Comments Submitted by: Brent Weesner

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