Public Comments

View ACOEM's responses to current issues and events.
ACOEM Supports Reauthorization of Pandemic and All-Hazards Preparedness Act

On March 28, 2023, ACOEM wrote Senate members of the Committee on Health, Education, Labor and Pensions to express strong support for the reauthorization of the Pandemic and All-Hazards Preparedness Act (PAHPA). In response to the question of what gaps exist in HHS' current activities and capabilities to fulfill the intent of PAHPA, ACOEM noted the need to support the training and sustainment of OEM physicians who are a critical resource enabling organizations to respond rapidly and judiciously to emergent situations that may negatively affect their employees, the public, or operations.

ACOEM Comments on OSHA's Voluntary Protection Programs

On March 22, 2023, the American College of Occupational and Environmental Medicine (ACOEM) provided comments to the U.S. Occupational Safety and Health Administration (OSHA) regarding the future direction of the Agency’s Voluntary Protection Programs (VPP).

ACOEM Comments on OSHA Proposed Rule on Blood Lead Level for Medical Removal

On October 28, 2022, ACOEM provided comments to OSHA on the agency’s Advance Notice of Proposed Rule Making (ANPRM) — Blood Lead Level for Medical Removal. In its comments, ACOEM expressed support for OSHA’s objective to update its lead standard to adequately protect American workers.

MARCOEM Advocates Against NJ Legislation Mandating Insurance Coverage of Dispensary-Purchased ‘Medical’ Cannabis and Cannabis-Derived Products

The Mid-Atlantic Regional College of Occupational and Environmental Medicine (MARCOEM), a component society of ACOEM, has established a leadership position in opposition to legislation in New Jersey that would require workers’ compensation carriers, health insurance plans, and state health programs to cover the cost of dispensary-purchased ‘medical’ cannabis and cannabis-derived products.

ACOEM Comments on Draft Medical Examiner Handbook

On September 14, 2022, FMCSA published a call for comments regarding Qualifications of Drivers: Medical Examiner’s Handbook and Medical Advisory Criteria Proposed Regulatory Guidance in the Federal Register. In response, ACOEM submitted comments to FMCSA regarding the draft Handbook. 

ACOEM Responds to DHHS’ National Research Action Plan on Long COVID

Functional recovery and return to work are crucially important outcomes of interest for long COVID and are among the foundations of the specialty of occupational and environmental medicine. The American College of Occupational and Environmental Medicine (ACOEM) appreciates the opportunity to respond to the Department of Health and Human Services’ (HHS) National Research Action Plan on Long COVID.

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.