safety, not labor organizing, and the Proposed Rule is more likely to interfere with OSHA inspections than enhance them. CWS comprises associations and employers focused on improving workplace safety through cooperation, assistance, transparency, clarity and accountability. CWS includes associations and employers across a range of sizes from very small businesses to larger companies.