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ASSE Government

Affairs Update

September 28, 2007

ASSE Weighs in on Key Mining Bills



ASSE has commented on the two key mine safety bills now under consideration in the US

House of Representatives. Mark up of the bill by the House Committee on Labor and

Education is expected in early October. The bills seek to build on safety provisions of the

MINER Act passed by Congress last year. The comments were developed by the

Government Affairs Committee based on the insight of leaders in ASSE's Mine Practice

Specialty. While ASSE takes positions on a variety of specific issues aimed to improve mine

safety, rescue and emergency response, it also suggests that, based on the risks that have

come to light in recent mine tragedies, the time has come for an overall safety analysis of the

mine industry to identify the most dangers risks so the focus of mine owners, the resources of

MSHA and NIOSH and Congressional efforts can be targeted to the most dangerous risks first.

ASSE’s statement as well as a side-by-side of the bills with ASSE’s comments on specific

provisions can be accessed on the front page of the ASSE website at http://www.asse.org/.



Also of interest is the appropriate investigation of the most recent highly visible mine disaster

at Crandall Canyon in Utah. Jonathan Snare, DoL’s Solicitor General, and Senator Michael

Enzi (R-WY) – joined by Senator Ted Kennedy (D-MA) – weighed in on the view that MSHA

should be allowed to conduct its investigation. The Enzi news release stating that can be

found at http://help.senate.gov/Min_press/2007_09_18_a.pdf



ASSE Support Bresland to Chair CSB



AMERICAN SOCIETY

OF SAFETY ENGINEERS

1800 East Oakton Street

Des Plaines, Illinois 60018-2187

847.699.2929

FAX 847.296.3769

www.asse.org



September 28, 2007



The Honorable Barbara Boxer

Chairman

Committee on Environment and Public Works

United States Senate

SD-456 Dirksen Senate Office Building

Washington, DC 20510-2602



RE: Support for Nomination of John Bresland

to Chair CSB Board



Dear Chairman Boxer:

2



The American Society of Safety Engineers (ASSE) is a global professional membership

society of safety, health and environmental (SH&E) professionals dedicated to helping make

sure workplaces are safe and healthy. Our 32,000 members include safety professionals,

industrial hygienists, hazard material managers, engineers, educators, ergonomists,

occupational health nurses and others who work for and with employers to prevent workplace

injuries, illnesses and deaths.



On behalf of our members, we want to express ASSE’s support for the President’s

nomination of John Bresland to the position of Chairman of the Board for the U.S. Chemical

Safety and Hazard Investigation Board (CSB), which the Committee on Environment and

Public Works will consider.



CSB plays an integral role in helping ensure that industry, the safety and health community,

and our members can learn about the causes of workplace accidents involving chemicals to

help ensure that the accidents are not repeated. Our members use the CSB’s

recommendations developed from its investigations as well as the quality written and video

technical reports. These resources help our members fulfill their responsibility in assisting

their employers protecting workers and workplaces from chemical hazards.



It is imperative that CSB is lead by a qualified safety and health professional who has the

appropriate education, training and experience in managing the complexities of chemical

safety issues. In our members’ opinion, John Bresland is well qualified to lead CSB. Over

the last five years as a member of CSB’s Board, he has played a key role in advancing CSB’s

capabilities. He has also personally reached out to the safety and health professional

community to see that the work of CSB reaches the audiences for which it is intended. With

his advanced training in chemistry and his professional experience managing safety, health

and environmental issues in private industry, ASSE believes John Bresland is in an excellent

position to carry on the work of expanding the effectiveness of CSB that the outgoing

Chairman, Carolyn Merritt, so capably led.



We respectfully urge the Committee to approve John Bresland’s appointment so he can begin

to provide that leadership as soon as possible. If ASSE’s members can be of any help to the

Committee in its deliberations, we encourage you to contact Dave Heidorn, JD, Manager of

Government Affairs and Policy at 847/768-3406 or dheidorn@asse.org.



Thank you for your time and attention to our views.



Sincerely,





Michael W. Thompson, CSP

President



cc: Representative James M. Inhofe

Ranking Minority Member

3



ASSE Urges OSHA Involvement in Z15 Committee



AMERICAN SOCIETY

OF SAFETY ENGINEERS

1800 East Oakton Street

Des Plaines, Illinois 60018-2187

847.699.2929

FAX 847.296.3769

www.asse.org



September 21, 2007



The Honorable Edwin G. Foulke, Jr.

Assistant Secretary of Labor

Occupational Safety and Health Administration

U.S. Department of Labor

200 Constitution Avenue, NW

Washington, DC 20210



RE: Urging OSHA Membership on

Z15 ASC on Safe Practices for

Motor Vehicle Fleet Operations



Dear Assistant Secretary Foulke:



As you know, the American Society of Safety Engineers (ASSE) greatly values the

participation of Occupational Safety and Health Administration (OSHA) staff in the safety and

health professional community. Increased opportunities for OSHA staff to share their expertise

and experience in professional safety activities is one of the leading successes of our Alliance.



Participation in safety standards development activities is also an area we believe OSHA staff

can be particularly valuable. Specifically, ASSE is the Secretariat for the standard "Safe

Practices for Motor Vehicle Operations" (ANSI/ASSE Z15.1-2006) addressing management of

motor vehicle fleet operations hazards and exposures. Currently, the Z15 Accredited Standards

Committee (ASC) is investigating several new areas for future standards development and

believes its goal would best be served if OSHA would join the Committee. ASSE agrees with

the Committee and urges you to help make sure that an OSHA staff member can represent the

agency’s interests on the Committee.



To be clear, there is an ANSI-required process that needs to be met before OSHA can become a

member. All organizations must apply. Before the Z15 ASC votes on an application, the

interested organization is required to attend two meetings. The applying organization attends

the first meeting as an observer, and the committee votes on the application during the second

meeting. An organization approved for committee membership is added to the roster and

receives ballots, draft standards and other information. If OSHA can participate on the Z15

ASC, the appropriate staff member should e-mail a notice of interest to Tim Fisher, Secretariat

staff, at tfisher@asse.org. An application and instructions will be sent on reply.



A copy of the Z15 standard is enclosed. More information on Z15 can be found at

http://www.asse.org/cartpage.php?link=z15.1-2006.

4



ASSE sincerely believes that OSHA’s participation in the voluntary consensus process is vitally

important to the advancement of safety. We urge you to consider this opportunity for OSHA to

join the Z15 ASC.



Sincerely,







Michael W. Thompson, CSP

President



cc: Paula White



ASSE Provides Comments on OSHA Motor Vehicle Safety Topics Page



On September 25, ASSE submitted the following comments for OSHA’s annual review of its

Safety and Health Topics page for Motor Vehicle Safety, which can be found at

http://www.osha.gov/SLTC/motorvehiclesafety/index.html. The comments were developed

through the Council on Professional Standards.



Current Page



According to the Bureau of Labor Statistics (BLS), more than 2,000 deaths a year

result from occupational motor vehicle incidents. That number is more than 30

percent of the annual number of fatalities from occupational injuries. These deaths

include driver and passenger deaths in highway crashes, farm equipment accidents,

and industrial vehicle incidents, as well as pedestrian fatalities.



The following questions link to information relevant to motor vehicle safety.



What standards apply?

OSHA | Other Federal



ASSE has not received any comments from its members addressing this issue



What information is available for the construction industry?

OSHA Standards | Hazards and Solutions | Additional Information



Under “other resources,” ASSE suggest that there be a link to the ANSI/ASSE A10

Standards for Construction and Demolition Operations. A10.34 addresses public

exposures and motor vehicles are part of this even though OSHA does not address

public hazards and exposures. Almost all of the A10 Standards address motor vehicle

safety to some extent on construction and demolition sites, but the standards that more

directly impact transportation are



ANSI/ASSE A10.6-1990 (R1998)

Safety Requirements for Demolition Operations - American National Standard

for Construction and Demolition Operations

ANSI/ASSE A10.7-1998 (R2005)



Safety Requirements for Transportation, Storage, Handling, and Use of Commercial Explosives

5





and Blasting Agents



ANSI/ASSE A10.9-1997 (R2004)



Safety Requirements for Concrete and Masonry Work - American National Standard for

Construction and Demolition Operations



ANSI/ASSE A10.12-1998 (R2005)



Safety Requirements for Excavation - American National Standard for Construction and

Demolition Operations



ANSI/ASSE A10.17-2006



Safe Operating Practices for Hot Mix Asphalt (HMA) Construction



ANSI/ASSE A10.24-2006



Roofing Safety Requirements for Low-Sloped Roofs



ANSI/ASSE A10.27-1998 (R2005)



Safety Requirements for Hot Mix Asphalt Facilities - American National Standard for

Construction and Demolition Operations



ANSI/ASSE A10.33-1998 (R2004)



Safety and Health Program Requirements for Multi-Employer Projects - American National

Standard for Construction and Demolition Operations



ANSI/ASSE A10.34-2001 (R2005)



Protection of the Public on or Adjacent to Construction Sites - American National Standard for

Construction and Demolition Operations



ANSI/ASSE A10.38-2000



Basic Elements of an Employer's Program to Provide a Safe and Healthful Work Environment -

American National Standard for Construction and Demolition Operations



The various ANSI standards for which ASSE serves as Secretariat can be found at

http://www.asse.org/publications/standards/secretariats.php#







Where do motor vehicle hazards occur and what are possible

solutions?

Hazard Recognition | Possible Solutions



ASSE suggest that a link to the ANSI/ASSE Z15 Standard for Motor Vehicle Operations

should be added here. The standard sets forth safety requirements for the operation of motor

6





vehicles, including, but not limited to, nomenclature, definition, data gathering, statistical

analysis, inspection, maintenance, training, and other related equipment and functions of motor

vehicle operations. The standard should be included under both the Hazard Recognition and

the Possible Solutions sections. The appropriate link is

http://www.asse.org/cartpage.php?link=z15.1-2006, which should be included under the

following two questions, also.



What can be done in the workplace to promote vehicle safety?

Policies | Fleet Management | Safety Programs | Driver Performance | More



As above, ASSE suggests a link to the ANSI/ASSE Z15 Standard for Motor Vehicle

Operations should be added here. The appropriate link is

http://www.asse.org/cartpage.php?link=z15.1-2006, which should be included under the

following two questions, also.



What additional information is available?

Related Safety and Health Topics Pages | Case Studies | Other Resources



Again as above, ASSE suggests a link to the ANSI/ASSE Z15 Standard for Motor Vehicle

Operations should be added here. The appropriate link is

http://www.asse.org/cartpage.php?link=z15.1-2006, which should be included under the

following two questions, also.



We also suggest the following links below be listed under “Other Resources” as important

transportation safety resources –



From the Federal Motor Carrier Safety Administration, its Share the Road Safely web site. The

Share the Road Safely program works to improve the knowledge of all highway users to

minimize the likelihood of a crash with a large truck, and reduce the consequences of those that

do occur. http://www.sharetheroadsafely.org/





We also suggest listing the web site of ASSE Transportation Practice Specialty, which

provides a variety of resources and links those interested in transportation safety to

leading transportation safety experts.

http://www.asse.org/practicespecialties/transportation/







US House Passes Diacetyl Legislation



This week, the US House of Representatives passed legislation calling on OSHA to develop a

standard on diacetyl exposure. ASSE’s statement in support of this legislation can be found

at http://www.asse.org/professionalaffairs/docs/061907Woolseydiacetyl.doc.



News - U.S. House of Representatives

EDUCATION & LABOR COMMITTEE DEMOCRATS

Congressman George Miller, Chairman



Wednesday, September 26, 2007



Legislation to Protect Food Flavoring Workers from Severe Lung Disease Passes

House

7



WASHINGTON, D.C. – By a vote of 260 to 154, the U.S. House of Representatives today

approved legislation intended to prevent workers in food processing plants from

getting a debilitating, irreversible lung disease that has already sickened and killed a

number of workers nationwide.



The legislation would force the U.S. Occupational Safety and Health Administration to

issue rules limiting workers’ exposure to diacetyl, a chemical used in artificial food

flavoring for microwave popcorn and other foods. Scientists have linked diacetyl

exposure to bronchiolitis obliterans, a severe lung disease often known as “popcorn

lung.” Despite mounting evidence over several years of the dangers of popcorn lung,

OSHA has failed to take action to limit diacetyl exposure, prompting the need for the

legislation approved by the House today.



“Seven years after the first cases of popcorn lung were identified, it is stunning that

OSHA has failed to protect American workers from this horrible disease,” said Rep.

George Miller (D-CA), chairman of the committee. “The cost of the Bush

administration’s failure to act can be measured in the number of workers who have

avoidably grown ill or died. This legislation is critical to stop the delays in protecting

workers from this serious workplace hazard.”



“It’s a travesty that OSHA has done nothing to regulate this chemical, while workers

have fallen seriously ill and some have actually died,” said Rep. Lynn Woolsey (D-

CA), chairwoman of the Subcommittee on Workforce Protections and chief sponsor of

the legislation. “That’s why it’s time for Congress to act to keep workers healthy and

safe. Passing this important legislation is a step in the right direction.”



Thousands of workers are still being exposed to diacetyl at factories that make or use

food flavorings.



The legislation, the Popcorn Workers Lung Disease Prevention Act (H.R. 2693), would:



Mandate that OSHA issue a standard within 90 days to minimize workers’ exposure to

diacetyl in popcorn and flavorings manufacturing plants. Employers would be

required to develop a written exposure control plan that would use engineering

controls and respirators to protect workers, and to conduct medical monitoring to

determine whether workers’ health continued to be harmed.

Mandate that OSHA issue a more comprehensive standard within two years, covering

all workplaces where workers may be exposed to diacetyl.

House Democrats urged the Labor Department to address this serious health hazard

in August 2006. For more information and for a copy of the August 2006 letter from

House Democrats to the Department of Labor, click here.



The Education and Labor Committee held a hearing on OSHA’s failure to issue

standards, including one for diacetyl, in April 2007. For more information, click here.



September 26, 2007

OSHA Holding October 17 Stakeholder Meeting on Diacetyl



OSHA has invited interested parties to participate in or observe an informal stakeholder

meeting on occupational exposure to diacetyl and food flavorings containing diacetyl. The

meeting is October 17, 2007, from 8:30 a.m.-4:30 p.m., at the Crown Plaza Hotel Washington

National Airport, 1480 Crystal Drive, Arlington, Virginia 22202. OSHA states that iIf more than

50 stakeholders register for the stakeholder meeting on October 17, 2007, a second meeting

8



will be scheduled for October 18, 2007, from 8:30 a.m. to 4:30 p.m. A notice of intention to

attend must be submitted by October 10, 2007.

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-

19087.htm



OSHA Announces Three Actions on Diacetyl



OSHA news release --



Sept. 24, 2007





OSHA announces three actions to protect workers exposed to butter

flavorings



WASHINGTON -- The U.S. Department of Labor's Occupational Safety and

Health Administration (OSHA) announced today that it is taking the following

three actions that will address concerns regarding diacetyl exposure in the

workplace:



1. Initiating a rulemaking under section 6(b) of the Occupational

Safety and Health Act.

2. Issuing a Safety and Health Information Bulletin (SHIB).

3. Providing Hazard Communication Guidance.



These actions build upon the National Emphasis Program that OSHA

announced in April 2007 to focus on the health hazards of microwave popcorn

butter flavoring containing diacetyl.



"OSHA's goal is to protect workers from exposure to chemical hazards associated

with microwave popcorn manufacturing," said Assistant Secretary of Labor for

OSHA Edwin G. Foulke Jr. "Our open, transparent regulatory process will seek

information and guidance from all stakeholders to gather the best information on

the health effects of exposure to diacetyl. That information will allow us to

institute effective protections for workers."



The SHIB provides information on health effects for workers exposed to butter

flavorings in microwave popcorn processing plants; information on exposure

controls that may be used to reduce exposures to butter flavorings; and

information on applicable OSHA standards.



The Hazard Communication Guidance alerts employers, workers,

manufacturers and importers about new information related to the health hazards

associated with diacetyl and food flavorings containing diacetyl; and provides

guidance on how to develop material safety data sheets and hazard warning

labels to be in compliance with OSHA's Hazard Communication Standard.



Under the Occupational Safety and Health Act of 1970, employers are responsible

for providing safe and healthful workplaces for their workers. OSHA's role is to

assure the safety and health of America's working men and women by setting and

enforcing standards; providing training, outreach and education; establishing

partnerships; and encouraging continual process improvement in workplace safety

and health. For more information, visit www.osha.gov.

9



OSHA Issues Directive on Slide-Locks



OSHA has issued a compliance directive setting enforcement policies and inspection

procedures for slide-locks to control hazardous energy on mechanical power presses and

general machinery. The directive is available at

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=36

89



GAO Looks at Euro/US Chem Regulation



These Government Accounting Office reports are usually at the end of GA Updates. This one

may be of particular interest to ASSE members. The GAO provides a wealth of information on

a variety of issues.



Chemical Regulation: Comparison of U.S. and Recently Enacted European

Union Approaches to Protect against the Risks of Toxic Chemicals. GAO-07-

825, August 17

http://www.gao.gov/cgi-bin/getrpt?GAO-07-825

Highlights - http://www.gao.gov/highlights/d07825high.pdf



September 19, 2007

FACOSH Meeting October 11



OSHA has announced that the Federal Advisory Council on Occupational Safety and Health

(FACOSH) will meet October 11, 2007, in Washington, DC, at the Department of Labor,

from 1 to 4:30 p.m. The tentative agenda includes updates on the FY 2007 performance results

of executive branch agencies in meeting the four goals of the Presidential Safety, Health, and

Return-to-Employment (SHARE) Initiative; FY 2006 Secretary of Labor's Report to the President on

the overall status of occupational safety and health in the executive branch; Federal Agency

Recordkeeping Subcommittee; federal agency training week being hosted by the OSHA Training

Institute on November 6-8, 2007 and results of OSHA's survey of federal agencies' training

resources; and Field Federal Safety and Health Councils.

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-

18406.htm



DHS Holding Exercises in DC, Phoenix and Portland, OR



From DHS –



U.S. Department of Homeland Security Conducts Largest Counterterrorism Exercise To Date



Release Date: September 24, 2007



For Immediate Release

Office of the Press Secretary

Contact: 202-282-8010



The U.S. Department of Homeland Security will conduct the largest and most comprehensive

counterterrorism exercise to date from Oct. 15-19 in Arizona and Oregon, and the U.S. territory of

Guam. Top Officials 4 (TOPOFF 4) is the fourth in a series of congressionally-mandated exercises and

involves various federal agencies as well as the governments of Australia, Canada and the United

10



Kingdom.



“The National Intelligence Estimate and recent activity overseas reinforce that we are in a period of

increased risk,” said Homeland Security Secretary Michael Chertoff. “Exercises like TOPOFF help test

response capabilities at all levels, strengthen national preparedness and deepen international

coordination. By responding realistically to these simulated attacks, we’re able to identify our strengths

and weaknesses, build better partnerships, and gain valuable knowledge for securing the nation against

terrorist attacks and other natural disasters.”



TOPOFF 4 will involve more than 15,000 participants from all levels of government, international

partners and the private sector in a full-scale, simulated response to radiological dispersal device

attacks.



“TOPOFF stresses our preparedness and response systems with situations that no single agency or

jurisdiction could handle on its own,” said David Paulison, Administrator of DHS’ Federal Emergency

Management Agency. “The right response actually takes thousands of individuals working together.

This exercise is about strengthening working relationships within our partners in federal, state and

local agencies, emergency management communities and private industry groups. It’s about increasing

preparedness by sharing information and processes.”



To reach the overarching goal and objectives to enhance interagency coordination, planning and

preparedness, TOPOFF 4 will focus on five key areas:



 Prevention: To test the handling and flow of operational and time-critical intelligence

between agencies to prevent a terrorist attack.

 Intelligence/investigation: To test the handling and flow of operational and time-critical

intelligence between agencies prior to, and in response to, a linked terrorist incident.

 Incident management: To test the full range of existing procedures for domestic incident

management of a terrorist weapon of mass destruction event and to improve the top officials’

capabilities to respond consistent with the National Response Plan and the National Incident

Management System.

 Public Information: To practice the strategic coordination of media relations and public

information in the context of a terrorist weapon of mass destruction event or incident of

national significance.

 Evaluation: To identify lessons learned and promote best practices.



TOPOFF 4 builds on experiences from previous exercises as well real world emergencies, and will

also prioritize increased coordination with U.S. Department of Defense and the private sector, an

expanded emphasis on prevention, a deeper focus on mass decontamination, long-term recovery and

remediation issues, and strengthened partnerships and communications with international allies.



In addition to TOPOFF 4 objectives, each supporting and partnering agency, state, territory and local

entity has developed a set of specific objectives to further assist them in preparing for emergency

situations.



For more information on TOPOFF 4, visit the Department of Homeland Security Web site at

www.dhs.gov/topoff4.



OSHA Issues Guidance on Slings for Handling Materials



OSHA news release –



Sept. 27, 2007

11



WASHINGTON -- New guidance from the Occupational Safety and Health

Administration (OSHA) will help employers select and use the appropriate slings when

handling and moving materials. The document, Guidance on Safe Sling Use, was

released today by the agency.



"OSHA's current general industry standard is more than 30 years old," said Assistant

Secretary of Labor for OSHA, Edwin G. Foulke, Jr. "This guidance document will aid

users in the safe selection and use of slings, including synthetic round slings, which

are not covered in OSHA's standard, as well as the newer grades of materials being

used in alloy steel chain and wire rope slings."



OSHA adopted its general industry sling standard on June 27, 1975, based on ANSI

B30.9-1971 Slings standard. OSHA has since made only minor corrections. OSHA

issued its construction industry sling standard on February 9, 1979, and its sling

standard for shipyards on April 20, 1982.



Improper selection or use of slings can result in sling failure or load slippage, which in

turn can lead to injuries or death. OSHA accident data for the years 1994 through

1996 show that there were four fatalities in general industry involving the misuse or

failure of slings.



OSHA intends to format the final product for use on the Web. With the document in

web format, a user can quickly get information on the type of sling he or she is using

without having to look through material that is not relevant to the workplace.



Under the Occupational Safety and Health Act of 1970, employers are responsible for

providing a safe and healthful workplace for their employees. OSHA's role is to assure

the safety and health of America's working men and women by setting and enforcing

standards; providing training, outreach, and education; establishing partnerships;

and encouraging continual process improvement in workplace safety and health. For

more information, visit www.osha.gov.



September 18, 2007

OSHA Asks Comments on Handling Fed Employee Discrimination Complaints



OSHA has asked for comments on its proposal to extend OMB approval of the information

collection (paperwork) requirements for handling discrimination complaints under federal

employee protection statutes. These regulations set forth procedures employees must use to

file a complaint with OSHA alleging that their employer violated a federal statute that

prohibits retaliation against employees who engage in activities protected by the various

employee protection statutes. Comments are due November 19, 2007.

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-

18314.htm



September 28, 2007

Transport of Compressed Oxygen/Other Gases/Chemical Oxygen Generators on Aircraft



In Junuary 2007, the Pipeline and Hazardous Materials Safety Administration (PHMSA)

published a final rule that amended requirements in the Hazardous Materials Regulations

applicable to the air transportation of compressed oxygen cylinders and oxygen generators.

In response to appeals to the final rule, this final rule amends those requirements and delays

the effective date of the requirements from October 1, 2007 to October 1, 2008

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-

19207.htm

12



September 20, 2007

PHMSA on Fuel Cell Cartridges/Systems on Aircraft in Carry-on Baggage



PHMSA is proposing to amend the Hazardous Materials Regulations (HMR) to permit certain

fuel cell cartridges and fuel cell systems designed for portable electronic devices to be

transported by passengers and crew in carry-on baggage on board passenger-carrying

aircraft. The proposed rule would cover fuel cells containing certain hazmat (flammable

liquids, including methanol; formic acid; certain borohydride materials; or butane) and

meeting certain performance and consumer use standards, which PHMSA proposes to

incorporate by reference into the HMR. PHMSA states that it has evaluated the possible

transportation safety risks determined they may safely be transported in the cabin of a

passenger-carrying aircraft. Comments are due November 19, 2007.

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-

18532.htm



September 27, 2007

EPA Seeks Comment on Waste Combustor NESHAP Legal Analysis



In October 2005, EPA issued national emission standards for hazardous air pollutants

(NESHAP) emitted by hazardous waste combusters. EPA then granted reconsideration

petitions on certain issues but has not yet issued a final determination on reconsideration.

Following theclose of the comment period on the proposed reconsideration rule, the

United States Court of Appeals for the District of Columbia Circuit issued several opinions

construing section 112 (d) of the Clean Air Act. One of those opinions has called into question

the legality of some of the standards for hazardous waste combusters. This notice discusses

the standards that EPA promulgated in October 2005 and identifies which standards EPA

believes are consistent with the Act and case law those that are not and need to be

reexamined through rulemaking. EPA wants comments on this analysis. Comments are due

October 18, 2007.

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-

19097.htm



September 18, 2007

EPA Direct Final Rule on Nonroad Diesel Corrections



In this rulemaking, EPA has made technical corrections to the rules establishing emission

standards for nonroad diesel engines. It is also amending the rules to provide nonroad diesel

equipment manufacturers with a production technical relief provision for Tier 3 equipment

similar to the technical relief provision already available for Tier 4 equipment. The direct final

rule is effective on November 19, 2007, unless EPA receives adverse comments by October

18 or request for public hearing by October 3, 2007.

http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/E7-

18161.htm



EPA Says Skies Improve in Eastern US



EPA news release –



Thursday, Sept. 27, 2007



EPA Report: Smog Thinner, Skies Healthier over Eastern U.S.



(Washington, D.C. - Sept. 27, 2007) Smog-forming emissions of nitrogen oxides (NOx)

from power plants and industry have declined significantly in 19 eastern states and the

13



District of Columbia. The NOx Budget Trading Program (NBP) annual report, released

today, indicates that summertime NOx emissions were seven percent lower than in 2005,

60 percent lower than in 2000 and 74 percent lower than in 1990.



"The proof is in the numbers. By cutting smog-forming emissions, 55 million Americans in

the eastern United States are breathing easier thanks to President Bush's clean air

policies," said EPA Administrator Stephen L. Johnson. "NOx reductions are not just good

news for the health of our environment and the health of our residents, they are good

news for the health of our economy."



The reduction of NOx – a precursor to ground-level ozone, or "smog" – has helped

reduce ground-level ozone concentrations an average of 5-8 percent in the eastern

United States in the last three years. Four out of five eastern ozone non-attainment areas

now meet the current standard.



The EPA report tracks summertime emission reductions from 1990 to 2006 and assesses

the impact of these reductions on ozone air quality in the eastern region. The largest NOx

reductions occurred in the mid-central area of the eastern United States including Illinois,

Indiana, Kentucky, Ohio, and West Virginia.



The NOx Budget Trading Program is flexible and lets electric generating units choose the

best options to reduce NOx emissions during ozone season for their facilities. Options

include adding NOx emission-control technologies, replacing existing controls with more

advanced technologies or optimizing existing controls. This flexibility, and an active NOx

allowance market, has helped lead to an over 99 percent compliance rate with the

program's requirements.



The 2006 NOx Budget report is online at:

http://www.epa.gov/airmarkets/progress/nbp06.html



Boeing Whistleblower Claims New 787 Unsafe



The Seattle Times reports that a fired Boeing employee has claimed that the

company’s new 787 is unsafe. The man’s whistleblower claim was dismissed by

OSHA, according to the paper, “on the grounds that Boeing's 787 design does not

violate any FAA regulations or standards." The article can be found at

http://seattletimes.nwsource.com/html/boeingaerospace/2003889663_boeing180.ht

ml



GAO Stuff



Combating Nuclear Smuggling: Additional Actions Needed to Ensure Adequate Testing of

Next Generation Radiation Detection Equipment. GAO-07-1247T, September 18

http://www.gao.gov/cgi-bin/getrpt?GAO-07-1247T

Highlights - http://www.gao.gov/highlights/d071247thigh.pdf



Department of Homeland Security: Progress Report on Implementation of Mission and

Management Functions. GAO-07-1240T, September 18 http://www.gao.gov/cgi-

bin/getrpt?GAO-07-1240T

Highlights - http://www.gao.gov/highlights/d071240thigh.pdf



Highlights of a GAO Forum: Transforming Transportation Policy for the 21st Century. GAO-

07-1210SP, September 19.

http://www.gao.gov/cgi-bin/getrpt?GAO-07-1210SP

14



Highlights - http://www.gao.gov/highlights/d071210sphigh.pdf



September 11: Problems Remain in Planning for and Providing Health Screening and

Monitoring Services for Responders, by Cynthia A. Bascetta, director, health care, before the

House Committee on Homeland Security. GAO-07-1253T, September 20.

http://www.gao.gov/cgi-bin/getrpt?GAO-07-1253T

Highlights - http://www.gao.gov/highlights/d071253thigh.pdf



Natural Hazard Mitigation: Various Mitigation Efforts Exist, but Federal Efforts Do Not Provide

a Comprehensive Strategic Framework. GAO-07-403, August 22.

http://www.gao.gov/cgi-bin/getrpt?GAO-07-403

Highlights - http://www.gao.gov/highlights/d07403high.pdf



Influenza Pandemic: Federal Executive Boards' Ability to Contribute to Pandemic

Preparedness, by Bernice Steinhardt, director, strategic issues, before the Subcommittee on

Oversight of Government Management, the Federal Workforce, and the District of Columbia,

Senate Committee on Homeland Security and Governmental Affairs. GAO-07-1259T,

September 28.

http://www.gao.gov/cgi-bin/getrpt?GAO-07-1259T

Highlights - http://www.gao.gov/highlights/d071259thigh.pdf



The Nation's Long-Term Fiscal Outlook: August 2007 Update. GAO-07-1261R, September 28.

http://www.gao.gov/cgi-bin/getrpt?GAO-07-1261R


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