August 15, 2011


Mr. Cass Sunstein Director, Office of Information & Regulatory Affairs The White House Regarding: RIN 1235-AA06 - NPRM for Child Labor Regulations Dear 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 to OIRA for review more than nine months ago, on November 12, 2010. The time has long passed for 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 injured while working at the Zaloudek Grain Co. in Kremlin, Oklahoma. Their legs were severed while working in a grain handling facility operating a large grain auger. Both will be permanently disabled because of these injuries. Their families, friends and community members are traumatized by this event as well. We understand that the Labor Department¶s draft rule may include proposed protections that could have prevented this incident from occurring. We hope this terrible event and the hundreds of other incidents that injure and kill young workers every year will compel you to release this draft proposal immediately and allow the Labor Department to proceed with a public comment period. Please have someone on your staff contact Tim Morse, PhD, CPE, chair of the Occupational Health & Safety Section, American Public Health Association at 860-679-4720 or by Friday, August 19, 2011 to let us know when your office¶s review will be completed and the NPRM will be released to allow the public comment process to begin. Sincerely, [See attached list; affiliations listed for identification purposes only] Mary E. Miller, RN, MN Child Labor Specialist Washington State Celeste Monforton Professorial Lecturer Dept of Environmental & Occupational Health School of Public Health & Health Services George Washington University

Rick Engler, Director New Jersey Work Environment Council On the web at 142 West State Street - Third Floor Trenton, New Jersey 08608 Karen B. Mulloy, DO, MSCH Associate Professor, Colorado School of Public Health Joel Shufro, Executive Director New York Committee for Occupational Safety and Health (NYCOSH) Jeanne Sears, PhD, RN Senior Research Scientist Department of Health Services & Center for Healthcare Improvement for Addictions, Mental Illness and Medically Vulnerable Populations (CHAMMP) University of Washington Carol W. Runyan, MPH, PhD Director, Injury Prevention Research Center Professor of Health Behavior and Health Education Professor of Pediatrics University of North Carolina Paul Landsbergis, ScD Associate Professor Department of Environmental and Occupational Health Sciences School of Public Health State University of New York-Downstate Medical Center Patty Quinlan, MPH, CIH Industrial Hygienist Division of Occupational and Environmental Medicine University of California San Francisco Justin Feldman Worker Health & Safety Advocate Congress Watch Public Citizen Washington, DC 20003

Shari Burgus, Education Director Farm Safety 4 Just Kids Jim Albers, MPH, CIH National Institute for Occupational Safety and Health (NIOSH) Craig Slatin, Sc.D., MPH Professor, Department of Community Health and Sustainability University of Massachusetts Lowell Adam M. Finkel, Sc.D. Senior Fellow and Executive Director Penn Program on Regulation Professor of Environmental and Occupational Health UMDNJ School of Public Health Tammy Miser Founder/Executive Director United Support & Memorial For Workplace Fatalities (USMWF) Marychris Rodriguez United Support & Memorial For Workplace Fatalities (USMWF) Deborah Safron Instructor in Sociology Michigan State University Michael D. Schulman William Neal Reynolds Distinguished Professor President-Elect: Rural Sociological Society Dept of 4-H Youth Development & Family & Consumer Sciences and Dept of Sociology North Carolina State University David H. Wegman Professor Emeritus Department of Work Environment University of Massachusetts Lowell Andrea Kidd Taylor, DrPH, MSPH Lecturer, Morgan State University School of Community Health & Policy Marcy Goldstein-Gelb Executive Director MassCOSH Mass. Coalition for Occupational Safety and Health

Michael J. Wright Director of Health, Safety & Environment United Steelworkers Pittsburgh, PA 15228 Rev. Stephen Copley Arkansas Committee on Occupational Safety and Health Committee Lewis Pepper, MD, MPH Boston University School of Public Health Boston, MA 02118 Barbara Rahke, Director Philaposh (Philadelphia Area Project on Occupational Safety and Health) 3001 Walnut Street, 5th Floor Philadelphia, PA 19104 Beth Rosenberg, ScD, MPH Assistant Professor Dept. Public Health & Community Medicine Tufts University School of Medicine Sally Greenberg, Executive Director National Consumers League Reid Maki, Coordinator Child Labor Coalition Peter Dooley, MS, CIH, CSP LaborSafe Health and Safety Consulting Ann Arbor, MI Adrienne DerVartanian Senior Attorney/Policy Analyst Farmworker Justice

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