From 1991 to 1997, I was the Group Leader, Environmental Restoration at the
USDOE Pinellas Plant wherein methylene chloride was one of the main
constituents of groundwater contamination and in some groundwater wells as
much as 1% of the groundwater sampled was determined to be methylene
chloride. Prior to groundwater contamination, methylene chloride was used in the
processes associated with weapons component manufacturing. Because of the
timing of regulation changes and health hazard knowledge, the standard should be
modified to address previously exposed employees consistent with what was done
with the Cadmium standard. Also, in cases such as GOCO facilities like the
USDOE Pinellas Plant, it would be helpful if it was clear to whom the
responsibilities belong, the USDOE as the facility owner who oversaw operations
and compliance or the Management & Operating contractors such as GE or
Lockheed Martin who employed the workers. Lastly, because these facilities only
became subject to the OSH Act pursuant to the Federal Facilities Compliance Act
it would need to be clear what relevant time periods are covered by such a
provision.
Brent Weesner
Comments Submitted by: Brent Weesner
This is comment on Notice
Regulatory Flexibility Act Review of the Methylene Chloride Standard
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