Comment from Thatcher, Makita

Re: OSHA Docket No. OSHA-2009-0035 — Ethylene Oxide Standard Information Collection Requirements To the Occupational Safety and Health Administration: I write in support of maintaining strong information collection, exposure monitoring, worker notification, medical surveillance, and record-access requirements under the Ethylene Oxide Standard. Ethylene oxide exposure is difficult for workers to evaluate without reliable monitoring, notice, and preserved records. In that context, paperwork is not merely administrative burden. It is part of the worker-protection system. Exposure-monitoring records, medical-surveillance records, written compliance programs, and physician-provided results help ensure that affected workers, OSHA, NIOSH, authorized representatives, and other appropriate parties can understand whether exposure occurred, whether controls were adequate, and whether health follow-up is needed. I respectfully urge OSHA and OMB to ensure that any reduction in estimated burden reflects a genuine reduction in covered exposure or medical-surveillance need, rather than a reduction in the practical ability of workers to receive monitoring, medical examinations, or access to records. The notice states that estimated burden hours are decreasing primarily because the number of workers receiving periodic medical examinations has declined from 24,992 to 16,663 examinations. OSHA should clearly explain the basis for that decline and whether it reflects reduced exposure, improved controls, changes in covered worksites, reporting assumptions, or other factors. The central worker-protection question is whether the information collection remains sufficient to ensure timely notice, accurate exposure records, meaningful medical surveillance, and long-term access to records for workers whose health may be affected by occupational exposure. I respectfully encourage OSHA to preserve requirements that ensure: Workers receive clear and timely notice of exposure-monitoring results. Exposure-monitoring and medical-surveillance records are maintained for appropriate periods and remain accessible to workers and their authorized representatives. Medical examination results are communicated clearly to affected workers. Any burden-reduction assumptions are transparent and do not weaken worker protections. OSHA retains enough aggregate and site-level information to evaluate whether the Ethylene Oxide Standard is functioning as intended. Information collection under this standard is necessary because workers cannot protect themselves from invisible occupational exposure without notice, monitoring, medical follow-up, and records. Where a workplace chemical may affect long-term health, the record is part of the safeguard. Respectfully, Makita Thatcher Georgia constituent