Comments, Letters, & Testimony to Agencies

The Member Scholars and staff of the Center for Progressive Reform often communicate with federal and state agencies, testifying, filing comments on proposed regulations, or bringing important matters to their attention with letters or other means of communication.

All such communications since 2011 are listed on this page. For testimony or other communications with Congress, visit this page
 
Communication with Agencies (Letters, Comments and Testimony) from CPR Member Scholars and staff:

Chemical Safety Board Joint Letter

CPR Policy Analyst Katie Tracy joined more than 50 health and safety activists on a letter to the Chemical Safety Board expressing objection to the exclusion of the victim’s names in the agency’s investigation report of the 2018 fatal blowout at the Pryor Trust gas well in Oklahoma. June 17, 2019.

Date: (June 17, 2019)
PDF: Chemical Safety Board Joint Letter
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Author(s): Katie Tracy

Letter to EPA on 2019 Chesapeake Bay WIPs

CPR joined 35 other members of the Choose Clean Water Coalition in comments to EPA on the 2019 Watershed Implementation Plans submitted by the Chesapeake Bay states, noting that the plans "do not ... provide the necessary assurances and accountability." May 24, 2019.

Date: (May 24, 2019)
PDF: Letter to EPA on 2019 Chesapeake Bay WIPs
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OSHA Whistleblower 11(c) Testimony

Remarks of Katie Tracy on 11(c) Whistleblower Protections at OSHA Stakeholder Meeting, May 14, 2019.

Date: (May 14, 2019)
PDF: OSHA Whistleblower 11(c) Testimony
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Author(s): Katie Tracy

Letter to Department of Labor on OSHA's Whistleblower Program.

The Center for Progressive Reform with 66 organizations and individuals on comments to OSHA recommending improvements to its administration of whistleblower protection provisions under Section 11(c) of the Occupational Safety and Health (OSH) Act, May 7, 2019.

Date: (May 7, 2019)
PDF: Letter to Department of Labor on OSHA's Whistleblower Program.
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Author(s): Katie Tracy

Letter to Department of Labor on Heat Stress, for Workers' Memorial Week.

The Center for Progressive Reform joined 100+ organizations in a Workers’ Memorial Week letter to the Department of Labor calling for a federal heat stress standard to protect workers from the growing dangers of climate change and rising temperatures, April 26, 2019.

Date: (April 26, 2019)
PDF: Letter to Department of Labor on Heat Stress, for Workers' Memorial Week.
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Author(s): Katie Tracy

Comments on EPA's MATS Reconsideration Proposal

Joint comments from CPR's Dan Farber, Catherine O'Neill, Rena Steinzor, and James Goodwin on the EPA's effort to undercut the Mercury and Air Toxics Standard (MATS rule), by eliminating consideration of "co-benefits," and with it, to lay groundwork for eliminating consideration of co-benefits from cost-benefit analyses for future environmental regulation, April 17, 2019.

Date: (April 17, 2019)
PDF: Comments on EPA's MATS Reconsideration Proposal
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Comments on Proposed Waters of the United States Rewrite. Joint comments from more than 20 CPR Member Scholars on the EPA and Army Corps of Engineers proposal to weaken the Waters of the United States rule, April 15, 2019.

Joint comments from more than 20 CPR Member Scholars on the EPA and Army Corps of Engineers proposal to weaken the Waters of the United States rule, April 15, 2019.

Date: (April 15, 2019)
PDF: Comments on Proposed Waters of the United States Rewrite. Joint comments from more than 20 CPR Member Scholars on the EPA and Army Corps of Engineers proposal to weaken the Waters of the United States rule, April 15, 2019.
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Comments on NARA/DOI Proposal. Joint comments from CPR and other institutions to the National Archives and Records Administration's on the Department of Interior's natural resources planning and development document records schedule, November 26, 2018.

Joint comments from CPR and other institutions to the National Archives and Records Administration's on the Department of Interior's natural resources planning and development document records schedule, November 26, 2018.

Date: (Nov. 26, 2018)
PDF: Comments on NARA/DOI Proposal. Joint comments from CPR and other institutions to the National Archives and Records Administration's on the Department of Interior's natural resources planning and development document records schedule, November 26, 2018.
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Joint comments on OSHA's NPRM on tracking workplace injuries

Joint comments on OSHA’s NPRM on tracking workplace injuries. Letter to OSHA from CPR Member Scholars Tom McGarity and Sid Shapiro and CPR Policy Analyst Katie Tracy opposing provisions that would roll back requirements in the 2016 final rule, Improve Tracking of Workplace Injuries and Illnesses, September 28, 2018.

Date: (Sept. 28, 2018)
PDF: Joint comments on OSHA's NPRM on tracking workplace injuries
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Author(s): Thomas McGarity, Sidney Shapiro, Katie Tracy

hogan_MD_Worker_Safety_092118

Letters to Maryland Gubernatorial Candidates re Worker Safety. Read a letter from CPR's Rena Steinzor and Katie Tracy to Maryland gubernatorial candidate Larry Hogan calling for a strengthened Maryland Occupational Safety and Health division, September 21, 2018.

Date: (Sept. 21, 2018)
PDF: hogan_MD_Worker_Safety_092118
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Author(s): Rena Steinzor, Katie Tracy

Letters to Maryland Gubernatorial Candidates re Worker Safety.

Letters to Maryland Gubernatorial Candidates re Worker Safety. Read a letter from CPR's Rena Steinzor and Katie Tracy to Maryland gubernatorial candidate Ben Jealous calling for a strengthened Maryland Occupational Safety and Health division, September 21, 2018.

Date: (Sept. 21, 2018)
PDF: Letters to Maryland Gubernatorial Candidates re Worker Safety.
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Author(s): Katie Tracy, Rena Steinzor

Joint Letter to EPA Administrator Andrew Wheeler re Regulatory Science Proposal

Joint Letter to EPA Administrator Andrew Wheeler re Regulatory Science Proposal. CPR joins in comments from 77 organizations calling on Wheeler to withdraw a proposal from his predecessor, Scott Pruitt, that would distort the science used in the agency's rulemaking, August 15, 2018.

Date: (Aug. 15, 2018)
PDF: Joint Letter to EPA Administrator Andrew Wheeler re Regulatory Science Proposal
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Joint Letter to EPA Administrator Andrew Wheeler re Cost-Benefit Analysis Proposal

Joint Letter to EPA Administrator Andrew Wheeler re Cost-Benefit Analysis Proposal from CPR Member Scholars. Nineteen CPR Member Scholars joined in comments calling on Wheeler to withdraw an Advance Notice of Public Rulemaking on cost-benefit analysis. August 13, 2018.

Date: (Aug. 13, 2018)
PDF: Joint Letter to EPA Administrator Andrew Wheeler re Cost-Benefit Analysis Proposal
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Author(s): David Adelman, Alejandro Camacho, Kirsten Engel, Victor Flatt, Alexandra Klass, Thomas McGarity, Rebecca Bratspies, Heather Elliott, Daniel Farber, Robert Glicksman, Martha McCluskey, Joel Mintz, Richard Murphy, Amy Sinden, Rena Steinzor, Robert Verchick, Sidney Shapiro, Karen Sokol, Joseph Tomain

FSIS Waiver Letters 073118

Date: (Aug. 1, 2018)

Joint Letters to Food Safety Inspection Service re poulty plant line speeds.

Joint Letters to Food Safety Inspection Service re poulty plant line speeds. CPR and 11 other organizations write to oppose requests from four poultry processors (Ozark Mountain Poultry, Peco Poultry, Pilgrim's Pride, Gerber Poultry) for waivers that would allow them to operate their evisceration lines at speeds that pose health and safety risks to workers and consumers. July 31, 2018. 

Date: (July 31, 2018)
PDF: Joint Letters to Food Safety Inspection Service re poulty plant line speeds.
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Joint FSIS letter

Joint FSIS letter. Joint comment letter from CPR Member Scholars Martha McCluskey, Tom McGarity, Sid Shapiro, Rena Steinzor, and CPR Policy Analyst Katie Tracy, calling on USDA/FSIS to withdraw proposed “Modernization of Swine Slaughter Inspection” rule because it raises serious concerns for worker health and safety, Apr. 30, 2018.

Date: (April 30, 2018)
PDF: Joint FSIS letter
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Author(s): Martha McCluskey, Thomas McGarity, Sidney Shapiro, Rena Steinzor, Katie Tracy

Joint FSIS letter

Date: (April 30, 2018)
PDF: Joint FSIS letter
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Joint Letter to Food Safety Inspection Service on Poultry Slaughter Inspection. Joint letter from safety advocates, including Rena Steinzor, April 20, 2012.

Date: (April 25, 2018)
PDF: Joint Letter to Food Safety Inspection Service on Poultry Slaughter Inspection. Joint letter from safety advocates, including Rena Steinzor, April 20, 2012.
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Joint Letter to Agriculture Secretary re Swine Slaughter Rule. Joint Letter from CPR and 18 other organizations urging Secretary Sonny Perdue to conduct public hearings and weigh peer review, March 15, 2018.

Date: (March 23, 2018)
PDF: Joint Letter to Agriculture Secretary re Swine Slaughter Rule. Joint Letter from CPR and 18 other organizations urging Secretary Sonny Perdue to conduct public hearings and weigh peer review, March 15, 2018.
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Letter to Chesapeake Executive Council. Joint letter from Clean Water Coalition to Ben Grumbles, chair, re accounting for climate change, November 28, 2017.

Date: (March 23, 2018)
PDF: Letter to Chesapeake Executive Council. Joint letter from Clean Water Coalition to Ben Grumbles, chair, re accounting for climate change, November 28, 2017.
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Joint Letter to Bay Jurisdictions Principals Staff Committee

Date: (Feb. 26, 2018)
PDF: Joint Letter to Bay Jurisdictions Principals Staff Committee
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Letter to the Department on Tip Rule Data Cover-up.

Date: (Feb. 2, 2018)
PDF: Letter to the Department on Tip Rule Data Cover-up.
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nrdc-sign-on-letter-to-nas-iris_2018-01-30

Letter to the National Academies of Science on IRIS. Joint letter to NAS re the future home of the IRIS toxicity database, co-signed by CPR Executive Director Matthew Shudtz, February 1, 2018. 

Date: (Jan. 30, 2018)
PDF: nrdc-sign-on-letter-to-nas-iris_2018-01-30
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Author(s): Matt Shudtz

Letter to EPA, Army Corps of Engineers on Waters of the United States rewrite. Letter to EPA and Army Corps of Engineers, co-signed by 21 CPR Member Scholars, September 25, 2017.

Date: (Sept. 26, 2017)
PDF: Letter to EPA, Army Corps of Engineers on Waters of the United States rewrite. Letter to EPA and Army Corps of Engineers, co-signed by 21 CPR Member Scholars, September 25, 2017.
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Letter to OSHA on Voluntary Protection Programs. Letter to OSHA's Voluntary Protection Programs, co-signed by CPR's Thomas O. McGarity, Sidney Shapiro, Rena Steinzor, Katherine Tracy, September 15, 2017.

Date: (Sept. 15, 2017)
PDF: Letter to OSHA on Voluntary Protection Programs. Letter to OSHA's Voluntary Protection Programs, co-signed by CPR's Thomas O. McGarity, Sidney Shapiro, Rena Steinzor, Katherine Tracy, September 15, 2017.
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Joint Letter to USDA, October 17, 2014 from Matt Shudtz, National Council of La Raza, Coalition of Black Trade Unionists, Celeste Montforton, re worker safety data collection.

Date: (Sept. 6, 2017)
PDF: Joint Letter to USDA, October 17, 2014 from Matt Shudtz, National Council of La Raza, Coalition of Black Trade Unionists, Celeste Montforton, re worker safety data collection.
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Letter to Several Federal Agencies re HIMP in Hog-Processing.

Date: (June 21, 2017)
PDF: Letter to Several Federal Agencies re HIMP in Hog-Processing.
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Letter to USDA, OIRA re NPIS Attestation. Letter to USDA Food Safety Inspection Service and Office of Information and Regulatory Affairs, co-signed by CPR Policy Analyst Katherine Tracy, June 16, 2017.

Date: (June 21, 2017)
PDF: Letter to USDA, OIRA re NPIS Attestation. Letter to USDA Food Safety Inspection Service and Office of Information and Regulatory Affairs, co-signed by CPR Policy Analyst Katherine Tracy, June 16, 2017.
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Comments to EPA on Implementation of Trump Executive Orders 13771 and 13777. Letter to EPA Associate Administrator Samantha Dravis from 25 CPR Member Scholars and Staff, May 15, 2017.

Date: (May 15, 2017)
PDF: Comments to EPA on Implementation of Trump Executive Orders 13771 and 13777. Letter to EPA Associate Administrator Samantha Dravis from 25 CPR Member Scholars and Staff, May 15, 2017.
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Ghost Rules Letter to Department Heads. Letter to Eight Department Heads

Date: (March 12, 2017)
PDF: Ghost Rules Letter to Department Heads. Letter to Eight Department Heads
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Guidance to Agencies on Implentation of 2-for-1 Deregulatory Executive Order

Date: (Feb. 10, 2017)
PDF: Guidance to Agencies on Implentation of 2-for-1 Deregulatory Executive Order
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Significant New Uses of Chemical Substances Comments. Comments to the Environmental Protection Agency on proposed rules to align its regulations for new chemical uses with OSHA rules

Date: (Nov. 22, 2016)
PDF: Significant New Uses of Chemical Substances Comments. Comments to the Environmental Protection Agency on proposed rules to align its regulations for new chemical uses with OSHA rules
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Forced Arbitration Comments. Comments to the Consumer Financial Protection Bureau re its proposal to limit the use of forced arbitration

Date: (Aug. 23, 2016)
PDF: Forced Arbitration Comments. Comments to the Consumer Financial Protection Bureau re its proposal to limit the use of forced arbitration
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Forced Arbitration Comments. Comments to the Consumer Financial Protection Bureau re its proposal to limit the use of forced arbitration

Forced Arbitration Comments. Comments to the Consumer Financial Protection Bureau re its proposal to limit the use of forced arbitration from Martha McCluskey, Thomas McGarity, Sidney Shapiro, James Goodwin, and Mollie Rosenzweig, August 22, 2016. 

Date: (Aug. 22, 2016)
PDF: Forced Arbitration Comments. Comments to the Consumer Financial Protection Bureau re its proposal to limit the use of forced arbitration
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Author(s): Martha McCluskey, Sidney Shapiro, Mollie Rosenzweig, James Goodwin, Thomas McGarity

TSCA Testimony

TSCA Testimony. Testimony at EPA Stakeholder Meetings on Risk Evaluation, Prioritization and the Toxic Substances Control Act by Katie Tracy, August 9 and 10, 2016. 

Date: (Aug. 9, 2016)
PDF: Tracy_TSCA_Prioritization_Evaluation_Testimony_080916_&_081016.pdf
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Author(s): Katie Tracy

Workplace Safety Civil Penalties Comments. Letter to OSHA on Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments from Martha McCluskey, Thomas McGarity, Sidney Shapiro, and Katherine Tracy, July 11, 2016.

Date: (July 12, 2016)
PDF: Workplace Safety Civil Penalties Comments. Letter to OSHA on Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments from Martha McCluskey, Thomas McGarity, Sidney Shapiro, and Katherine Tracy, July 11, 2016.
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Joint letter to Maryland Department of the Environment Secretary Grumbles and Attorney General Frosh.

Date: (May 5, 2016)
PDF: Joint letter to Maryland Department of the Environment Secretary Grumbles and Attorney General Frosh.
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MS4 letter to EPA. From Evan Isaacson and Katrina Miller, a letter on NPDES Municipal Separate Storm Sewer System (MS4) General Permits, March 21, 2016.

Date: (March 22, 2016)
PDF: MS4 letter to EPA. From Evan Isaacson and Katrina Miller, a letter on NPDES Municipal Separate Storm Sewer System (MS4) General Permits, March 21, 2016.
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Comments on Draft OSHA Guidance: Recommended Practices for Preventing and Addressing Retaliation. CPR's Thomas O. McGarity, Sidney Shapiro, and Katherine Weatherford, January 19, 2016.

Date: (March 1, 2016)
PDF: Comments on Draft OSHA Guidance: Recommended Practices for Preventing and Addressing Retaliation. CPR's Thomas O. McGarity, Sidney Shapiro, and Katherine Weatherford, January 19, 2016.
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Letter to Benjamin Grumbles, Secretary Maryland Department of the Environment, December 17, 2015, from CPR Member Scholar Rena Steinzor and others, urging prompt release of 2015 Frosh Report.

Date: (Dec. 23, 2015)
PDF: Letter to Benjamin Grumbles, Secretary Maryland Department of the Environment, December 17, 2015, from CPR Member Scholar Rena Steinzor and others, urging prompt release of 2015 Frosh Report.
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Letter to DOL on EO 13673 Guidance, August 27, 2015

Date: (Aug. 27, 2015)
PDF: Letter to DOL on EO 13673 Guidance, August 27, 2015
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Shudtz CPR testimony OSHA silica hearing 04 03 2014

Date: (April 3, 2014)
PDF: Shudtz (CPR) testimony - OSHA silica hearing 04-03-2014.pdf
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CPR Bay Agreement Comments

Date: (March 17, 2014)
PDF: CPR Bay Agreement Comments.pdf
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CPR Comments on FDA Generics Rule Final 1

Date: (March 10, 2014)
PDF: CPR Comments on FDA Generics Rule Final(1).pdf
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CPR comments OSHA silica proposal OSHA 2010 0034

Date: (Feb. 12, 2014)
PDF: CPR comments - OSHA silica proposal OSHA-2010-0034.pdf
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Letter to Maryland Department of the Environment urging it to stop waiving pollution permit application fees for Concentrated Animal Feeding Operations, by CPR President Rena Steinzor and Policy Analyst Anne Havemann.

Date: (Dec. 5, 2013)
PDF: Letter to Maryland Department of the Environment urging it to stop waiving pollution permit application fees for Concentrated Animal Feeding Operations, by CPR President Rena Steinzor and Policy Analyst Anne Havemann.
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Comments to the FDA on food safety rules for raw produce on November 15, 2013, by CPR Member Scholars Lisa Heinzerling, Thomas O. McGarity, Sidney Shapiro, and Rena Steinzor, and CPR Policy Analyst Michael Patoka.

Date: (Nov. 14, 2013)
PDF: Comments to the FDA on food safety rules for raw produce on November 15, 2013, by CPR Member Scholars Lisa Heinzerling, Thomas O. McGarity, Sidney Shapiro, and Rena Steinzor, and CPR Policy Analyst Michael Patoka.
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Comments to the FDA on preventive controls for human food production, November 15, 2013

Date: (Nov. 14, 2013)
PDF: Comments to the FDA on preventive controls for human food production, November 15, 2013
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Letter to OIRA re USDA proposal to 'modernize' the poultry inspection system.

Date: (April 9, 2013)
PDF: Letter to OIRA re USDA proposal to 'modernize' the poultry inspection system.
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Letter to ACUS on bias toward industry on international regulatory cooperation

Date: (March 22, 2013)
PDF: Letter to ACUS on bias toward industry on international regulatory cooperation
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Letter to EPA on industry efforts to stall IRIS toxicological assessment through non-germane comments

Date: (Nov. 1, 2012)
PDF: Letter to EPA on industry efforts to stall IRIS toxicological assessment through non-germane comments
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Letter to ACUS on bias toward industry

Date: (Oct. 18, 2012)
PDF: Letter to ACUS on bias toward industry
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Letter to ACUS on science in the administrative process

Date: (Sept. 7, 2012)
PDF: Letter to ACUS on science in the administrative process
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Letter to EPA Nominating Bisphenol A (BPA) for Fourth Contaminant Candidate List.

Date: (June 27, 2012)
PDF: Letter to EPA Nominating Bisphenol A (BPA) for Fourth Contaminant Candidate List.
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Letter to EPA Administrator Lisa Jackson regarding review of IRIS profiles

Date: (June 15, 2012)
PDF: Letter to EPA Administrator Lisa Jackson regarding review of IRIS profiles
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Letter to USTR Ron Kirk on environmental provisions in trade promotion authority legislation.

Date: (May 4, 2012)
PDF: Letter to USTR Ron Kirk on environmental provisions in trade promotion authority legislation.
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Letter to ACUS on collaboration with the Chamber of Commerce

Date: (April 30, 2012)
PDF: Letter to ACUS on collaboration with the Chamber of Commerce
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Comments to FDA on BPA

Date: (April 18, 2012)
PDF: Comments to FDA on BPA
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Letter to EPA on North American Commission for Environmental Cooperation.

Date: (March 29, 2012)
PDF: Letter to EPA on North American Commission for Environmental Cooperation.
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Comments to EPA Science Advisory Board (SAB). On January 24, 2012, CPR Member Scholar Rena Steinzor and Senior Policy Analyst Matthew Shudtz submitted comments on a draft report by the SAB's Committee on Science Integration for Decision Making.

Date: (Jan. 24, 2012)
PDF: Comments to EPA Science Advisory Board (SAB). On January 24, 2012, CPR Member Scholar Rena Steinzor and Senior Policy Analyst Matthew Shudtz submitted comments on a draft report by the SAB's Committee on Science Integration for Decision Making.
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Comments to NIOSH

Date: (Jan. 12, 2012)
PDF: Comments to NIOSH
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Letter to EPA re IRIS toxics database

Date: (Dec. 22, 2011)
PDF: Letter to EPA re IRIS toxics database
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Letter to OMB re EPA's IRIS toxics database.

Date: (July 8, 2011)
PDF: Letter to OMB re EPA's IRIS toxics database.
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Letter to Cass Sunstein re Chemicals of Concern listings

Date: (June 20, 2011)
PDF: Letter to Cass Sunstein re Chemicals of Concern listings
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SBA's Crain and Crain Study. On February 8, 2011, CPR Member Scholar Sidney Shapiro wrote to the Small Business Administration and its Office of Advocacy Office

Date: (Feb. 7, 2011)
PDF: SBA's Crain and Crain Study. On February 8, 2011, CPR Member Scholar Sidney Shapiro wrote to the Small Business Administration and its Office of Advocacy Office
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Coal Ash Rulemaking. On November 19, 2010, CPR President Rena Steinzor and UMaryland Law Clerk Michael Patoka submitted comments to the EPA on the agency's proposed rulemaking on coal ash. News release.

Date: (Nov. 19, 2010)
PDF: Coal Ash Rulemaking. On November 19, 2010, CPR President Rena Steinzor and UMaryland Law Clerk Michael Patoka submitted comments to the EPA on the agency's proposed rulemaking on coal ash. News release.
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Chesapeake Bay Watershed Implementation Plans, submitted comments to the EPA

Date: (Nov. 4, 2010)
PDF: Chesapeake Bay Watershed Implementation Plans, submitted comments to the EPA
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Coal Ash. Rena Steinzor's Testimony on Coal Ash, before an EPA panel conducting regional hearings on its proposed rule, August 30, 2010, Washington, DC.

Date: (Aug. 30, 2010)
PDF: Coal Ash. Rena Steinzor's Testimony on Coal Ash, before an EPA panel conducting regional hearings on its proposed rule, August 30, 2010, Washington, DC.
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OMB Report to Congress on Costs and Benefits of Regulation.

Date: (June 23, 2010)
PDF: OMB Report to Congress on Costs and Benefits of Regulation.
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Letter to White House Counsel re OIRA.

Date: (March 22, 2010)
PDF: Letter to White House Counsel re OIRA.
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OSHA Listens Presentation. On March 4, 2010, CPR Policy Analyst Matt Shudtz made a presentation from Member Scholar Rena Steinzor and himself to an 'OSHA Listens' session, chaired by OSHA Administrator David Michaels.

Date: (March 4, 2010)
PDF: OSHA Listens Presentation. On March 4, 2010, CPR Policy Analyst Matt Shudtz made a presentation from Member Scholar Rena Steinzor and himself to an 'OSHA Listens' session, chaired by OSHA Administrator David Michaels.
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OSHA Hearing on HazCom standard.

Date: (March 3, 2010)
PDF: OSHA Hearing on HazCom standard.
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Toyota Safety Letter. On February 9, 2010, CPR Member Scholars Rena Steinzor and Sidney Shapiro sent a letter to the House Oversight and Government Reform Committee

Date: (Feb. 9, 2010)
PDF: Toyota Safety Letter. On February 9, 2010, CPR Member Scholars Rena Steinzor and Sidney Shapiro sent a letter to the House Oversight and Government Reform Committee
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Comments on Draft Water Quality Report for the Chesapeake Bay. CPR Policy Analyst Yee Huang's comments on EPA's draft 202a Water Quality Report & 203 Strategy for the Chesapeake Bay, January 8, 2010.

Date: (Jan. 14, 2010)
PDF: Comments on Draft Water Quality Report for the Chesapeake Bay. CPR Policy Analyst Yee Huang's comments on EPA's draft 202a Water Quality Report & 203 Strategy for the Chesapeake Bay, January 8, 2010.
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Letter to OIRA on 2009 OMB Report to Congress

Date: (Nov. 4, 2009)
PDF: Letter to OIRA on 2009 OMB Report to Congress
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Comments on ESA Consultation Rules. On August 3, 2009

Date: (Aug. 3, 2009)
PDF: Comments on ESA Consultation Rules. On August 3, 2009
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Letter to White House Science Advisor.

Date: (June 5, 2009)
PDF: Letter to White House Science Advisor.
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Risk Assessment Request to Extend Comment Period.

Date: (June 5, 2009)
PDF: Risk Assessment Request to Extend Comment Period.
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Comments on VOCs via IQA. CPR's Sidney Shapiro and Rena Steinzor's August 3, 2004 response to the paint industry's Information Quality Act challenge to state rules on volatile organic compounds (VOCs) in paint.

Date: (May 6, 2009)
PDF: Comments on VOCs via IQA. CPR's Sidney Shapiro and Rena Steinzor's August 3, 2004 response to the paint industry's Information Quality Act challenge to state rules on volatile organic compounds (VOCs) in paint.
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DOL Risk Assessment Comments. Rena Steinzor and Policy Analyst Matt Shudtz's September 29, 2008 comments on DOL's Risk Assessment proposal.

Date: (May 6, 2009)
PDF: DOL Risk Assessment Comments. Rena Steinzor and Policy Analyst Matt Shudtz's September 29, 2008 comments on DOL's Risk Assessment proposal.
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Final Comments on Obama Regulatory Review Process

Date: (May 6, 2009)
PDF: Final Comments on Obama Regulatory Review Process
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IRIS Letter. Member Scholar Rena Steinzor and CPR Policy Analyst Matt Shudtz's April 27, 2008 letter to EPA Administrator Stephen L. Johnson

Date: (May 6, 2009)
PDF: IRIS Letter. Member Scholar Rena Steinzor and CPR Policy Analyst Matt Shudtz's April 27, 2008 letter to EPA Administrator Stephen L. Johnson
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Letter on Endangered Species Act Consultation Regulation. April 1, 2009 letter to Interior Secretary Salazar and Commerce Secretary Locke

Date: (May 6, 2009)
PDF: Letter on Endangered Species Act Consultation Regulation. April 1, 2009 letter to Interior Secretary Salazar and Commerce Secretary Locke
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Letter to Secretary Ann Veneman re Mad Cow

Date: (May 6, 2009)
PDF: Letter to Secretary Ann Veneman re Mad Cow
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Mercury Credit-Trading. Catherine O'Neill's January 3, 2005 comments on EPA's proposed mercury pollution credit-trading scheme.

Date: (May 6, 2009)
PDF: Mercury Credit-Trading. Catherine O'Neill's January 3, 2005 comments on EPA's proposed mercury pollution credit-trading scheme.
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Preliminary Comments on Obama Regulatory Process Memo. Rena Steinzor's February 20, 2009 letter to OMB chief Peter Orszag

Date: (May 6, 2009)
PDF: Preliminary Comments on Obama Regulatory Process Memo. Rena Steinzor's February 20, 2009 letter to OMB chief Peter Orszag
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Risk Assessment Bulletin. Member Scholar Rena Steinzor's June 15, 2006 letter to OMB urging it to withdraw its proposed risk assessment bulletin.

Date: (May 6, 2009)
PDF: Risk Assessment Bulletin. Member Scholar Rena Steinzor's June 15, 2006 letter to OMB urging it to withdraw its proposed risk assessment bulletin.
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Steinzor CII Comments for DHS. Rena Steinzor's May 2004 comments on the Department of Homeland Security's Procedures for Handling Critical Infrastructure Information (Interim Rule).

Date: (May 6, 2009)
PDF: Steinzor CII Comments for DHS. Rena Steinzor's May 2004 comments on the Department of Homeland Security's Procedures for Handling Critical Infrastructure Information (Interim Rule).
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