Advocacy

Public Comments

View ACOEM's responses to current issues and events.
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 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 Supports H.R.2193, the Asunción Valdivia Heat Illness and Fatality Prevention Act of 2021

ACOEM has expressed its support for H.R. 2193 which directs OSHA to issue a federal standard on the prevention of excessive heat in the workplace for outdoor and indoor workers.

College Urges DOL to Issue Emergency Temporary Standard for COVID-19

On April 13, ACOEM wrote to Martin Walsh, DOL Secretary urging the Department to issue the Emergency Temporary Standard for COVID-19. While commending the Administration on the progress that has been made to vaccinate the American people, ACOEM stressed that COVID-19 is still a present danger in many workplaces and that vaccinations, though accelerating, are not yet at the point where they will stem community spread of the disease.

ACOEM Comments on FMCSA Alternative Vision Standard for CMV Drivers

In comments to the Department of Transportation regarding FMCSA's proposed Alternative Vision Standard, ACOEM raises concerns regarding several aspects of the proposal including questions about what is stable vision and who is responsible for review of the driver's safety record. In addition, ACOEM expressed concern that the basis for the alternative vision standard is flawed.

ACOEM Issues Action Alert -- Urges Membership to Tell Congress to Protect Health Care and Social Service Workers from Workplace Violence

Rep. Joe Courtney (D-CT) has reintroduced the Workplace Violence Prevention for Health Care and Social Service Workers Act (H.R.1195). This bipartisan legislation is intended to protect caregivers from violence on the job. ACOEM has written Rep. Courtney to support his legislation, and is urging ACOEM members to do the same.