Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
Featured Stories
Citizens' Council for Health Freedom Urges FTC Action Against Detrimental Healthcare Non-Compete Agreements
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WASHINGTON, Oct. 30 -- Citizens' Council for Health Freedom (CCHF), St. Paul, Minnesota, issued a public comment letter to the Federal Trade Commission (FTC) addressing the detrimental effects of employee non-compete agreements in the healthcare sector. The letter emphasizes that such agreements can restrict competition, hinder access to valued medical care, and adversely affect the wellbeing of both healthcare providers and patients.
CCHF argues that non-compete agreements undermine the foundational American principles of freedom to move and compete. The organization points out that these agreements
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WASHINGTON, Oct. 30 -- Citizens' Council for Health Freedom (CCHF), St. Paul, Minnesota, issued a public comment letter to the Federal Trade Commission (FTC) addressing the detrimental effects of employee non-compete agreements in the healthcare sector. The letter emphasizes that such agreements can restrict competition, hinder access to valued medical care, and adversely affect the wellbeing of both healthcare providers and patients.
CCHF argues that non-compete agreements undermine the foundational American principles of freedom to move and compete. The organization points out that these agreementsbind employees to their companies, often forcing them to relocate great distances to find new employment. This practice is especially troublesome in healthcare settings because it can result in patients losing their trusted physicians, whose expertise and familiarity with the patients' medical history are vital for quality care.
The organization further illustrates the increasing number of physicians employed under these restrictive contracts, a trend accelerated by the Affordable Care Act and burdensome electronic health record regulations. As a consequence, a significant percentage of physicians report feelings of dissatisfaction and frustration stemming from administrative pressures and financial constraints, leading to growing concerns about physician shortages amidst a rising Medicare population.
CCHF identifies three major issues linked with the prevalence of non-compete agreements. Firstly, they believe that such contracts contribute to a declining interest among medical professionals in remaining in the field. Many physicians are exiting the profession due to a combination of factors, including decreased compensation, administrative burdens, and the restrictive nature of these agreements.
Secondly, the letter argues that non-compete clauses stifle the emergence of independent medical practices that could introduce competitive pricing and improve patient satisfaction. By restricting physicians from pursuing alternatives, these agreements inhibit the creation of more satisfying and accessible care options.
Lastly, CCHF highlights that non-compete agreements perpetuate corporate control over the healthcare system. The organization asserts that this control drains financial resources and can result in unethical practices, including the exploitation of patients.
While CCHF expresses gratitude toward the Trump administration for recognizing the challenges posed by non-compete agreements, they assert that the issue falls under states' rights, emphasizing that the federal government should refrain from regulating these agreements and instead adhere to constitutional parameters. The FTC is encouraged to consider these points in its evaluations moving forward.
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The letter was written by:
Twila Brase, RN, PHN, Co-founder and President, CCHF
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Read full text of letter here: https://www.regulations.gov/comment/FTC-2025-0463-0087
Center For American Progress Urges Strong Heat Protection Standards
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WASHINGTON, Oct. 30 -- The Center for American Progress (CAP) submitted a public comment letter to the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) concerning its proposed rule for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. CAP's letter underscores the urgency of implementing robust standards to safeguard workers from extreme heat, a hazard that has become increasingly prevalent in various work environments.
In its correspondence, CAP commended OSHA for its initiative to address heat-related illnesses, highlighting that exposure to
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WASHINGTON, Oct. 30 -- The Center for American Progress (CAP) submitted a public comment letter to the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) concerning its proposed rule for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings. CAP's letter underscores the urgency of implementing robust standards to safeguard workers from extreme heat, a hazard that has become increasingly prevalent in various work environments.
In its correspondence, CAP commended OSHA for its initiative to address heat-related illnesses, highlighting that exposure toextreme heat continues to pose significant health risks and economic consequences, including lost productivity and increased healthcare costs. The organization noted that heat is recognized as the leading cause of weather-related fatalities in the United States. CAP's research revealed alarming statistics related to heat-related emergencies, estimating that extreme heat days result in approximately 235,000 emergency department visits and over 56,000 hospital admissions each summer, culminating in nearly $1 billion in healthcare costs.
CAP's previous reports have identified policy proposals aimed at protecting vulnerable populations, particularly low-income and outdoor workers, emphasizing the necessity for a federal heat standard. The organization argues that the lack of a cohesive national guideline leaves states with varying protection levels, effectively creating a patchwork approach that fails to sufficiently safeguard workers against extreme heat.
Notably, CAP expressed concerns regarding the Nevada Heat Standard, suggesting that it lacks crucial elements that ensure workers' safety. The organization warned that if OSHA were to adopt this model, it could lead to diminished protections compared to the existing general duty clause. CAP highlighted inadequacies in the Nevada standard, such as its reliance on subjective judgments by employers regarding heat-related risks, absence of mandatory water provisions, and inadequate preventative measures like requiring shade only after an employee succumbs to heat illness.
Additionally, CAP stressed the importance of robust rest-break mandates, especially for vulnerable workers like crane operators, who are exposed to extreme temperatures in high-demand scenarios. It asserted that practical measures should incorporate flexible rest requirements within a framework of layered controls aimed at minimizing occupational heat illness.
In conclusion, CAP called for OSHA to finalize and implement the proposed standard, advocating for comprehensive safeguards that address the well-documented risks associated with extreme heat exposure in the workplace. The organization remains committed to advancing health policies that uphold the welfare of all American workers.
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The letter was written by:
Jill Rosenthal, Director of Public Health Policy
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Read full text of letter here: https://www.regulations.gov/comment/OSHA-2021-0009-25620
CAP Urges Exceptions for Physician J-1 Visa Holders in Proposed Immigration Rule
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WASHINGTON, Oct. 30 -- The College of American Pathologists (CAP) has issued a public comment letter to the Immigration and Customs Enforcement (ICE) in response to a proposed rule that would establish a fixed time period of admission for non-immigrant academic students, exchange visitors, and representatives of foreign information media. CAP is advocating for exceptions specifically for J-1 visa holders who are physicians, citing concerns over workforce shortages in the medical field.
The proposed rule from ICE, issued on August 27, aims to limit J-1 visas to a maximum of four years or the length
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WASHINGTON, Oct. 30 -- The College of American Pathologists (CAP) has issued a public comment letter to the Immigration and Customs Enforcement (ICE) in response to a proposed rule that would establish a fixed time period of admission for non-immigrant academic students, exchange visitors, and representatives of foreign information media. CAP is advocating for exceptions specifically for J-1 visa holders who are physicians, citing concerns over workforce shortages in the medical field.
The proposed rule from ICE, issued on August 27, aims to limit J-1 visas to a maximum of four years or the lengthof the education program, which poses challenges for international medical graduates (IMGs) specializing in pathology. The impact of such policy changes could further aggravate the already strained medical workforce, with current projections indicating a potential shortage of up to 86,000 physicians by 2036. Demand remains high for pathologists, with over 1,500 job postings expected in 2024 while the number of residency positions stays capped.
CAP emphasizes that most pathologists undergo fellowship training after residency, which is crucial for their professional development. The four-year limit prescribed by the proposed rule would not adequately accommodate this standard practice, leading to potential administrative and procedural difficulties. For instance, marriage between visa extensions and fellowship applications could hinder the processes for both pathologists and their training programs, complicating an already competitive field.
Additionally, CAP highlights the vital role that non-U.S. IMGs play in healthcare across the United States, particularly in underserved areas. Nearly a third of the active pathology workforce comprises IMGs, and these individuals significantly contribute to vital diagnostic services. The Conrad 30 waiver program, which allows IMGs to practice in areas lacking healthcare access, has facilitated the placement of approximately 20,000 physicians over the past 30 years, demonstrating the importance of these programs for local communities.
The letter stresses that undermining the ability of J-1 visa holders to continue their training and practice could result in a loss of skilled physicians, ultimately compromising patient care. CAP urges the administration to reconsider the framework being proposed. With substantial investments made in training IMGs, retaining these highly skilled individuals aligns with national health interests, especially in the context of a growing physician shortage.
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The letter was signed by:
Qihui "Jim" Zhai, MD, FCAP
President, College of American Pathologists
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Read full text of letter here: https://www.regulations.gov/comment/ICEB-2025-0001-21901
Boeing Nominates Executive for FAA Research Committee
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WASHINGTON, Oct. 30 -- The Boeing Co., Seattle, Washington, has submitted a letter to the U.S. Department of Transportation nominating Mike Caimona for membership on the FAA Research, Engineering, and Development Advisory Committee (REDAC). Caimona currently serves as the chief executive officer of Aurora Flight Sciences, a subsidiary of Boeing, and holds the position of vice president of the Aurora Integrated Systems group.
In the nomination, Boeing emphasizes Caimona's extensive experience in the field of aviation technology, highlighting his 25-year career dedicated to leading teams that focus
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WASHINGTON, Oct. 30 -- The Boeing Co., Seattle, Washington, has submitted a letter to the U.S. Department of Transportation nominating Mike Caimona for membership on the FAA Research, Engineering, and Development Advisory Committee (REDAC). Caimona currently serves as the chief executive officer of Aurora Flight Sciences, a subsidiary of Boeing, and holds the position of vice president of the Aurora Integrated Systems group.
In the nomination, Boeing emphasizes Caimona's extensive experience in the field of aviation technology, highlighting his 25-year career dedicated to leading teams that focuson innovative solutions for the future of flight. His work encompasses various applications, including advancements in aircraft configurations, autonomous systems, and propulsion technologies. This breadth of experience positions him as a compelling candidate for REDAC, where he could provide valuable insights.
As part of the nomination package, Boeing included a letter of recommendation, an affirmation of eligibility, contact details, and a biography detailing Caimona's career achievements. The company is optimistic about Caimona's potential contribution to the committee, stressing his profound knowledge of technology necessary for advancing aviation safety and efficiency.
Caimona's previous roles at the company involved significant leadership responsibilities, such as overseeing the development of remote systems for Boeing's Autonomous Systems and leading initiatives aimed at innovating future mobility within the industry. His diverse experience, including time spent enhancing technological capabilities for the Navy during critical operations, further reinforces his qualification for a role on REDAC.
Boeing asserts that Caimona meets all established eligibility requirements for membership on the committee and expresses anticipation for a favorable consideration of his nomination. The decision by the agency regarding the appointment remains pending, and Boeing is hopeful that Caimona's application will be well received.
The FAA Research, Engineering, and Development Advisory Committee plays an essential role in addressing issues related to aviation safety and technological advancement, making it imperative to have leaders like Caimona who have a thorough understanding of the necessary innovations in the aviation sector. As Boeing awaits a response, the company continues to support efforts that enhance the future of flight through focused leadership and innovation.
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The letter was signed by:
Kara Charles
Director, Regulatory Issues Management
Safety, Security & Airworthiness
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Read full text of letter here: https://www.regulations.gov/comment/FAA-2025-2175-0009
American Chemistry Council Urges OSHA to Revise Heat Injury Prevention Standards
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WASHINGTON, Oct. 30 -- The American Chemistry Council (ACC) has submitted a public comment letter to the Occupational Safety and Health Administration (OSHA) regarding its proposed rulemaking on heat injury and illness prevention. The letter outlines concerns raised during an informal hearing held on June 23, 2025, emphasizing the need for a more flexible approach to heat hazards in workplace environments, particularly in the chemical manufacturing industry.
In its comments, ACC highlights that the safety of workers is a paramount priority for its members, and they are committed to sustainable
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WASHINGTON, Oct. 30 -- The American Chemistry Council (ACC) has submitted a public comment letter to the Occupational Safety and Health Administration (OSHA) regarding its proposed rulemaking on heat injury and illness prevention. The letter outlines concerns raised during an informal hearing held on June 23, 2025, emphasizing the need for a more flexible approach to heat hazards in workplace environments, particularly in the chemical manufacturing industry.
In its comments, ACC highlights that the safety of workers is a paramount priority for its members, and they are committed to sustainableoperations that protect not only their employees but also local communities and the environment. The organization pointed to its Responsible Care program, which mandates rigorous safety measures, and noted that member companies have seen record lows in safety incidents during the past year. ACC contends that this proven track record demonstrates the effectiveness of a performance-based approach rather than the prescriptive standards being proposed.
The letter suggests that the current draft rule underestimates the complexity and diversity of the chemical manufacturing industry. ACC advises that OSHA should allow employers to conduct Job Hazard Analyses (JHAs) that can encompass heat hazards alongside other risks. This would enable businesses to tailor their safety measures to the specific challenges they face in different locations and conditions, thus ensuring worker safety while maintaining operational flexibility.
Furthermore, ACC raised concerns about the proposed standards that dictate fixed heat trigger temperatures without considering regional climatic variations. They recommend that employers should have the authority to define their own heat trigger levels based on local conditions and data from sources like the National Weather Service. Such an approach would not only acknowledge environmental differences but also facilitate compliance with OSHA regulations.
ACC's letter also calls for flexibility surrounding the provision of drinking water and break areas for workers, urging OSHA to avoid overly prescriptive requirements that could be impractical. For instance, the need to quantify water access in specific amounts could pose logistical challenges for large facilities. The ACC proposes that general guidelines on adequate water access would be more effective than strict numeric requirements.
The organization emphasized its commitment to reducing heat-related incidents and underlined the importance of employee involvement in developing effective prevention programs. By advocating for adjustments to OSHA's proposed regulations, ACC aims to ensure that heat injury and illness prevention is both effective and adaptable in a dynamically changing industry landscape.
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The letter was signed by:
Rebecca O'Donnell
Associate Director, Process Safety & Occupational Health
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Read full text of letter here: https://www.regulations.gov/comment/OSHA-2021-0009-25614
FlightSafety International Nominates Douglas Gill for REDAC Position
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WASHINGTON, Oct. 30 -- FlightSafety International, Columbus, Ohio, has submitted a letter to the Federal Aviation Administration (FAA) nominating Douglas Gill for a position on the Research, Engineering, and Development Advisory Committee (REDAC). The nomination outlines Mr. Gill's extensive experience in complex systems development, particularly in simulation and training technologies, which the company believes will greatly benefit the FAA's advisory efforts.
In the letter, FlightSafety emphasizes Mr. Gill's qualifications, noting his 40 years in the field, with 27 of those years dedicated to
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WASHINGTON, Oct. 30 -- FlightSafety International, Columbus, Ohio, has submitted a letter to the Federal Aviation Administration (FAA) nominating Douglas Gill for a position on the Research, Engineering, and Development Advisory Committee (REDAC). The nomination outlines Mr. Gill's extensive experience in complex systems development, particularly in simulation and training technologies, which the company believes will greatly benefit the FAA's advisory efforts.
In the letter, FlightSafety emphasizes Mr. Gill's qualifications, noting his 40 years in the field, with 27 of those years dedicated toFlightSafety International. His professional background spans advanced simulation, training, learning technologies, and the integration of these systems, positioning him as a strong candidate for the committee. The organization asserts that his unique perspective and expertise will aid REDAC in formulating recommendations regarding the aviation research portfolio's needs and objectives.
Mr. Gill's contributions to the field include research on cybersickness and extensive work in the development of modeling and simulation system architectures. His involvement in presenting relevant topics at prestigious conferences, such as the Interservice/Industry Training, Simulation and Education Conference, underscores his reputation within the aviation and simulation training communities. FlightSafety highlights Mr. Gill's recent presentations, which focus on critical aspects of simulation technologies that are of interest to the FAA.
Throughout his career, Mr. Gill has demonstrated leadership as the Director of Engineering for FlightSafety's Visual Simulation Systems business unit, where he oversaw product development and managed a diverse team of engineers. His previous experience as a software engineer for Boeing further adds to his credentials in commercial aviation. Additionally, Mr. Gill holds both a Bachelor of Science and a Master of Science in Computer Science.
Beyond his professional accomplishments, the nominee's commitment to community service is notable. FlightSafety notes his volunteer efforts as a Little League baseball manager and his involvement with his church's retreat activities, reflecting his dedication to improving the welfare of those around him.
The organization expresses full confidence in Mr. Gill's ability to represent FlightSafety International and the broader aviation community's interests on REDAC. In the letter, FlightSafety offers to provide additional information regarding Mr. Gill if needed, reinforcing their support for his nomination and his potential contributions to the committee's vital work.
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The letter was signed by:
Anna Taborsky
Senior Vice President
Engineering
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Read full text of letter here: https://www.regulations.gov/comment/FAA-2025-2175-0011
AFSCME Urges OSHA to Strengthen Proposed Heat Illness Prevention Standard
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WASHINGTON, Oct. 30 -- The American Federation of State, County and Municipal Employees (AFSCME) has submitted a public comment letter to the Occupational Safety and Health Administration (OSHA) advocating for stronger protections against heat-related illness in the workplace. This letter supports the proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings standard, reflecting on the tragic circumstances surrounding the death of a member due to heat exposure.
In the letter, AFSCME emphasized the urgent need for OSHA to issue a final standard, noting the inadequacies in
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WASHINGTON, Oct. 30 -- The American Federation of State, County and Municipal Employees (AFSCME) has submitted a public comment letter to the Occupational Safety and Health Administration (OSHA) advocating for stronger protections against heat-related illness in the workplace. This letter supports the proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings standard, reflecting on the tragic circumstances surrounding the death of a member due to heat exposure.
In the letter, AFSCME emphasized the urgent need for OSHA to issue a final standard, noting the inadequacies incurrent measures that led to preventable fatalities. The organization highlighted the death of Ronald Silver II, a Baltimore Department of Public Works employee who succumbed to heat-related illness while working under extreme conditions. AFSCME detailed how Silver and his coworkers faced unsafe heat levels without proper training or resources. Reports of elevated temperatures had been frequent, yet the agency failed to implement adequate safety protocols.
AFSCME's communication underscored how Silver's tragic incident was not isolated. Workers in various industries are susceptible to heat illness, particularly as climate conditions continue to worsen. They argue that the proposed regulations are long overdue, iterating that without effective guidelines, many workers may be at risk.
The organization presented findings from a report by the Center for Labor and a Just Economy at Harvard Law School, which assessed the effectiveness of heat regulations in preventing fatalities. The report noted a substantial reduction in outdoor work deaths linked to heat exposure in states like California, which adopted regulations to protect workers. Following the implementation of the revised Cal/OSHA heat standard in 2015/2016, researchers found that California's fatality rates were significantly lower compared to neighboring states without similar protections.
AFSCME has put forth several recommendations to enhance the proposed standard, including granting workers the authority to stop work when experiencing heat stress, expanding the definition of affected workers to include those in sedentary roles, and ensuring mandatory breaks at lower temperature thresholds. They stress the importance of consistent documentation of heat-related incidents and advocate for prioritizing effective controls in heat illness prevention plans.
According to AFSCME, these improvements are essential in preventing further tragedies and ensuring the safety of the workforce. The organization's plea serves as a compelling reminder of the challenges workers face and the necessity for comprehensive regulations to safeguard their health and lives.
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The letter was signed by:
Ellie Barbarash
Senior Health and Safety Advocate
Department of Research and Collective Bargaining Services
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Read full text of letter here: https://www.regulations.gov/comment/OSHA-2021-0009-25623
ACRO Requests FDA Modifications to Clinical Trial Guidance
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WASHINGTON, Oct. 30 -- The Association of Clinical Research Organizations (ACRO) is urging the Food and Drug Administration (FDA) to modify its draft guidance on Protocol Deviations for Clinical Investigations of Drugs, Biological Products and Devices. The organization submitted a public comment letter to the FDA, addressing concerns over the framework's risk-based approach and its alignment with European Union (EU) and United Kingdom (UK) regulations.
Founded in 2002, ACRO represents some of the leading clinical research organizations globally, employing nearly 400,000 individuals and conducting
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WASHINGTON, Oct. 30 -- The Association of Clinical Research Organizations (ACRO) is urging the Food and Drug Administration (FDA) to modify its draft guidance on Protocol Deviations for Clinical Investigations of Drugs, Biological Products and Devices. The organization submitted a public comment letter to the FDA, addressing concerns over the framework's risk-based approach and its alignment with European Union (EU) and United Kingdom (UK) regulations.
Founded in 2002, ACRO represents some of the leading clinical research organizations globally, employing nearly 400,000 individuals and conductingresearch across various regions. In its letter, ACRO outlined discrepancies between the FDA and its counterparts in the EU and UK regarding terminologies and thresholds for reporting protocol deviations. While the FDA uses terms such as "important protocol deviations," the EU and UK prefer "serious breaches," complicating cross-jurisdictional reporting and compliance.
ACRO's examination of related guidance documents revealed potential confusions in the terminology surrounding reporting requirements. The significant differences in how the FDA and EU/UK categorize protocol deviations could lead to over-reporting, ultimately impacting regulatory processes, data reliability, and participant safety. The draft guidance, according to ACRO, has the potential to create unnecessary burdens on sponsors and regulatory bodies by inflating the number of incidents flagged as serious breaches.
The organization cited particular concerns about two main areas - the misalignment of reporting thresholds for significant protocol deviations and potential protocol waivers for eligibility criteria. ACRO expressed support for the FDA's efforts to reduce the noise in protocol deviation reporting but highlighted risks associated with the proposed definitions that blur distinctions between reporting requirements in the U.S. and its international counterparts.
Moreover, ACRO noted that increased flexibility in managing protocol deviations may inadvertently conflict with practices established by other regulators. It underscored the importance of ensuring that patient safety, data integrity, and compliance remain paramount, especially when allowing deviations from eligibility criteria that have historically been stringently controlled.
As part of its recommendations, ACRO emphasized the need for the FDA to harmonize its guidance with international standards, advocating for clearer definitions and the removal of ambiguous terminology that may contribute to over-reporting.
In its public comment letter, ACRO reiterated its commitment to collaborating with the FDA and other global regulatory bodies to enhance the existing framework, ultimately benefiting clinical trial participants and the integrity of the research process. The insights provided by ACRO aim to facilitate a more coherent and uniform approach to clinical investigations, fostering better regulatory outcomes across the board.
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The letter was signed by:
Karen Noonan
Senior Vice President, Global Regulatory Policy
knoonan@acrohealth.org
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Read full text of letter here: https://www.regulations.gov/comment/FDA-2023-D-5016-0056
