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 All, 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 Alan H. Hall, M.D. President and Chief Medical Toxicologist Toxicology Consulting and Medical Translating Services, Inc. (TCMTS, Inc.) 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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