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8/6/2019 Letter to Sunstein on WH Child Labor Proposed Rule
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August 15, 2011 SENT BY EMAIL TO:
Mr. Cass Sunstein
Director, Office of Information & Regulatory Affairs
The White House
Regarding: RIN 1235-AA06 - NPRM for Child Labor Regulations
Dear Mr. Sunstein:
We are writing to urge your office to complete its review of the Labor Department’s draft
proposed rule (RIN 1235-AA06) entitled " Child Labor Regulations, Orders, and Statements of Interpretation.” This proposal rule, which is not economically significant, was submitted to
OIRA for review more than nine months ago, on November 12, 2010. The time has long passed
for the public notice and comment period to begin on it.
Earlier this month, two 17-year-old boys, Bryce Gannon and Tyler Zander were seriously injured
while working at the Zaloudek Grain Co. in Kremlin, Oklahoma. Their legs were severed whileworking in a grain handling facility operating a large grain auger. Both will be permanently
disabled because of these injuries. Their families, friends and community members are
traumatized by this event as well. We understand that the Labor Department’s draft rule may
include proposed protections that could have prevented this incident from occurring. We hopethis terrible event and the hundreds of other incidents that injure and kill young workers every
year will compel you to release this draft proposal immediately and allow the Labor Department
to proceed with a public comment period.
Please have someone on your staff contact Tim Morse, PhD, CPE, chair of the OccupationalHealth & Safety Section, American Public Health Association at 860-679-4720 or
[email protected] by Friday, August 19, 2011 to let us know when your office’s review will be
completed and the NPRM will be released to allow the public comment process to begin.
Sincerely,
Mary E. Miller, RN, MN
Child Labor Specialist
Washington State
Celeste MonfortonProfessorial LecturerDept of Environmental & Occupational HealthSchool of Public Health & Health ServicesGeorge Washington University
Rick Engler, Director
New Jersey Work Environment Council
8/6/2019 Letter to Sunstein on WH Child Labor Proposed Rule
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On the web at www.njwec.org
142 West State Street - Third Floor
Trenton, New Jersey 08608
Karen B. Mulloy, DO, MSCH
Associate Professor,Colorado School of Public Health
Joel Shufro, Executive DirectorNew York Committee for Occupational Safety and Health (NYCOSH)
Jeanne Sears, PhD, RNSenior Research ScientistDepartment of Health Services &Center for Healthcare Improvement for Addictions, Mental Illnessand Medically Vulnerable Populations (CHAMMP)
University of Washington
Carol W. Runyan, MPH, PhDDirector, Injury Prevention Research CenterProfessor of Health Behavior and Health EducationProfessor of PediatricsUniversity of North Carolina
Paul Landsbergis, ScDAssociate ProfessorDepartment of Environmental and Occupational Health SciencesSchool of Public HealthState University of New York-Downstate Medical Center
Patty Quinlan, MPH, CIHIndustrial HygienistDivision of Occupational and Environmental MedicineUniversity of California San Francisco
Justin FeldmanWorker Health & Safety AdvocateCongress WatchPublic CitizenWashington, DC 20003
Shari Burgus, Education DirectorFarm Safety 4 Just Kids
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Jim Albers, MPH, CIHNational Institute for Occupational Safety and Health (NIOSH)
Craig Slatin, Sc.D., MPHProfessor, Department of Community Health and Sustainability
University of Massachusetts Lowell
Adam M. Finkel, Sc.D.Senior Fellow and Executive DirectorPenn Program on RegulationProfessor of Environmental and Occupational HealthUMDNJ School of Public Health
Tammy MiserFounder/Executive DirectorUnited Support & Memorial For Workplace Fatalities (USMWF)
Marychris RodriguezUnited Support & Memorial For Workplace Fatalities (USMWF)
Deborah SafronInstructor in SociologyMichigan State University
Michael D. SchulmanWilliam Neal Reynolds Distinguished ProfessorPresident-Elect: Rural Sociological Society
Dept of 4-H Youth Development & Family & Consumer Sciences and Dept of SociologyNorth Carolina State University
David H. WegmanProfessor EmeritusDepartment of Work EnvironmentUniversity of Massachusetts Lowell
Andrea Kidd Taylor, DrPH, MSPHLecturer, Morgan State University
School of Community Health & Policy
Marcy Goldstein-GelbExecutive DirectorMassCOSHMass. Coalition for Occupational Safety and Health
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Michael J. WrightDirector of Health, Safety & EnvironmentUnited SteelworkersPittsburgh, PA 15228
Rev. Stephen CopleyArkansas Committee on Occupational Safety and Health Committee
Lewis Pepper, MD, MPHBoston University School of Public HealthBoston, MA 02118
Barbara Rahke, DirectorPhilaposh (Philadelphia Area Project on Occupational Safety and Health)3001 Walnut Street, 5th FloorPhiladelphia, PA 19104
Beth Rosenberg, ScD, MPHAssistant ProfessorDept. Public Health & Community Medicine Tufts University School of Medicine
Sally Greenberg, Executive DirectorNational Consumers League
Reid Maki, CoordinatorChild Labor Coalition
Peter Dooley, MS, CIH, CSPLaborSafe Health and Safety ConsultingAnn Arbor, MI
Adrienne DerVartanianSenior Attorney/Policy AnalystFarmworker Justice
