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Small Business Regulatory Review and Reform Initiative

Six-Month Status Update on r3 Top 10 Reviews/Reforms of Current Rules
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The Office of Advocacy announced the 2008 r3 Top 10 nominations for review and reform on February 28, 2008. In the six months since the Top 10 announcement, Advocacy has worked with the agencies and with small business stakeholders to move forward on the ten recommendations. This chart provides a status update as of August 28, 2008. The chart will be updated to reflect any responses, announcements, reviews, and reforms announced by the respective agencies.

Nomination
Status as of August 2008

Update Air Monitoring Rules for Dry Cleaners to Reflect Current Technology
EPA should revise outdated or inaccurate testing requirements so that modern dry cleaners can have a valid method for demonstrating compliance.

Advocacy contact: Keith Holman 202-205-6533

EPA
Revising the New Source Performance Standard (NSPS) for petroleum dry cleaning equipment is a priority for EPA. more

Flexibility for Community Drinking Water Systems
EPA should consider expanding the ways for small communities to qualify to meet alternative drinking water standards, provided that the alternative standards are protective of human health and are approved by state authorities.

Advocacy contact: Kevin Bromberg 202-205-6533

EPA
On March 2, 2006 EPA announced a review of the affordability criteria for small systems (71 Federal Register 10671). more

Simplify the Rules for Recycling Solid Waste
EPA should simplify the rules for recycling useful materials that, because of their current classification, must be handled, transported, and disposed of as hazardous wastes.

Advocacy contact: Kevin Bromberg 202-205-6533

EPA
On October 28, 2003, EPA issued a proposal to revise the definition of solid waste. more

EPA Should Clearly Define “Oil” in its Oil Spill Rules
EPA should clarify the definition of “oil” in its oil spill program, so that small facilities that store nonpetroleum-based products are not unintentionally captured by spill prevention program requirements.

Advocacy contact: Kevin Bromberg 202-205-6533

EPA
On May 30, 2008 EPA and representatives of the U.S. Coast Guard met with small business stakeholders. more

Update Flight Rules for the Washington, DC, Metropolitan Area
FAA and other agencies should review the flight restriction rule for the region surrounding Washington, DC, to determine whether the rule could be revised to avoid harming small airports within the region.

Advocacy contact: Bruce Lundegren 202-205-6533

DOT/FAA
On March 19, 2008 the FAA notified Advocacy by letter that it expects to finalize the flight restriction rules by January 2009. more

Eliminate Duplicative Financial Requirements for Architect-Engineering Services Firms in Government Contracting
The duplicative retainage requirement should be removed or reduced in architect-engineering services contracts, as has been done for other services.


Advocacy contact: Major Clark 202-205-6533

FAR Council
The Office of Federal Procurement Policy (OFPP) submitted Advocacy's r3 retainage proposal to the FAR Council. The FAR case number assigned to this issue is 2008-015. more

Simplify the Home Office Business Deduction
The IRS should revise their rules to permit a standard deduction for home-based businesses, which constitute 53 percent of all small businesses.

Advocacy contact: Dillon Taylor 202-205-6533

Treasury/IRS
On March 14, 2008, the IRS informed Advocacy that this issue has been assigned to IRS attorneys for review. more

Update MSHA Rules on the Use of Explosives in Mines to Reflect Modern Industry Standards
MSHA should update its current rules to be consistent with modern mining industry explosives standards.

Advocacy contact: Bruce Lundegren 202-205-6533

DOL/MSHA
MSHA has not formally announced its intention to update explosives standards. more

Update OSHA’s Medical / Laboratory Worker Rule
The current rule should be reviewed to determine whether it can be made more flexible in situations where workers do not have potential exposure to bloodborne pathogens.

Advocacy contact: Bruce Lundegren 202-205-6533

DOL/OSHA
OSHA has not formally announced its intention to review rules governing exposure to bloodborne pathogens.

Update Reverse Auction Techniques for Online Procurement of Commercial Items
The current reverse auction techniques should be reviewed to determine whether a government-wide rule is necessary to create a more consistent and predictable online process.

Advocacy contact: Major Clark 202-205-6533

OFPP
On October 4, 2006 the Office of Federal Procurement Policy (OFPP) announced to the acquisition community that this action item is under review to determine the appropriate course of action for this acquisition tool. more

    U.S. Federal Government Abbreviations
      (EPA) Environmental Protection Agency
      (FAA) Federal Aviation Administration, U.S. Department of Transportation
      (FAR Council) Federal Acquisition Regulation Council
      (IRS) Internal Revenue Service, U.S. Department of the Treasury
      (MSHA) Mine Safety and Health Administration, U.S. Department of Labor
      (OSHA) Occupational Safety and Health Administration, U.S. Department of Labor
      (OFPP) Office of Federal Procurement Policy, Office of Management and Budget

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