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  • ACOEM Comments on Requirements for DOL Agencies' Assessment of Occupational Health Risks

    July 29, 2008

    The Honorable George Miller
    Committee on Education and Labor 
    United States House of Representatives 
    Washington, DC   20515  

    The Honorable Ted Kennedy
    Committee on Heath, Education, Labor
    United States Senate
    Washington, DC  20510

    Dear Chairman Miller and Chairman Kennedy: 

    I am writing to express the support of the American College of Occupational and Environmental Medicine (ACOEM) for your legislative efforts to direct the Department of Labor (DOL) to suspend its attempt to promulgate the rule, Requirements for DOL Agencies' Assessment of Occupational Health Risks. 

    The proposed rulemaking would require the department to allow a new round of challenges to the risk assessments used to determine how much exposure to certain chemicals is unsafe.  This would add another time consuming step to the already lengthy process of setting risk assessments for workplace chemicals, to the detriment of workers. 

    DOL should move cautiously in any rulemaking that impacts workers’ on-the-job exposure to chemicals and toxins.  Instead, the agency seems to be circumventing the transparent rulemaking process by promulgating a rule without input from workers, employers, and occupational physicians and allied occupational health providers. 

    ACOEM firmly believes that evidence-based science should be the underpinning of any rulemaking that impacts worker health and safety.  However, the DOL’s intent to truncate the rulemaking process has provided no opportunity for anyone outside of the agency to review the evidence base for this proposed rule.  

    ACOEM represents more than 5,000 physicians and other health care professionals specializing in the field of occupational and environmental medicine. Founded in 1916, ACOEM is the nation's largest medical society dedicated to promoting the health of workers through preventive medicine, clinical care, disability management, research, and education. 

    In this capacity, the health and safety of workers is a paramount concern. Decisions affecting the lives of millions of American workers should not be considered in secrecy or on timetables that have been accelerated with no apparent justification. We support your efforts to ensure their health and well being in this matter.  

    Thank you for your leadership in protecting workers’ health and safety. 


    Robert Orford, MD