These proposed Regulations are embarrassingly not ready for passage.  Various components are contradictory, unclear, in conflict with federal guidelines and/or violate acknowledged best practices.  Worker safety is certainly important.  However, this effort attempting to define hundreds of safety practices in tens of thousands of individualized circumstances – from dentists to construction workers and more -- is frankly the height of vanity and hubris, will lead to further economic damage to workers, employers and our economy, and has never before been successful even under the most regulated of economic systems.

As drafted, the regulations are irreparable and should be rejected.  A thoughtful and non-political effort would start over and begin by soliciting and incorporating with seriousness the knowledge and experience of all stakeholders.