August 15, 2011SENT BY EMAIL TO:mabel_e._echols@omb.eop.govMr. Cass SunsteinDirector, Office of Information & Regulatory AffairsThe White HouseRegarding: RIN 1235-AA06 - NPRM for Child Labor RegulationsDear 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 toOIRA 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 injuredwhile 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 permanentlydisabled 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 mayinclude 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 everyyear 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 OccupationalHealth & Safety Section, American Public Health Association at 860-679-4720 or tmorse@uchc.eduby Friday, August 19, 2011 to let us know when your office’s review will becompleted and the NPRM will be released to allow the public comment process to begin.Sincerely, Mary E. Miller, RN, MNChild Labor SpecialistWashington State
Celeste MonfortonProfessorial LecturerDept of Environmental & Occupational HealthSchool of Public Health & Health ServicesGeorge Washington UniversityRick Engler, DirectorNew Jersey Work Environment Council