General Instructions for Drafting Comments

Comment Instructions

Instructions for Commenting on Particular Proposals

For example – an item might be something like :

  1. Delay of New Standards for Limiting Workplace Exposure to Airborne Beryllium, Docket No. OSHA-H005C-2006-0870. (Comments Due March 13, 2017)

The content of the comments you submit on a proposed regulatory or deregulatory action can consist of “data, views, or arguments,” either in opposition to or support of what is proposed.  Our recommendation is that you make it clear in the first sentence or two exactly what regulation you are commenting on and whether you believe the proposed action should or should not become final and effective.  Having made that clear, you should then proceed to explain the basis for your opinion or conclusions.

For more detailed advice on how to draft comments on a regulatory proposal, we recommend that you look at the Government’s “Tips For Submitting Effective Comments” here, (You can also find these tips on the website by clicking on the words “View Commenter’s Checklist (PDF)” above the comment box that appears when you click on “Comment Now” next to a regulatory item.)

Most importantly, however – and as the Government’s tips emphasize – the public comment process is not a vote, but a process enabling members of the public to bring relevant information and considerations to the attention of Government authorities before a regulatory decision is finalized.  A simple comment that you oppose or support a specific proposed action may have some meaning if that position is shared by an enormous number of other commenters.  But the most effective comments are those that bring to the attention of Government authorities some point, perspective, or consideration that has not already been taken into account in formulating the proposal.  Thus, it is best to be creative, speak of personal experience or experiences of those you know that have relevance to the issue at hand (even if only by analogy), and – wherever possible – draw upon and highlight any special knowledge or expertise you might have relating to the regulatory topic.   Again, it is still worth sending in a comment to communicate your views, even if that comment is very short and simple; but the best and most potentially impactful comments will be those that bring up points the Government will need to actively consider and respond to, if they are to have a record demonstrating legally required consideration of all relevant factors in their decisionmaking.

Note that although the comment box limits content to 5000 typed characters, you can attach a documents to whatever you type into the box.  Therefore, you can send comments that exceed 5000 characters by simply attaching a longer letter or continuation of your comments to your submission.