These comments reflect the frontline experience of American Society of Safety Engineers (ASSE) members who strive to help protect workers on jobsites across the US in all industries, including construction. These comments also reflect the expertise of the members of the ANSI Z117 Accredited Standards Committee for Confined Space Entry, of which ASSE is the secretariat. Based on those views, ASSE's overall conclusion is that this proposed rule is unduly complicated, introduces unnecessarily new terminology and requirements that are complicated and burdensome, and fails to recognize current safety practices that are widely understood and have proven successful in practice both in general industry and construction. At the heart of these concerns is OSHA's failure to provide rulemaking that is harmonious with the widely accepted Z117.1-2003 consensus standard, Safety Requirements for Confined Spaces. This article presents the specific concerns of the ASSE members.