Advocacy Listens To Small Business, Comments On Drug Testing

The Mine Safety and Health Administration (MSHA) has proposed the Alcohol- and Drug-Free Mines: Policy, Prohibitions, Testing, Training, and Assistance rule. [73 Fed. Reg. 52136 (September 8, 2008).]


Advocacy hosted a small business roundtable on October 30 to discuss the proposed rule and listen to the concerns of small mining operators.


Small business representatives were concerned that MSHA’s rule would disrupt their existing drug and alcohol programs, and many preferred that MSHA adopt a performance standard that establishes mandatory, minimum requirements for a drug and alcohol program and leaves it to the mine operator to implement.  They also felt that MSHA has understated the cost of the proposed rule, and that MSHA lacked sufficient data about drug and alcohol use at mines or the degree to which drugs and alcohol have been contributing factors in mine fatalities and injuries.


On November 6, based on what we learned, Advocacy submitted comments on the proposed rule to MSHA.  A one-page Fact Sheet about our concerns is also available.


We would be interested in any feedback you have about the proposed rule or our comments.


—Bruce Lundegren, Assistant Chief Counsel


  1. J.A>Devlin USN (Ret.) says

    Before I go on, is your charter as identified below?

    “U.S. Congress created the Office of Advocacy within the U.S Small Business Administration to protect, strengthen and effectively represent the nation’s small businesses within the federal government’s legislative and rule-making processes. The Office of Advocacy works to reduce the burdens that federal policies impose on small firms and maximize the benefits small businesses receive from the government. Advocacy’s mission, simply stated, is to encourage policies that support the development and growth of American small business.”

    I assume that the above is? Well being a SDVO I think it’s time that Advocacy ACTS rather than Listens To Small Business, or Comments On Veteran Owned SDVO.

    Small Business simply has given up on the SBA including Advocacy. Why? SBA “talk the talk but has not walked the walk” Clearly if SBA enforced it’s Charter, held SBA feet to the fire concerning SDB, ALL SDBs’, I would not be sending this email comment.

    Look it’s simple, Advocacy, GAO, lead by SBA’s own Inspector General need to get out of the Beltway and look at what the Field is attempting to accomplish. That group needs to realize that Laws, Mandates and Presidential Orders are not simply suggestions re PL 106-50….SBA is broken and no matter what the Public Relation Machine within SBA generates the reality are SBA borders of being a pure waste of tax money.

    My take is simply: SIX MONTHS to study and identify the problems, that are identified now, and six months to fix them. I have watched SBA fumble the ball on VO and SDVO SDB’s for over ten years…I think it’s about time these SDBs’ get that attention and stop being discriminated against by SBA, DoD, DCMA and every Politically Connected Government Supplier. People its time! Civil Servants and SBA has accountability to ME! Stop talking and start moving forward! WE ARE TIRED OF THE CONSTENT STREAM OF SMOKE AND MIRRORS PR THAT COMES OUT OF YOUR ORGANIZATION AND SBA HQ…. PEOPLE IT TIME to CYA with this new Administration because I feel there’s a house cleaning coming and you just might be part of the clean sweep….I know I’m going to help by calling attention to SBA Advocacy action or lack of action within my Political Sphere.

  2. T Michael says

    I am not sure what J.A. Devlin’s comment has to do with drug testing for mine workers. However, he would be properly directed to a series of ACTIONS the Office of Advocacy has taken to push SBA (and other agencies)to meet its obligations for small business contracting (including SDVO preferences). Of course, the Office of Advocacy can (and should) do more. And, J.A. Devlin deserves credit for pointing this out (although, completely unrelated to the posting on MSHA regulatory action).

  3. Custom Essays says

    Thanks for your information. Most of the posts in the blog is really valuable. Regards

Comments are closed.