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:
Joint Letter on Extending Comment Periods During Coronavirus Emergency

CPR joined with 163 public interest organizations in signing a letter to OMB calling on it to direct executive branch agencies to hold open all active comment periods for pending rulemakings for as long as the Declaration of a National Emergency concerning the coronavirus remains in effect. March 19, 2020.

Type: Letters to Agencies (March 19, 2020)
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CPR Letter to OMB Re Comment Extension During Coronavirus

In March 2020, with the full implications of the novel coronavirus just coming into view, CPR Member Scholars and staff wrote to the Office of Management and Budget calling on OMB to direct all executive branch agencies to hold open all active comment periods for their pending rulemakings as long as the COVID-19 declaration of national emergency remains in effect.

Type: Letters to Agencies (March 18, 2020)
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Author(s): William Andreen, Rebecca Bratspies, Alejandro Camacho, Gilonne d'Origny, Michael C. Duff, Heather Elliott, David Flores, Alyson Flournoy, Bill Funk, Robert Glicksman, Carmen Gonzalez, James Goodwin, Michele Janin, Sarah Krakoff, Thomas McGarity, Darya Minovi, Joel Mintz, Dave Owen, Laurie Ristino, Matt Shudtz, Karen Sokol, Rena Steinzor, Steph Tai, Katie Tracy, Sandra Zellmer
Comments to SEC on Disclosure of Payments by Resource Extraction Issuers

Comments to SEC on Proposed Rule for Disclosure of Payments by Resource Extraction Issuers. Joint letter from Daniel Farber, Richard Murphy and James Goodwin opposing an effort by the SEC to use the Congressional Review Act to justify issuing a weaker rule than what Congress called for in Dodd-Frank.

Type: Letters to Agencies (March 16, 2020)
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Author(s): Daniel Farber, Richard Murphy, James Goodwin
Joint Letter to OMB on Civil Enforcement of Regulations

Comments from 14 CPR Member Scholars on the Trump administration’s attempt to further hamstring civil enforcement of agency regulations, and calling instead for strengthened enforcement.

Type: Letters to Agencies (March 16, 2020)
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Joint Letter to Secretary of Labor re Coronavirus

CPR was one of 30 organizations writing in support of a petition from the AFL-CIO calling for an OSHA emergency temporary standard for infectious disease to address the Coronavirus epidemic. March 13, 2020.

Type: Letters to Agencies (March 13, 2020)
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Joint Letter to MDE on Stormwater Permits and AFOs

CPR was one of 10 organizations calling for significant improvements in the state's stormwater permit program as it relates to industrial animal feeding operations (AFOs), December 26, 2019.

Type: Letters to Agencies (Dec. 26, 2019)
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Author(s): Matt Shudtz
Joint Letter to the President re Federal Advisory Committees

CPR joins 70+ organizations calling on the President to rescind an executive order arbitrarily reducing the number of federal advisory committees, October 4, 2019.

Type: Letters to Agencies (Oct. 4, 2019)
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Joint Letter to Fairfax County, Virginia, Commonwealth's Attorney re deadly worksite trench collapse

CPR’s Rena Steinzor, Katie Tracy, and David Flores joined with 19 individuals and organizations calling on Fairfax Commonwealth’s Attorney Raymond Morrogh to open a criminal investigation into a worksite trench collapse on July 23, 2019 in Fairfax County, Virginia, killing a teenager and injuring an adult male, August 19, 2019.

Type: Letters to Agencies (Aug. 19, 2019)
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Author(s): Rena Steinzor, Katie Tracy, David Flores
Choose Clean Water Coalition Follow-Up Letter to EPA on Chesapeake Bay WIPs

CPR joined other members of the Choose Clean Water Coalition in a letter to the Environmental Protection Agency, taking it to task for failing to ensure that the Watershed Implementation Plans (WIPs) submitted by the Chesapeake Bay states were adequate to achieve the 2025 pollution-reduction goals. August 5, 2019. 

Type: Letters to Agencies (Aug. 5, 2019)
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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.

Type: Letters to Agencies (June 17, 2019)
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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.

Type: Letters to Agencies (May 24, 2019)
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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.

Type: Letters to Agencies (May 14, 2019)
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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.

Type: Letters to Agencies (May 7, 2019)
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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.

Type: Letters to Agencies (April 26, 2019)
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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.

Type: Letters to Agencies (April 17, 2019)
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Author(s): Daniel Farber, Catherine O'Neill, Rena Steinzor, James Goodwin
Comments on Proposed Waters of the United States Rewrite

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.

Type: Letters to Agencies (April 15, 2019)
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Joint Comments on proposal from the National Archives and Department of Interior

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.

Type: Letters to Agencies (Nov. 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.

Type: Letters to Agencies (Sept. 28, 2018)
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Author(s): Thomas McGarity, Sidney Shapiro, 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.

Type: Letters to Agencies (Sept. 21, 2018)
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Author(s): Katie Tracy, Rena Steinzor
Letter to Maryland Govern Larry Hogan re Worker Safety
Letter to Maryland Governor Larry Hogan re Worker Safety
Type: Letters to Agencies (Sept. 21, 2018)
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Author(s): Rena Steinzor, Katie Tracy
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.

Type: Letters to Agencies (Aug. 15, 2018)
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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.

Type: Letters to Agencies (Aug. 13, 2018)
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Author(s): 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
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. 

Type: Letters to Agencies (July 31, 2018)
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Joint to Food Safety Inspection Service re Swing Slaughter Rule

Joint letter to the Food Safety Inspection Service on proposed swine slaughter rule.

Type: Letters to Agencies (April 30, 2018)
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Author(s): Martha McCluskey, Thomas McGarity, Sidney Shapiro, Rena Steinzor, Katie Tracy
Joint Letter from CPR and 18 other organizations urging Secretary Sonny Perdue to conduct public hearings and weigh peer review of Swine Safety Rule

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.

Type: Letters to Agencies (March 15, 2018)
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Coalition letter to Bay Jurisdictions Principals Staff Committee re accounting for climate change in Chesapeake Bay cleanup planning

Coalition letter to Bay Jurisdictions Principals Staff Committee re accounting for climate change in Chesapeake Bay cleanup planning, February 23, 2018

Type: Letters to Agencies (Feb. 23, 2018)
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Letter to the Department of Labor on Tip Rule Data Cover-up

Letter to the Director of the Division of Regulations, Legislation and Interpretation Wage and Hour Division U.S. Department of Labor on Tip Rule Data Cover-up

Type: Letters to Agencies (Feb. 5, 2018)
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Author(s): James Goodwin, Sidney Shapiro, Thomas McGarity, Katie Tracy, Rena Steinzor, Amy Sinden
Joint Letter to the National Academies on IRIS Process
Joint Letter to the National Academies on IRIS Process
Type: Letters to Agencies (Jan. 30, 2018)
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Author(s): Matt Shudtz
Joint letter from Clean Water Coalition to Ben Grumbles, chair, Chesapeake Executive Council, re accounting for climate change

Joint letter from Clean Water Coalition to Ben Grumbles, chair, Chesapeake Executive Council, re accounting for climate change, November 28, 2017.

Type: Letters to Agencies (Nov. 28, 2017)
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Joint letter to EPA, Army Corps of Engineers from 21 CPR Member Scholars on Waters of the United States rewrite

Joint letter to EPA, Army Corps of Engineers from 21 CPR Member Scholars on Waters of the United States rewrite, February 25, 2017.

Type: Letters to Agencies (Sept. 25, 2017)
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Letter to OSHA's Voluntary Protection Programs, September 15, 2017

Letter to OSHA's Voluntary Protection Programs, co-signed by CPR's Thomas O. McGarity, Sidney Shapiro, Rena Steinzor, Katherine Tracy, September 15, 2017.

Type: Letters to Agencies (Sept. 15, 2017)
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Author(s): Rena Steinzor, Katie Tracy, Sidney Shapiro, Thomas McGarity
Coalition Letter to USDA Food Safety Inspection Service and Office of Information and Regulatory Affairs, June 16, 2017.

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.

Type: Letters to Agencies (June 21, 2017)
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Author(s): Katie Tracy
Joint Letter to Several Federal Agencies re HIMP in Hog-Processing

Letter to Several Federal Agencies re the USDA’s Food Safety and Inspection Service (FSIS) to expand the Hazard Analysis and Critical Control Point-based Inspection Models Project (HIMP) pilot program throughout the hog-processing industry.

Type: Letters to Agencies (June 19, 2017)
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Author(s): Katie Tracy
Joint comments to EPA on implementation of Trump Executive Orders 13771 and 13777.

Joint 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.

Type: Letters to Agencies (May 15, 2017)
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Joint letter from CPR Member Scholars on ‘Ghost Rules’ in the regulatory pipeline at the beginning of the Trump administration

Joint letter from CPR Member Scholars to eight department heads on ‘Ghost Rules’ in the regulatory pipeline at the beginning of the Trump administration

Type: Letters to Agencies (March 12, 2017)
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Author(s): Rena Steinzor, Thomas McGarity, Sidney Shapiro
Joint Letter to OIRA re Guidance to Agencies on Implementation of 2-for-1 Deregulatory Executive Order

Joint Letter to OIRA from 31 CPR Member Scholars and Staff re Guidance to Agencies on Implementation of 2-for-1 Deregulatory Executive Order

Type: Letters to Agencies (Feb. 10, 2017)
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Coalition Comments on 'Significant New Uses of Chemical Substances' Rule

Coalition comments to the Environmental Protection Agency on proposed rules to align its regulations for new chemical uses with OSHA rules.

Type: Letters to Agencies (Nov. 21, 2016)
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Comments to the Consumer Financial Protection Bureau re its proposal to limit the use of forced arbitration

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. 

Type: Letters to Agencies (Aug. 22, 2016)
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Author(s): Martha McCluskey, Sidney Shapiro, Mollie Rosenzweig, James Goodwin, Thomas McGarity
Comments to the U.S. Environmental Protection Agency at Stakeholder Meetings on Chemical Risk Evaluation and Prioritization Rulemakings

Comments to the U.S. Environmental Protection Agency at Stakeholder Meetings on Chemical Risk Evaluation and Prioritization Rulemakings by Katie Tracy

Type: Letters to Agencies (Aug. 9, 2016)
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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.

Type: Letters to Agencies (July 12, 2016)
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Author(s): Martha McCluskey, Sidney Shapiro, Thomas McGarity, Katie Tracy
Coalition letter to Maryland Department of the Environment Secretary Grumbles and Attorney General Frosh re enforcement trends

Coalition letter to Maryland Department of the Environment Secretary Grumbles and Attorney General Frosh re downward trends in enforcement proceedings in Maryland.

Type: Letters to Agencies (May 5, 2016)
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Author(s): Rena Steinzor
MS4 letter to EPA from Evan Isaacson and Katrina Miller

Letter to EPA re NPDES Municipal Separate Storm Sewer System (MS4) General Permits, from Evan Isaacson and Katrina Miller, March 21, 2016.

Type: Letters to Agencies (March 21, 2016)
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Author(s): Katrina Miller
Comments on Draft OSHA Guidance for Recommended Practices for Preventing and Addressing Retaliation.

Joint comments on draft OSHA Guidance: Recommended Practices for Preventing and Addressing Retaliation.

Type: Letters to Agencies (Jan. 19, 2016)
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Author(s): Katie Tracy, Thomas McGarity, Sidney Shapiro
Joint Letter to Maryland Department of the Environment urging prompt release of 2015 ‘Frosh Report.’

Joint letter to Benjamin Grumbles, Secretary, Maryland Department of the Environment, from CPR Member Scholar Rena Steinzor and others, urging prompt release of 2015 "Frosh Report," assessing the Department's enforcement activities.

Type: Letters to Agencies (Dec. 17, 2015)
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Author(s): Rena Steinzor
Letter to Department of Labor on Executive Order 13673 Guidance

Letter to Department of Labor on Executive Order 13673 Guidance, "Fair Pay and Safe Workplaces," on behalf of poultry and meatpacking workers.

Type: Letters to Agencies (Aug. 26, 2015)
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Author(s): Matt Shudtz, Katie Tracy
Joint Letter to USDA re worker safety data collection

Joint Letter to USDA from Matt Shudtz, National Council of La Raza, Coalition of Black Trade Unionists, Celeste Montforton, re worker safety data collection.

Type: Letters to Agencies (Oct. 17, 2014)
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Author(s): Matt Shudtz
Matthew Shudtz' testimony at OSHA Hearing on Proposed Standard for Respirable Silica Dust

Matthew Shudtz' testimony at OSHA Hearing on Proposed Standard for Respirable Silica Dust, April 3, 2014

Type: Letters to Agencies (April 3, 2014)
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Author(s): Matt Shudtz
CPR Comments on the Draft Chesapeake Bay Watershed Agreement

CPR Comments on the Draft Chesapeake Bay Watershed Agreement, the first interstate agreement since EPA issued the Total Maximum Daily Load (TMDL) for the Chesapeake Bay.

Type: Letters to Agencies (March 17, 2014)
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Author(s): Rena Steinzor, Anne Havemann
CPR Comments on FDA Generics Rule

CPR Comments on FDA Generics Rule, the Food and Drug Administration’s proposal to revise its regulations governing the procedures for changing product labeling to reflect certain types of newly acquired information in order to extend to generic drug manufacturers the same opportunities afforded “brand name” drug manufacturers.

Type: Letters to Agencies (March 10, 2014)
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Author(s): Sidney Shapiro, Thomas McGarity, James Goodwin
CPR comments on proposed OSHA rule on respirable silica

CPR comments on proposed OSHA rule on respirable silica, encouraging OSHA to act with a sense of urgency

Type: Letters to Agencies (Feb. 11, 2014)
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Author(s): Martha McCluskey, Sidney Shapiro, James Goodwin, Thomas McGarity
Letter to Maryland Department of the Environment re its practice of waiving pollution permit application fees for CAFOs

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.

Type: Letters to Agencies (Dec. 5, 2013)
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Author(s): Rena Steinzor, Anne Havemann
Comments to the FDA on food safety rules for raw produc

Comments to the FDA on food safety rules for raw produce on several CPR Member Scholars and staff

Type: Letters to Agencies (Nov. 15, 2013)
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Author(s): Lisa Heinzerling, Thomas McGarity, Sidney Shapiro, Rena Steinzor, Michael Patoka
Comments to the FDA on preventive controls for human food production

Comments from several CPR Members Scholars and staff to the FDA on preventive controls for human food production, November 15, 2013

Type: Letters to Agencies (Nov. 15, 2013)
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Author(s): Lisa Heinzerling, Thomas McGarity, Sidney Shapiro, Rena Steinzor, Michael Patoka
Letter to OIRA re USDA proposal to 'modernize' the poultry inspection system
Type: Letters to Agencies (April 9, 2013)
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Author(s): Rena Steinzor, Michael Patoka
Letter to ACUS on bias toward industry on international regulatory cooperation

Letter to the Administrative Conference of the United States urging it to ensure greater balance in its continuing work on International Regulatory Cooperation. "In general, ACUS has elevated business and trade concerns over health, safety, and environmental protections throughout its research project on IRC...."

Type: Letters to Agencies (March 21, 2013)
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Author(s): Thomas McGarity, Rena Steinzor, Michael Patoka
Letter to EPA on industry efforts to stall IRIS toxicological assessment through non-germane comments

Letter to EPA on "filter failure," resulting from industry efforts to stall IRIS toxicological assessment through non-germane comments

Type: Letters to Agencies (Nov. 1, 2012)
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Author(s): Rena Steinzor, Matt Shudtz
Letter to ACUS on its bias in favor of industry

Letter to the Administrative Conference of the United States on bias toward the views of regulated industry

Type: Letters to Agencies (Oct. 18, 2012)
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Author(s): Rena Steinzor, Thomas McGarity
Letter to ACUS on science in the administrative process

Letter to the Administrative Conference of the United States on science in the administrative process. "In particular, we are interested in the recommendations related to the role of the White House Office of Information and Regulatory Affairs [and its] ...failure to follow the transparency requirements of Executive Order 12,866 and its interference in matters that involve expert scientific judgment.

Type: Letters to Agencies (Aug. 21, 2012)
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Author(s): Rena Steinzor, Matt Shudtz
Letter to EPA Nominating BPA for Fourth Contaminant Candidate List

Letter to EPA Nominating Bisphenol A (BPA) for Fourth Contaminant Candidate List, based on its known adverse health effects

Type: Letters to Agencies (June 22, 2012)
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Author(s): Noah Sachs, Amy Sinden
Letter to EPA re nominees to new advisory committee on IRIS

CPR letter to EPA Administrator Lisa Jackson regarding candidates for scientific advisory committee of Integrated Risk Information System profiles, with particular attention to candidates' conflicts of interest

Type: Letters to Agencies (June 15, 2012)
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Author(s): Rena Steinzor, Matt Shudtz
Letter to USTR on environmental provisions in trade promotion authority legislation

Letter to U.S. Trade Representative Ron Kirk on environmental provisions in trade promotion authority legislation related to the Trans-Pacific Partnership

Type: Letters to Agencies (May 4, 2012)
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Author(s): John Knox, David Hunter, Carmen Gonzalez
Letter to ACUS on collaboration with the Chamber of Commerce

Letter to Administrative Conference of the United States on co-sponsorship of conference on "incorporation by reference" in the international arena with the U.S. Chamber of Commerce

Type: Letters to Agencies (April 27, 2012)
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Author(s): Thomas McGarity
Joint Letter to Food Safety Inspection Service on Poultry Slaughter Inspection. Joint letter from safety advocates, including Rena Steinzor, April 20, 2012.

Joint letter from safety advocates to the Food Safety Inspection Service on Poultry Slaughter Inspection Rule.

Type: Letters to Agencies (April 20, 2012)
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Author(s): Rena Steinzor
Comments to FDA on BPA

CPR Comments on the American Chemistry Council's Petition to Remove Approval for Polycarbonate Resins in Infant Feeding Bottles and Certain Spill-Proof Cups Due to the Abandonment of these Uses

Type: Letters to Agencies (April 17, 2012)
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Author(s): Noah Sachs, Aimee Simpson
Letter to EPA on North American Commission for Environmental Cooperation

Letter from seven CPR Members Scholars to EPA on U.S. policy toward the Commission for Environmental Cooperation, the regional organization created by the North American Agreement on Environmental Cooperation, and in particular on the Commission’s citizen submissions procedure

Type: Letters to Agencies (March 29, 2012)
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Author(s): Rebecca Bratspies, Carmen Gonzalez, David Hunter, John Knox, Noah Sachs, A. Dan Tarlock
Comments to EPA Science Advisory Board on Science Integration for Decision Making

Comments from CPR Member Scholar Rena Steinzor and Senior Policy Analyst Matthew Shudtz on a draft report by the EPA Scientific Advisory Board's Committee on Science Integration for Decision Making

Type: Letters to Agencies (Jan. 24, 2012)
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Author(s): Rena Steinzor, Matt Shudtz
Comments to NIOSH re carcinogen classification system and recommended exposure limits

Comments to NIOSH re carcinogen classification system and recommended exposure limits, applauding effort to review existing standards and offering specific recommendations

Type: Letters to Agencies (Dec. 22, 2011)
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Author(s): Thomas McGarity, Sidney Shapiro, Wendy Wagner, Matt Shudtz
Letter to EPA re IRIS toxics database, response to American Chemistry Council misinterpretation

Letter to EPA re Integrated Risk Information System database, in response to American Chemistry Council misinterpretation of IRIS-related riders in recent budget legislation

Type: Letters to Agencies (Dec. 22, 2011)
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Author(s): Rena Steinzor, Matt Shudtz
Letter to OMB re EPA's Integrated Risk Information System database, responding to American Chemistry Council

Letter to OMB re EPA's Integrated Risk Information System database, responding to American Chemistry Council letter calling for submission of all current IRIS evaluations to be submitted to the National Academy of Sciences, in an effort to "grind this process to a slow walk."

Type: Letters to Agencies (July 8, 2011)
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Author(s): Rena Steinzor, Wendy Wagner
Letter to OIRA re Chemicals of Concern listings

Letter to OIRA Administrator Cass Sunstein re Chemicals of Concern listings under TSCA

Type: Letters to Agencies (June 20, 2011)
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Author(s): Wendy Wagner, Rena Steinzor, Noah Sachs
Letter to SBA on the 'Crain and Crain' Study.

Letter from Sidney Shapiro to Small Business Administration calling on the Office of Advocacy to withdraw its sponsorship of a report based on seriously flawed research methods

Type: Letters to Agencies (Feb. 8, 2011)
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Author(s): Sidney Shapiro
Comments to EPA on proposed rulemaking on coal ash

Comments from Rena Steinzor to the EPA on its proposed rulemaking on coal ash

Type: Letters to Agencies (Nov. 19, 2010)
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Author(s): Rena Steinzor, Michael Patoka
Comments on Chesapeake Bay Watershed Implementation Plans

Jurisdiction-specific comments to leaders of Bay states and the District of Columbia, and the EPA, on the jurisdictions' Chesapeake Bay Watershed Implementation Plans

Type: Letters to Agencies (Nov. 4, 2010)
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Author(s): Rena Steinzor, Yee Huang
Coal Ash Testimony before an EPA panel conducting regional hearings

Rena Steinzor's Testimony before an EPA panel conducting regional hearings on its proposed rule on Coal Ash

Type: Letters to Agencies (Aug. 30, 2010)
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Author(s): Rena Steinzor
Comments on 2010 OMB Report to Congress on Costs and Benefits of Regulation

Comments from CPR Member Scholars and staff on 2010 OMB Report to Congress on Costs and Benefits of Regulation

Type: Letters to Agencies (June 23, 2010)
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Author(s): Sidney Shapiro, Amy Sinden, Rena Steinzor, James Goodwin
Letter to White House Counsel re ongoing violations of presidential executive orders by OIRA

Letter from several CPR Member Scholars to White House Counsel re three ongoing violations of presidential executive orders by the White House Office of Information and Regulatory Affairs: 1) continuing review of agency guidance documents; 2) exceeding deadlines for completing reviews; 3) failing to disclose "before and after" documents allowing public scrutiny of OIRA revisions to rules

Type: Letters to Agencies (March 17, 2010)
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Author(s): Robert Glicksman, Thomas McGarity, Sidney Shapiro, Amy Sinden, Rena Steinzor
CPR Comments to OSHA on 'HazCom' standard

CPR Comments to OSHA on its Hazard Communication standard

Type: Letters to Agencies (March 5, 2010)
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Author(s): Sidney Shapiro, James Goodwin
CPR Comments at Hearing on OSHA 'HazCom' standard
Type: Letters to Agencies (March 4, 2010)
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Author(s): Matt Shudtz
CPR Member Scholars letter to the House Oversight and Government Reform Committee on Toyota safety recall

CPR Member Scholars Rena Steinzor and Sidney Shapiro's letter to the House Oversight and Government Reform Committee re the failure of the National Highway Transportation Safety Administration to address in a timely fashion engineering failures in certain Toyota models

Type: Letters to Agencies (Feb. 9, 2010)
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Author(s): Sidney Shapiro, Rena Steinzor
Comments on Draft Water Quality Report for the Chesapeake Bay.

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

Type: Letters to Agencies (Jan. 8, 2010)
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Author(s): Yee Huang
Letter to OIRA on 2009 OMB Report to Congress

Comments to the White House Office of Information and Regulatory Affairs on 2009 OMB Report to Congress re the costs and benefits of regulation, by Amy Sinden, Rena Steinzor and James Goodwin

Type: Letters to Agencies (Nov. 5, 2009)
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Author(s): Amy Sinden, Rena Steinzor, James Goodwin
Comments on Endangered Species Act Consultation Rules

Comments on Endangered Species Act Consultation Rules, supporting withdrawal of Bush administration "midnight rule" weakening enforcement

Type: Letters to Agencies (Aug. 3, 2009)
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Author(s): Mary Jane Angelo, Holly Doremus, Dan Rohlf, James Goodwin
Letter to White House Science Advisor on Scientific Integrity

Letter to White House Science Advisor on Scientific Integrity from CPR's Rena Steinzor

Type: Letters to Agencies (May 13, 2009)
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Author(s): Rena Steinzor
Letter to Interior and Commerce Secretaries on Endangered Species Act Consultation Regulation.

Letter on Endangered Species Act Consultation Regulation. April 1, 2009 letter to Interior Secretary Salazar and Commerce Secretary Locke

Type: Letters to Agencies (April 1, 2009)
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Author(s): Robert Glicksman, Alejandro Camacho, Dan Rohlf, Margaret Giblin
Final Comments on Obama Regulatory Review Process

Final Comments on Obama Regulatory Review Process, joint letter from several CPR Member Scholars

Type: Letters to Agencies (March 16, 2009)
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Author(s): Robert Glicksman, Thomas McGarity, Sidney Shapiro, Amy Sinden, Rena Steinzor, Robert Verchick
Preliminary Comments on Obama Regulatory Process Memo.

Preliminary Comments on Obama Regulatory Process Memo. Letter to OMB chief Peter Orszag.

Type: Letters to Agencies (Feb. 20, 2009)
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Author(s): Rena Steinzor
Comments on the Department of Labor's Risk Assessment proposal

Rena Steinzor and Policy Analyst Matt Shudtz's comments urging the Department of Labor to withdraw its Risk Assessment proposal.

Type: Letters to Agencies (Sept. 29, 2008)
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Author(s): Rena Steinzor, Matt Shudtz
Coalition letter requesting extension of comment period on OSHA risk assessment policy

Coalition letter requesting extension of comment period on OSHA risk assessment policy, signed by more than 40 policy experts, including CPR's Rena Steinzor

Type: Letters to Agencies (Sept. 5, 2008)
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Author(s): Rena Steinzor
Letter to EPA Administrator Stephen L. Johnson re IRIS

Member Scholar Rena Steinzor and CPR Policy Analyst Matt Shudtz's April 27, 2008 letter to EPA Administrator Stephen L. Johnson re the Integrated Risk Information System database

Type: Letters to Agencies (April 28, 2008)
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Author(s): Rena Steinzor, Matt Shudtz
Letter to OMB urging it to withdraw its proposed risk assessment bulletin.

Risk Assessment Bulletin. Member Scholar Rena Steinzor's June 15, 2006 letter to OMB urging it to withdraw its proposed risk assessment bulletin.

Type: Letters to Agencies (June 15, 2006)
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Author(s): Rena Steinzor
Comments on EPA's proposed mercury pollution credit-trading scheme.

Catherine O'Neill's comments on EPA's proposed mercury pollution credit-trading scheme.

Type: Letters to Agencies (Jan. 3, 2005)
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Author(s): Catherine O'Neill
Comments on Volatile Organic Compounds in paint, responding to industry Information Quality Act request

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: "Wrong in principle, wrong on the law, and wrong on the facts."

Type: Letters to Agencies (Aug. 3, 2004)
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Author(s): Sidney Shapiro, Rena Steinzor, Margaret Giblin
Comments on the Department of Homeland Security's Procedures for Handling Critical Infrastructure Information (Interim Rule).

Rena Steinzor's May 2004 comments on the Department of Homeland Security's Procedures for Handling Critical Infrastructure Information (Interim Rule).

Type: Letters to Agencies (May 20, 2004)
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Author(s): Rena Steinzor, Karen Sokol
Letter to Secretary Ann Veneman re Mad Cow

Letter to Secretary of Agriculture Ann Veneman asking her to "correct the public record with respect to misleading statements contained in USDA’s December 30 press release on Bovine Spongiform Encephalopathy (mad cow disease) and to ask [her]to take more effective action to protect U.S. consumers from the risk of contracting variant Creutzfeldt-Jacob Disease."

Type: Letters to Agencies (Jan. 13, 2004)
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Author(s): Thomas McGarity

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