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EEOICPA - Coordination of offset or surplus

The postponement or denial of EEOICPA medical benefits because of a surplus amount is improper and inconsistent with intent of Congress in providing remedial compensation and medical benfits. There is no authorization in the Act for “offset” or “coordination of benefits” extended to “medical benefits” as is provided for in the associated regulations [20 C.F.R. § 30.505(b)(2)(iii) and 20 CFR §30.626(c)(2)(ii)]. Contrary... more »

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EEOICPA Notification to Claimants

• Consider requiring the OWCP to automatically and timely provided to the employee any written medical documentation, contemporaneous records, and other records or documents obtained or generated by the OWCP and not submitted by the employee or their representative that the OWCP has relied on to render a decision on medical benefits. This includes directed medical exam (medical second opinion) reports, district medical... more »

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OFCCP Should Withdraw Its Proposed Employee Compensation report

The Office of Federal Contract Compliance Programs has published an NPRM which would require federal subcontractors to submit to the federal government employee summary compensation data collected in an “Equal Pay Report” (EPR). (Though the rule is not yet final, we include it in this submission because the comment period has closed (as of January 5, 2015) and the RFI only prohibits review of “DOL rulemakings currently... more »

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Farmworker Justice Recommendations for Farmworker Protections

Farmworker Justice is a national, non-profit advocacy and education organization that works to improve working and living conditions for migrant and seasonal farmworkers and their families. Since its founding 30 years ago, Farmworker Justice has advocated for farmworkers in matters that affect their immigration status, working conditions, health occupational safety and access to justice.. Farmworker Justice submits these... more »

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DOL Should Update and Modernize PERM Regulations

There are a number of aspects of the PERM regulations (Program Electronic Review Management used in the Labor Certification process for permanent residency sponsorship by employers) that continue to require revision, so they are updated and modernized, none of which have been addressed since the 2011 regulatory review process:

20 CFR Part 656 currently has no agency timelines for adjudications, audits or appeals. When... more »

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DOL Should Withdraw H-2B Program Rule and Accede to DHS

The Department’s comprehensive program rule to govern the H-2B visa program was published after the April 2011 collection of comments on regulatory reform. This rule, also published at 20 CFR Part 655, creates a burdensome and unworkable construct for legally employing temporary foreign workers. In fact the program rules were a blatant attempt by DOL to simply graft the requirements the agency had imposed in the H-2A... more »

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DOL Should Withdraw Its H-2B Wage Methodology Rule

After imposition of a new prevailing wage methodology was barred by Congress in appropriations riders for FY12 and FY13, the Department of Labor did an end-run around congressional intent and promulgated a new joint rule with the Department of Homeland Security that, technically, was not barred by the riders. The new prevailing wage methodology under 20 CFR Part 655 was unworkable for most employers, who were able to... more »

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OSHA Should Abandon Its Opposition to Incentive Programs

In a memo to field staff on March 12, 2012, OSHA established a new policy that incentive programs wouild constitute a violation of the whistleblower protections under Section 11(c) of the OSH Act. The agency provided no data, no studies, no reports to support this position--only its belief that these programs suppress employees from coming forward with injuries or hazards. If OSHA believes this, the agency must conduct... more »

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OSHA Should Withdraw Its Interpretation on Walk Around Rights

OSHA's Feb. 13, 2013 letter of interpretation to the United Steelworkers allowing third-party employee representatives to accompany OSHA inspectors on walk-around inspections, without any showing of need or qualifcations is contrary to agency regulations that say an employee representative "shall be" an employee of the company. Accordingly, this LOI should be withdrawn.

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Comments to U.S. Department of Labor on Decreasing Regulatory Bu

The Independent Bakers Association (IBA) is pleased to respond to the Department of Labor’s invitation for public comment on how the Department can improve its regulations by modernizing, modifying, redesigning, streamlining, expanding, or repealing them. IBA is a national trade association of over 250 wholesale bakeries and related organizations. Our members include government contractors which are subject to regulations... more »

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Reduce training frequency for OSHA Bloodborne Pathogens Standard

31 March 2015

Regarding: Yale University’s Comments on DOL’s Request for Information
Submitted via E Docket


OSHA Docket Office
U.S. Department of Labor
200 Constitution Ave., NW
Washington, DC 20210

Dear Occupational Safety and Health Administration:

Yale University submits the following comments in response to the Department of Labor’s (DOL) 3 February 2015 Request for Information (RFI) on improving regulation... more »

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Combustible Dust Standard

Since 1923, when the NFPA published the first “national consensus standard” on the prevention of dust explosions in grain in flour mills, the hazards associated with combustible dust has not been unknown. In 2009, OSHA reported that loss from these explosions or fires affected almost 350,000 companies across the nation.

Each of these accidents could have been prevented with proper regulation to employers that would prevent... more »

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OSHA HazCom 2012 & Small Container Labeling

One of the most difficult issues for fragrance companies like mine, and for a number of other industries, is the treatment of small or sample sized products under the Hazard Communication Standard. While other jurisdictions like Canada and the European Union allowed for special accommodation for small bottles, OSHA has not allowed for an exemption. The result is a new, arduous, costly and incredibly burdensome process... more »

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