Letter to Sunstein WH

8/6/2019 Letter to Sunstein WH

http://slidepdf.com/reader/full/letter-to-sunstein-wh 1/4

August 15, 2011 SENT BY EMAIL TO:[email protected]

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 passedfor 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 aretraumatized 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 Departmentto proceed with a public comment period.

Please have someone on your staff contact Tim Morse, PhD, CPE, chair of the Occupational

Health & 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,

[See attached list;

affiliations listed for identification purposes only]

Mary E. Miller, RN, MN

Child Labor SpecialistWashington State

Celeste Monforton

Professorial Lecturer Dept of Environmental & Occupational Health

School of Public Health & Health ServicesGeorge Washington University



Rick Engler, Director

New Jersey Work Environment Council

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 Director New York Committee for Occupational Safety and Health (NYCOSH)

Jeanne Sears, PhD, RN

Senior Research ScientistDepartment of Health Services &

Center for Healthcare Improvement for Addictions, Mental Illnessand Medically Vulnerable Populations (CHAMMP)

University of Washington

Carol W. Runyan, MPH, PhD

Director, Injury Prevention Research Center Professor of Health Behavior and Health Education

Professor of PediatricsUniversity of North Carolina

Paul Landsbergis, ScD

Associate Professor Department of Environmental and Occupational Health Sciences

School of Public HealthState University of New York-Downstate Medical Center

Patty Quinlan, MPH, CIH

Industrial HygienistDivision of Occupational and Environmental Medicine

University of California San Francisco

Justin Feldman

Worker Health & Safety AdvocateCongress Watch

Public CitizenWashington, DC 20003



Shari Burgus, Education Director Farm Safety 4 Just Kids

Jim Albers, MPH, CIH

National 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 Director

Penn Program on RegulationProfessor of Environmental and Occupational Health

UMDNJ School of Public Health

Tammy Miser Founder/Executive Director

United Support & Memorial For Workplace Fatalities (USMWF)

Marychris RodriguezUnited Support & Memorial For Workplace Fatalities (USMWF)

Deborah Safron

Instructor in SociologyMichigan State University

Michael D. Schulman

William Neal Reynolds Distinguished Professor President-Elect: Rural Sociological Society

Dept of 4-H Youth Development & Family & Consumer Sciences and Dept of Sociology North Carolina State University

David H. Wegman

Professor EmeritusDepartment of Work Environment

University of Massachusetts Lowell

Andrea Kidd Taylor, DrPH, MSPH

Lecturer, Morgan State UniversitySchool of Community Health & Policy

Marcy Goldstein-Gelb

Executive Director MassCOSH

Mass. Coalition for Occupational Safety and Health



Michael J. WrightDirector of Health, Safety & Environment

United SteelworkersPittsburgh, PA 15228

Rev. Stephen CopleyArkansas Committee on Occupational Safety and Health Committee

Lewis Pepper, MD, MPHBoston University School of Public Health

Boston, MA 02118

Barbara Rahke, Director Philaposh (Philadelphia Area Project on Occupational Safety and Health)

3001 Walnut Street, 5th Floor Philadelphia, PA 19104

Beth Rosenberg, ScD, MPHAssistant Professor

Dept. Public Health & Community MedicineTufts University School of Medicine

Sally Greenberg, Executive Director

National Consumers League

Reid Maki, Coordinator Child Labor Coalition

Peter Dooley, MS, CIH, CSPLaborSafe Health and Safety Consulting

Ann Arbor, MI Adrienne DerVartanianSenior Attorney/Policy Analyst

Farmworker Justice

Documents

Letter to Sunstein WH