Employers Walkaround Representative Rulemaking Coalition Comments on Proposed Rule – Worker Walkaround Representative Designation Process

Dear Assistant Secretary Parker:

On behalf of the Employers Walkaround Representative Rulemaking Coalition (“Coalition”), we are pleased to submit comments addressing the Occupational Safety and Health Administration’s (“OSHA” or “the Agency”) August 30, 2023, proposal to amend 29 C.F.R. 1903.8(c) – the “Worker Walkaround Representative Designation Process” Rule (Docket No. OSHA-2023-0008) (hereafter “the Proposal” or “proposed rule”).

The Coalition is composed of a broad and diverse group of employers and trade associations representing many industries, including retail, manufacturing, energy production, petroleum refining and pipeline/terminal operations, construction, logistics, food manufacturing and distribution, grain, feed and agricultural product processing, steel manufacturing, chemical manufacturing, environmental services, and more,1 with millions of employees across thousands of workplaces in every state in the Nation. The common thread among our members is that they are or represent responsible and conscientious employers who care deeply about their employees’ safety and health. As its members will be directly impacted by the proposed rule, the Coalition has a substantial interest in the outcome of this rulemaking.