Advocacy

Public Comments

View ACOEM's responses to current issues and events.
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.

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.