OSHA Instruction CPL 1.2 October 30, 1978

OCT 11, 1977

MEMORANDUM FOR OSHA SENIOR STAFF

THRU: Basil J. Whiting, Jr.

FROM: Grover C. Wrenn SUBJECT: Interagency "Early Warning System"

One of the Interagency Regulatory Liaison Group programs now being implemented is the Early Warning of Alert System. The function of the System is to quickly notify other Federal Agencies participating in the Liaison Group of newly identified health hazards or of planned or impending regulatory actions. The regulations and enforcement programs of these Agencies affect many of the same industries and are concerned with related health hazards. Early notification of hazards or regulatory actions will facilitate coordinated actions, aid in data gathering, and will help maximize protection of public and environmental health while minimizing conflicting, inconsistent or duplicative requirements placed on the regulated industry.

Each of the four participating Agencies has designated an individual to be the coordinator and primary contact person for the Alert System. For the interim, I will be the OSHA coordinator. It is the coordinator's responsibility to assure that new rulemakings or significant new findings on a hazardous substance are communicated to the other three Agencies, and that similar reports from the other Agencies are communicated to appropriate OSHA staff. It is anticipated that further coordination would be carried out by technical and program staff of each of the Agencies, with policy direction being provided by the Agency principals. The Regulatory Development Work Group, of which the coordinators are members, will act in an oversight function, maintaining a current inventory of coordinated rulemakings and "trouple-shooting" any problems that the staffs could not resolve.

Information that should be brought immediately to my attention to communicate through the Alert System would include new research challenging our knowledge of the relative toxicity of a given substance, petitions for the regulation of a substance, epidemiological findings of significantly greater occurrences of an occupational disease in a workplace, and compliance actions which could impact on the regulatory policies or programs of another Agency. Other actions which should be communicated to other Agencies routinely would include OSHA guidelines on toxic

OSHA Instruction CPL 1.2 October 30, 1978

materials, program memoranda relating to health standards, and standards development projects to evaluate the adequacy of existing standards. One may choose not to participate in coordinated efforts on a given rulemaking if the problem is not relevant to OSHA's programs or because of resource limitations, but it is important that the Agencies are aware of each others actions.

Please be certain that a member of your staff is designated as a contact person for further information if your office originates the alert. That person would be identified by me to the other Agency coordinators and would be expected to assume lead responsibility in coordinating the exchange of information on these matters. Any recommendations developed by coordinated actions, such as joint hearings or investigations, should be submitted to the Assistant Secretary through my office.

If you have any further questions on this procedure or on the purpose of the program, please contact me at extension 37081 or Bob Cluck at extension 37105.