There are some really good comments and there are some very political comments, which should be expected in this type of transfer of information. I did notice that NOT ONE of the commenters answered the 85 questions OSHA requested they answer to support their comments/positions. Here is what the RFI stated:
OSHA is providing the following questions to collect data, information, and comments on the options discussed in this RFI. The Agency invites the public to respond to any questions for which they have specific knowledge, data, or information, regardless of their involvement in PSM-covered operations. OSHA would appreciate detailed responses to the following questions. When responding, please reference the specific question number to which you are responding.
I wrote several articles in support of several of these improvement areas, but I did not “officially” comment because the 85 questions OSHA asked were looking for responses from PEOPLE WHO OPERATE businesses who handle these highly hazardous chemicals. Seeing how I have not managed a covered process in 11 years I did not feel my comments/positions/opinions was what OSHA was seeking.
With that said, you can now read all the comments from the trade groups and a few individuals @ http://www.regulations.gov/#!docketDetail;D=OSHA-2013-0020.
Here is the link to the original RFI: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=24053