N002010
Friday, January 18, 2002 6:13 PM
Comment concerning interim final rules
January 18, 2002
Kenneth L. Zwick
Director, Office of Management Programs
Civil Division
U.S. Department of Justice
Dear Mr. Zwick:
The New York Committee for Occupational Safety and Health is a
non-profit provider of health-and-safety-related training,
information and advocacy, serving workers throughout the New York
metropolitan area, with a membership consisting of over 250 union
organizations and 400 individuals -- union members, health and
safety activists, injured workers, healthcare workers, attorneys,
public health advocates, environmentalists and concerned citizens.
On behalf of the members of NYCOSH, I submit the following comment
on the Interim Final Rules:
Anyone who sustained a disabling injury as a result of the
September 11 attack ought to be eligible for federal compensation.
It is completely unreasonable to deny such compensation to anyone
who sustained a disabling injury, but did not obtain medical
services within 24 hours of being injured.
It is likely that many people received injuries that were serious
enough to require medical attention, but not serious enough to
visit an emergency room. If an injured person chose to seek
treatment for the injury from their regular physician by making an
appointment for treatment on the day after the attack, such a
person would not be eligible under the interim rules? 24-hour time
limit.
It is very possible that some people who were injured in the
attack were in such a state of psychological shock that they did
not obtain medical treatment for days after the attack. It is
reasonable to limit compensation to people who were injured as a
result of the attack, but there is no reasonable basis for
excluding anyone who, for whatever reason, delayed obtaining
medical services for their injury.
Sincerely,
Comment by:
New York Committee for Occupational Safety and Health