Public Comments

View ACOEM's responses to current issues and events.
ACOEM Responds to H.R. 6087, Improving Access to Workers' Compensation for Federal Workers Act of 2022

On July 20, 2022, ACOEM registered its concerns regardingh H.R. 6087, the Improving Access to Workers’ Compensation for Injured Federal Workers Act of 2022.

College Requests Membership on ACET

The Advisory Council for the Elimination of Tuberculosis (ACET) provides advice and recommendations regarding the elimination of TB to the HHS Secretary, the Assistant Secretary for Health, and the Director of CDC. ACOEM has requested that the Secretary of DHHS, the Director of CDC, and the Chair of ACET, consider including the College as a liaison member of the Advisory Council.

ACOEM Responds to Mandatory Guidelines for Federal Workplace Drug Testing Programs Using Urine

On June 6, 2022, ACOEM commented on SAMHSA's proposed Mandatory Guidelines for Federal Workplace Drug Testing Programs using Urine. The College focused on those guidelines which will have the greatest impact on medical review officers or those who administer a drug testing program.

ACOEM Supports Petition to Establish Subcommittee on Prevention of Occupational Lead Exposure

ACOEM has expressed its support for a a submission to the Lead Exposure Prevention Advisory Committee (LEPAC), a CDC Federal Advisory Committee, entitled “Petition to LEPAC to Establish a Subcommittee on Prevention of Occupational Lead Exposure.” 

ACOEM Supports Addition of Oral Fluid Testing to DOT Drug Testing Programs

On April 22, ACOEM provided comments to the Department of Transportation (DOT) regarding its Notice of Proposed Rulemaking (NPRM) concerning the addition of oral fluid specimen testing to its transportation industry drug-testing program. In its comments, the College reinforced its support for the addition of oral fluid testing to the federal repertoire, noting that it agreed with DOT that oral fluid testing is now to the level of scientific validity and specificity on par with urine testing. The College also provided specific comments regarding aspects of the final rule including split specimens, uncancelling a result, and opposite gender directly observed urine collection.

ACOEM Responds to CDC Request for Comments on Opioids Guideline

On April 5, ACOEM provided feedback to the Centers for Disease Control and Prevention (CDC) regarding its Clinical Practice Guideline for Prescribing Opioids – United States, 2022. ACOEM expressed its support for many of the changes made to CDC’s original Opioids Guideline (2016) and for the overall review process.

ACOEM Comments on EPA Draft Scope of Risk Evaluation for Asbestos

On February 18, ACOEM submitted comments to EPA in response to the agency’s Draft Scope of the Risk Evaluation for Asbestos Part 2: Supplemental Evaluation Including Legacy Uses and Associated Disposals of Asbestos. The College expressed support for the inclusion of legacy uses and disposal activities, the expansion of the definition of asbestos to include asbestiform fibers other than chrysotile (i.e., amphibole fibers), and that asbestos contamination of vermiculite from Libby, Montana, was addressed. The College did, however, convey concerns about the inclusion of talc per se, encouraging EPA to focus on the contaminating asbestos in talc and not the talc itself.

ACOEM Provides Comments on the Emergency Temporary Standard (ETS) for Occupational Exposure to COVID-19

On August 20,2021, ACOEM expressed its support for OSHA's Emergency Temporary Standard (ETS) for Occupational Exposure to COVID-19. ACOEM highlighted the need for the ETS to protect health care and health care support service workers from occupational exposure to COVID-19 in settings where people with COVID-19 are reasonably expected to be present and offered recommendations regarding physicial barriers, medical removal, contact tracing, etc.