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Legislative Memo

BILL:

A.3749-A (Englebright)

Support

SUBJECT:

"Children's Environmental Health & Safety Policies"

 

DATE:

May 3, 2004

 

The Business Council believes that this legislation, despite its good intentions, would largely duplicate ongoing national efforts and produce uncertain additional public health benefits, but require extensive state resources to implement. Therefore, we recommend against its approval.

Our specific reasons for opposing this bill include the following:

First, the bill creates an public advisory committee to help develop policy regarding public health assessments, but establishes no criteria to assure that the panelists will have relevant expertise. Likewise, the bill excludes both academic and private sector experts from the advisory panel.

Second, the bill imposes a sweeping mandate on affected State agencies and the advisory committee (evaluate any risk assessments on which state standards, regulations and guidance are based, and, within three years, review and revise relevant state regulations to conform to criteria established in the report), while providing zero additional resources to accomplish them. There are literally hundreds of such standards used by the state in its environmental quality programs, and thousands of risk assessments that have served as background in the development of such standards at both the state and federal level. It is difficult to believe that a credible job of assessing this volume of material can be accomplished in the one year study period set forth in this bill.

Third, and perhaps most important, the need for this state-specific initiative is unclear, given ongoing activity at the federal level including:

Instead of the impossibly broad legislative mandate set forth in A.3749, it would be more appropriate for the state to track and respond to these ongoing national assessments of childrens' public health and safety issues, and focus any additional research and/or regulatory resources that might be made available by the legislation on those issues of greatest priority and relevance to New York State.

For these reasons, The Business Council respectfully recommends against approval of A.3749-A.