The Office of Senate Chief Counsel for Employment (“SCCE”) submits the following comments on the Office of Compliance (“OOC”) Draft Report on the 111th Congress Biennial Safety and Health Inspections (the “Biennial Report”). We request that you consider our comments when finalizing the Biennial Report and that you include this letter as an appendix to the final Biennial Report, subject to security review by the U.S. Capitol Police

No Citations For Senate Offices

We are pleased that the Biennial Report recognizes the Senate’s safety record: no outstanding citations exist for Senate offices and no citations were issued during the 111th Congress. We appreciate your acknowledgement that this safety record is the result of the commendable accomplishments of the staff of each Senate office working with the SCCE in cooperation with the Office of the Senate Sergeant at Arms (“Senate SAA”), and the Office of the Architect of the Capitol (“AOC”) in providing a safe work environment for all Senate employees.

Corrections, Additions And Clarifications To The Biennial Report

The SCCE recommends the following corrections, additions and clarifications to the Biennial Report to ensure that Congress receives complete and accurate information regarding current health and safety conditions in the congressional workplace.

The Biennial Report

• On page 10, the third paragraph states that “[a] number of the fire door latches [in the Capitol Visitor Center] had been covered with tape to prevent them from working in an emergency.” This statement is misleading as it suggests that the latches were covered with tape for the purpose of rendering the fire doors inoperable in an emergency. To avoid misinterpretation, we request that the sentence be changed to read: “A number of fire door latches had been covered with tape, which we believe could have prevented the fire doors from working effectively in an emergency.”
• On pages 12-13, under “Risk-Based Biennial Inspections,” please clarify that the CAA does not require employing offices to conduct self-inspections as a substitute for the OOC Office of General Counsel’s (“OGC”) obligation under 2 U.S.C, § 1341(e)( 1) to conduct inspections