> >I think a lot of the statements surrounding costs are SSWAGs - (Semi-Scientific)WAGs. Long on estimates, short on data on how those estimates were obtained.

Yes, my experience of the CFATS discussions related to academic labs was that the regulators also made WAGs as to what their universe of interest was and the level of compliance that was necessary to achieve their goals. In my opinion, a large part of the 83% reduction in initial costs estimates resulted because the DHS assumed that a much larger universe of concern existed than they ended up regulating. The second conceptual hurdle was the traditional one of treating labs as manufacturing sites rather than idea factories.

As some level, it took 13 years to answer the questions that review of the regulation before its promulgation asked. I'm not saying that another process is possible, but I think that it's good to put error bars on cost estimates associated with new government initiatives.

- 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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