On November 8, the Coalition for Workplace Safety submitted a request to the Occupational Safety and Health Administration asking the agency to extend the comment period on its COVID-19 Vaccination and Testing Emergency Temporary Standard for an additional 60 days. The current comment period, which only provided 30 days for the public to provide input, was woefully insufficient. Our request, which was filed by Morgan Lewis on behalf of the coalition, can be read below:
Dear Assistant Secretary Parker:
Morgan Lewis represents the Coalition for Workplace Safety (“CWS”) for purposes of submitting comments concerning OSHA’s COVID-19 Vaccination and Testing Emergency Temporary Standard. I write to request an extension to the very brief comment period. As you know, OSHA has provided the public with only 30 days to provide comments, which is insufficient given the extensive rulemaking at issue. CWS members (and the employer community overall) need this additional time to understand the implications of the ETS as they work to implement it, identify issues, and then comprehensively present their concerns to OSHA. With additional time, stakeholders will be better-positioned to inform OSHA as it develops a permanent rule. Based on the above, we respectfully request that you provide an additional 60 days to the comment period, extending it into early February. We appreciate you considering this request.