> > Does anyone have any insight into why these proposed rules aren’t taking a more consistent approach?

My experience in working with the Region 1 and national offices around a small rule amendment (chemical wastes in labs) is that the EPA offices operate quite independently of each other, between branches and in the same location. I had aspirations of synchronizing OSHA and EPA lab regulatory expectations, but that seems unlikely without continuous Congressional oversight of any process that is put in motion. The new rules are based on the Lautenberg Chemical Safety for the 21st Century Act, which is so broad as to make such oversight impossible.

One example is that OSHA tried a broader approach to regulating chemicals by class in 1989 and ergonomics in 2000 and the judicial and Congressional reactions were “no way”.

Semi-related, anybody sign an EPA Land Disposal Restriction notice recently (I did three times yesterday) (sorry, Russ)?

- Ralph

Ralph Stuart, CIH, CCHO
ralph**At_Symbol_Here**rstuartcih.org

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