Date: Fri, 25 Jul 2008 14:17:00 -0400
Reply-To: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: List Moderator <ecgrants**At_Symbol_Here**UVM.EDU>
Subject: 3 RE: [DCHAS-L] U.S. Rushes to Change Workplace Toxin Rules

From: "Hopper, Charles R." 
Date: July 25, 2008 9:30:29 AM EDT (CA)
Subject: RE: [DCHAS-L] U.S. Rushes to Change Workplace Toxin Rules

It's too bad that this has become a political forum.  The underlying  
assumption is that the "chemical industry's management" is out to  
reduce worker safety.  This is far from the truth.  Many times  
government rules and regulations are not based on science or "real  
life" situations but on the worst possible scenario which never  
happens.  Let's keep this a non-political exchange of ideas and  
information of safety in the handling of chemicals.

From: Alan Hall 
Date: July 25, 2008 9:35:45 AM EDT (CA)
Subject: RE: [DCHAS-L] U.S. Rushes to Change Workplace Toxin Rules


I'm going to have to think about this one for awhile, but I am deeply  
disturbed if this proves to be true and I don't necessarily know what  
a Board Certified Medical Toxicologist, former Occupational/ 
Environmental Medicine Physician who occasionally does some consulting  
with DOL and politically doesn't particularly like the current  
administration and is not pleased with the possible next choices could  
do.  Sometimes in your nightmares or dreams, you begin to like the  
times you spent in Canada and Australia just a little bit better.

And yet, I've served my country in any way I could.  What are the next  
steps?  I've annoyed congresspersons and even Senators to try and get  
a point across when I believed in it.  I try not to do it these days,  
but there's some times when you have to stand up on your hind legs and  
howl at the moon like any well-blooded coyote, and worker health in  
safety is one of those times.  I've got scars still on my arms for a  
poorly-controlled aluminum facility, and I know other things too  
numerous to mention.  I wasn't always an MD.  We all started somewhere  
and I had my first full-time job at the age of 13 years.

Let me know how we can approach this issue as we should as responsible  
EHS professionals.

But somehow, perhaps this is a "coyote" issue where we have to howl at  
the moon as responsible professionals.

Alan H. Hall, M.D.
President and Chief Medical Toxicologist
Toxicology Consulting and Medical Translating Services, Inc. (TCMTS,  
Laramie, WY
Clinical Assictant Professor of Preventive Medicine and Biometrics
University of Colorado Health Sciences Center
Denver/Aurora, Colorado
Senior Advisor
Forensic Science
Weatherford College
eatherford, Texas

From: Paul Sonnenfeld 
Date: July 25, 2008 11:59:15 AM EDT (CA)
Subject: RE: [DCHAS-L] U.S. Rushes to Change Workplace Toxin Rules

Okay, so the Bush Adminstration is playing fast and loose with federal  
rulemaking procedures.  Please remember that federal courts have been  
taking a dim view of this practice as evidenced by the number of cases  
the US EPA has lost.  Perhaps the folks at DOL, in their haste to  
craft these new rules are forgetting about the statute.  You know,  
that general duty clause.  My recollection is that that statute trumps  
any rule or regulation promulgated by DOL.

This is not to say that we don't have to diligently review the  
proposed rule when it is finally published in the Federal Register.

Paul Sonnenfeld, CPEA

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