> I also wonder if the EPA folks were aware of regulations promulgated by USDA and other agencies involved in animal research, and/or how the question was posed.
>
This is an interesting question. I had the opportunity to work with EPA in the development of a new rule and see the process up close. One reason that the process takes so long is that the agencies do a reasonably careful scan of other federal requirements related to the topic at hand. This is challenging, as there are many different languages and mandates that address the same topic across the federal and state governments. (One "cute" one is that Keene State heats the campus with 100% reclaimed non-fossil biofuels, but we have to add ten gallons of fossil fuel-based diesel by hand to every delivery of a truckful of renewable fuels to satisfy road tax requirements.)

When agencies find conflicts for a new rule, they sometimes work with the other agency to address those; other times they decide to ignore those conflicts. As you point out, a specific use of a chemical is the intersection of a variety of complicated regulations based on different stakeholders and considerations, so the agency leaves it up to the chemical users to figure it out in real life.

Which is why many of us have jobs ;).

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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