A blog reader called the other day to see if she could excerpt “Regulatory Whack-a-Mole“, below, for her association newsletter.(We blushingly agreed.) In the course of our conversation, she put her finger on an issue that we danced around but didn’t directly hit: FACA.
FACA is the Federal Advisory Committee Act. Enacted a few decades ago, its purpose is to make sure that any group that provides ongoing advice to the federal government does so in an open and transparent way. Under FACA, a federal agency continually seeking advice from a standing outside group needs to charter the group, open any meetings to the public and provide a public record of all proceedings.
Since OSHA appears to be ceding its authority wholesale to ACGIH, ought this not be subject to the rigors of FACA? At the very least, ACGIH meetings where the work is done should be open to the public and a public record made of the proceedings, no? At the end of day, these folks appear to have far more authority than groups that have far more scrutiny. Maybe it’s time for the FACA-ization of the ACGIH.
Let the sun shine.
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