Public Comments

The GW Regulatory Studies Center scholars independently pursue high quality research to illuminate regulatory theory, policy, and practice; the Center does not take institutional positions on issues. To maintain its independence and the quality and integrity of its products, the GW Regulatory Studies Center does not accept funding that stipulates predetermined results or that limits dissemination of its scholarly activity or research. While the Center files public comments on specific regulations, it does so from the perspective of the public interest, and will not accept direct funding for individual comments.

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Public Interest Comment on DHS's Proposed Rule: Removal of International Entrepreneur Parole Program

June 29, 2018

By: Daniel R. Pérez & Lisa Zimmer
The Department of Homeland Security is proposing to eliminate its international entrepreneur program, which was created in 2017, despite the agency's previous findings that the program will increase economic growth, job creation, and U.S. based innovation. The proposal also runs contrary to the administration's declared policy of shifting towards a more merit-based immigration system, decreasing regulatory costs, and demonstrated early success from the program.

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Public Interest Comment on FDA’s Advanced Notice of Proposed Rulemaking: Tobacco Product Standard for Nicotine Level of Combusted Cigarettes

June 15, 2018

By: David Zorn, Ph.D.
In a comment filed on the "Advance Notice of Proposed Rulemaking, Tobacco Product Standard for Nicotine Level of Combusted Cigarettes," Zorn observes that the FDA's plan to develop a maximum nicotine level for cigarettes is a novel and creative approach to promote public health. He also examines some drawbacks of the FDA's plan, including the speculative and unproven nature of the underlying hypothesis, as well as the limitations of removing access to only combustible sources of nicotine.

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Public Interest Comment on The Food Safety and Inspection Service’s proposed rule: Egg Products Inspection Regulations

June 12, 2018

By: Richard B. Belzer, Independent Consultant
This public interest comment provides an overview of the Food Safety Inspection Service’s (FSIS) proposed rule requiring official plants that process egg products to develop and implement Hazard Analysis and Critical Control Point Systems and Sanitation Standard Operating Procedures. FSIS would eliminate certain existing requirements, and add new labeling requirements. The comment reviews the justifications for the rulemaking change, and provides answers to how it would affect previous rules, industry growth, and foodborne illness rates.