By Eric J. Conn and Beeta B. Lashkari
We hope you saw our post last week about OSHA’s new Emergency Response Rulemaking and the Rulemaking Coalition that Conn Maciel Carey LLP is organizing to work on this surprisingly onerous proposed rule.
When we published that article, the NPRM package had been revealed by OSHA but had not yet been published in the Federal Register. That has now changed. OSHA’s proposed Emergency Response rule for emergency and related responders was officially published in the Federal Register today. Unless OSHA grants a request for an extension of the comment period, stakeholders’ written comments to the NPRM will be due in 90-days – by May 6, 2024.
Here is more detail about some concerning aspects of OSHA’s new proposed Emergency Response Rule and about our Rulemaking Coalition.
CMC’s prior OSHA Rulemaking Coalitions over the last several years have been successful in making important changes to OSHA’s major rulemakings and have otherwise been valuable experiences for our participants because of the timely and detailed updates about the rulemaking processes that we have provided. We intend to take the same approach for this rulemaking. We will coordinate with our coalition participants to: Continue reading