February 15, 1999
U.S. Department of Transportation
The purpose of this letter is submit a comment from the American Society of Safety Engineers (ASSE) addressing the 12/22/98 Federal Register Announcement: Pipeline Safety; Incorporation of Standard NFPA 59 in the Liquefied Natural Gas Regulations, (RSPA-97-3002, Notice #2, RIN 2137-AD11).
ASSE serves as Secretariat of seven (7) American National Standards Institute Committees (ANSI) developing safety and health standards which are used by private sector organizations as well as state/Federal governmental agencies such as MSHA, OSHA, etc... ASSE members also sit on over forty (40) additional standards development committees and the Society sponsors educational sessions on standards development. The Society also has eleven (11) technical divisions consisting of: Construction, Consultants, Engineering, Environmental, Health Care, International, Management, Public Sector, Risk Management and Insurance, Mining, Transportation, and Industrial Hygiene, (Attachment #1).
National consensus standards reflect the opinions of the professionals who work at all levels of the public and private sectors in technology development, manufacturing, training, financial analysis, personnel, academia as well as insight from the final end user. This balanced insight enables standards to be crafted in a way which not only benefits and protects users of the standard, but also furthers the interests of the businesses which have been created to meet user demand.
ASSE supports the utilization of consensus standards in the formulation of legislation and regulation for occupational safety and health. Governmental agencies, such as OSHA, CPSC, DOT, NHTSA, etc... should utilize these consensus standards as they provide an efficient/effective supporting mechanism to public sector rule making. ASSE commends DOT for utilizing these existing standards to assist in guiding efficient/effective public policy. We have included our position statement on voluntary national consensus standards to provide additional insight on this issue, (Attachment #2).
We thank you for your attention to this matter, and if you should have any questions or concerns please feel free to contact the Society.
Fred F. Fleming, CSP, OHST
Copy To: ASSE Board of Directors
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