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Letter from Director of Multinational Business Services, Inc. to Oakland Environmental Services Manager


August 5, 1999

Ms. Brooke A. Levin
Environmental Services Manager
City of Oakland
Daiziel Building
250 Frank H. Ogawa Plaza, Suite 5301
Oakland, California 94612-2034

Dear Ms. Levin:

I am writing for several reasons. First, I would like to thank you for your correspondence of July designed to update me on the most recent developments associated with the City's efforts to eliminate dioxin emissions. As you may recall, I have been working on issues related to the National Toxicology Program's (NIP) Ninth Report on Carcinogens and the criteria for listing substances as "known human carcinogens" in that report. Thus, the information you provided is of great interest and much appreciated.

Of a more generic interest is the impact a draft NTP document is having on legislative and regulatory activities at the local level. I think that codifying all such activities for all substances proposed for the Ninth Report is worthwhile from a public policy perspective.

Consequently, I have referred the dioxin-related developments in San Francisco and Oakland to the Center for Regulatory Effectiveness (CRE), an organization upon whose Board I sit (description attached). The CRE has taken an interest in citing examples of federal/State/local legislative and regulatory activities based upon the proposed Ninth Report. I am advised that CRE plans to start a section on its Web site (www.TheCRE.com) to address these types of issues, with the San Francisco and Oakland ordinances being the first items for coverage. In fact, the CRE plans to open an Interactive Public Docket on the impact that the Ninth Report has on State and local governments, to encourage an ongoing public debate of these topics related to the Ninth Report and to provide officials such as yourself with additional information as you continue to analyze the issue and implement the ordinance. I encourage you to visit the Web site and give us your thoughts.

For these reasons, we would like to work with you to keep the interested public apprised of local developments on use of the Ninth Report. Thus, I would appreciate your keeping us advised regarding relevant actions pertaining to the dioxin ordinances, and I will pass the information along to CRE staff. Useful information, which presently comes to mind, would include the membership of the Regional Task Force. It would also be helpful to know who is preparing the key reports on PVCs and dioxin which are called for under the ordinances, as we would like to contact those individuals to place the draft and/or final reports on the Web site.

Thank you for your assistance, and please feel free to call me should you like to discuss this issue further at any point.

Sincerely

Jim J. Tozzi
Director