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Previous by Date: Subject: Re: [DCHAS-L] [FR] Documents citing 79 FR 48693 Date: Monday, June 22, 2020 at 11:43:33 AM Author: "Stuart, Ralph" <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>

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As one involved with the writing of the original ACS response to the
proposed rule, I agree we had much uncertainty. Even with that, the end
result was a markedly reduced impact on the research and academic community.
And, while there have been a few well-publicized "diversions" of research
materials since CFATS was enabled, there have not been any known threats or
actions of the terrorism ilk within this community.

The initiation of CFATS had much uncertainty and we all did our best to
identify the facts and estimate (speculate?) on the impacts. I think that
(aside from those with obvious agendas) the same situation prevails today
with COVID. In 10-20 years historians will point out, correctly, the faulty
assumptions and incorrect estimates.

A colleague of ours lamented recently that "science will suffer greatly" as
the general public does not appreciate that what is being played out as we
learn about the virus and the disease reflects the way scientific progress
occurs. It is not the neat package portrayed on CSI.

Stay healthy and stay safe
Neal

Reply from:
NEAL LANGERMAN
(619) 990-4908

-----Original Message-----
From: ACS Division of Chemical Health and Safety On
Behalf Of Stuart, Ralph
Sent: Monday, June 22, 2020 8:44 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] [FR] Documents citing 79 FR 48693

> >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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