Public Comments

View ACOEM's responses to current issues and events.
ACOEM Concerned OSHA's Proposed Changes to Beryllium Rule Could Diminish Worker Health Protections

ACOEM strongly supports OSHA’s proposal to include both construction and shipyard workers under the beryllium rule. However, the College expresses concern that other proposed changes to the rule will diminish health protection for workers exposed to beryllium, compared to the final rule that OSHA promulgated on January 9, 2017.

ACOEM Comments on OSHA Respirable Crystalline Silica Standard for Construction.

ACOEM responds to OSHA regarding effectiveness of engineering and work practice controls in the Respirable Crystalline Silica Standard for Construction, 


Legalization of Marijuana – Implications for Workplace Safety: A Statement from the American College of Occupational and Environmental Medicine

As the U.S. Congress looks at a number of legislative proposals relating to federal marijuana policy, the American College of Occupational and Environmental Medicine (ACOEM) cautions legislators to avoid piecemeal solutions.  Regardless of marijuana’s legal status in a jurisdiction, ACOEM strongly supports legislative proposals that allow employers to prohibit those employed in safety-sensitive positions from working while under the influence of marijuana.

ACOEM Comments to FMCSA Regarding Automated Driving Systems in Commercial Motor Vehicles

Any operator with ultimate responsibility for operating automated driving systems must not have any medical issue which might interfere with their cognitive function to ensure that they are able to react if and when the need arose, states ACOEM in response to FMCSA's request for comments on safe integration of automated driving systems (ADS)-equipped commercial motor vehicles.

ACOEM Supports National Drug Clearinghouse

ACOEM supports a National Clearinghouse tol improve the process of identifying commercial drivers who should not be performing safety-sensitive functions because of a violation of agency drug and alcohol testing regulations.

ACOEM Expresses Appreciation for Amendment Protecting Construction and Maritime Workers from Beryllium

ACOEM expresses its appreciation to Rep. Bobby Scott, Chair of the House Education and Labor Committee, for his amendment to prohibit OSHA for rolling back the beryllium standards for construction and maritime workers.

ACOEM Responds to EPA Proposed Rule on Use of Methylene Chloride-Containing Paint Removal Products By Commercial Entities

It is ACOEM’s opinion that training, certification, and limited access of methylene chloride-containing products for commercial use will not provide enough safeguards to workers, and would present an unreasonable risk of serious illness and death.

ACOEM Comments on DOT Guidance Documents

ACOEM believes there is a need for the DOT to take a more active role in distributing guidance to its intended audiences. Interested parties, such as medical examiners, may be unaware that such guidance exists or overlook its importance given that it is not regulatory.

ACOEM Voices Support for H.R.1309, the Workplace Violence Prevention for Health Care and Social Service Workers Act

ACOEM supports directing OSHA to establish a standard requiring health care and social service employers to  implement a workplace violence prevention plan to prevent and protect employees from violent incidents in the workplace.