The Alliance for Chemical Distribution (ACD) submitted comments to the Occupational Safety & Health Administration (OSHA) urging the agency to reevaluate its proposed rule on the Worker Walkaround Representative Designation Process.

In the comments, ACD’s Senior Vice President of Regulatory Affairs, Jennifer Gibson, emphasized that the current form of the proposed rule does not justify a modification to the agency's operations, and would not enhance the quality of inspections compared to the current system.

According to ACD, the proposed rule undermines the safety and security of these chemical facilities.

“The most worrisome aspect of this proposal is its requirement to force facilities to permit entry to individuals who would otherwise be forbidden from entering. ACD members house a wide range of chemicals and have various chemical processes occurring at their facilities, some of which can be dangerous. For these reasons, ACD members have long supported programs such as the Chemical Facility Anti-Terrorism Standards (CFATS) and worked closely with regulators to ensure their chemicals and processes are protected. This proposal would effectively undermine these efforts as it would force facilities to grant entry to individuals without undergoing any necessary background or other safety checks. Such individuals would be given intimate access and information regarding which chemicals are stored on the premises, where they are stored, and what they are used for. This is extremely worrying and raises significant security concerns.”

Gibson concluded by highlighting this proposed rule would hamper inspections, impede safety, and increase costs on chemical facilities.

“ACD recognizes the need for proper OSHA inspections and fully supports measures to improve them. However, the changes in this proposal would not improve inspections and would instead undermine the effectiveness of OSHA inspections while creating additional safety concerns for employees and communities.”

According to OSHA, the proposed changes will aid OSHA's workplace inspections by better enabling employees to select a representative of their choice to accompany the OSHA Compliance Safety and Health Officer during a physical workplace inspection. OSHA states that employee representation during the inspection is critically important to obtaining the necessary information about worksite conditions and hazards.

To see a summary of the proposed rule change, visit

To read ACD’s full comments, visit