Do you think engineering and administrative controls should be used first? When does it become unreasonable to expect a business to use engineering controls first? Should OSHA continue the pursuit of this change in a different fashion? Should they have left off the part about enforcing engineering controls unless it will “threaten the employer’s ability to remain in business”? Part of the problem with just providing PPE is that the hazard still remains, and if the PPE fails, the hazard is still there. Is PPE enough? Are the employers right in saying the economic impact of the proposed change is too much?

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