Testimony, Comments and Briefs

2019 Comments

  • APHA comments on the Nondiscrimination in Health and Health Education Programs or Activities rule proposed by the U.S. Department of Health and Human Services (Aug. 12)
  • APHA comments to EPA regarding Draft: OPPT Updated Risk Characterization for Occupational Inhalation of PV29 Based on Updated Approach (July 10)
  • APHA comments opposing the Office of Management and Budget’s notice to change the Official Poverty Measure (June 21)
  • APHA comments opposing the U.S. Department of Housing and Development's proposed rule, "Verification of Eligible Status," which would restrict or eliminate access to public and other subsidized housing for mixed-status immigrant families that have members who are undocumented or otherwise ineligible for housing assistance (July 3) 
  • APHA comments to EPA regarding the advance notice of proposed rulemaking on a training, certification and limited access program for commercial users of methylene chloride (May 24)
  • Health organization comments in response to the Food and Drug Administration's draft guidance aimed at preventing youth access to, and appeal of, flavored tobacco products, including e-cigarettes and cigars (April 30) 
  • Health organization comments to U.S. EPA opposing the proposed reconsideration of the “appropriate and necessary finding” for the Mercury and Air Toxics Standard for coal- and oil-fired power plants (April 17)
  • Health organization comments regarding EPA's proposed revised definition of Waters of the United States (April 15)
  • APHA comments opposing the U.S. Department of Agriculture's proposed rule, "Supplemental Nutrition Assistance Program: Requirements for Able-Bodied Adults without Dependents," which would impose harsh work requirements on certain SNAP participants and eliminate SNAP benefits for more than 755,000 adults (April 2)
  • Health organization comments to U.S. EPA opposing the proposed rule to weaken the 2015 carbon pollution limits for New, Modified and Reconstructed Stationary Sources (March 18)
  • APHA comments on the proposed Healthy People 2030 objectives (Jan. 17)
  • APHA comments urging EPA to revisit and revise the Draft Risk Evaluation for PV29 under the Toxic Substances Control Act (Jan. 14)
  • APHA comments opposing the Department of Health and Human Services' proposed rule, "Patient Protection and Affordable Care Act, Exchange Program Integrity," which threatens to eliminate coverage of abortion in the ACA marketplaces (Jan. 8) 

2019 Briefs

  • Public health brief field in the U.S. District Court for the Southern District of New York highlighting the negative public health impacts of the U.S. Department of Homeland Security's final rule, "Inadmissibility on Public Charge Grounds" (Sept. 10) 
  • Organization brief filed before the U.S. District Court for the District of Maryland by the Center for Science in the Public's Interest, and others, against the U.S. Department of Agriculture for their recent decision to offer nutrition "flexibilities," allowing schools to serve meals with more sodium and fewer whole grains (Sept. 6) 
  • Organization brief to the U.S. Court of Appeals for the Fourth District highlighting the negative public health impacts of the U.S. Department of Defense's discriminatory policy against service members living and serving with HIV (July 25)
  • Health organization brief filed in the U.S. Supreme Court in the case of Harris Funeral Homes v. Equal Employment Opportunity Commission, et al. in support of the employees (July 3)
  • Public health brief filed in the U.S. Court of Appeals for the Ninth Circuit urging the court to support Plaintiffs-Appellees’ emergency motion for reconsideration en banc of the decision to allow implementation of the final Title X rule (June 26)
  • Public health brief filed in the U.S. District Court for the District of Oregon in support of the Title X Family Planning Program in the case State of Oregon vs. Azar (April 9)
  • Health organization brief in support of the Defendants-Appellees in the case Parents for Privacy v. Dallas School District No. 2 (March 11) 
  • Health organization brief before the U.S. Court of Appeals in the Fifth Circuit in the Whole Women's Health Texas disposal case requiring the burial and cremation of fetal remains from miscarriages and abortions (Jan. 10)

2019 Testimony

  • APHA testimony before the House Budget Committee hearing: The Costs of Climate Change: From Coasts to Heartland, Health to Security (July 24)
  • Friends of HRSA Coalition testimony supporting increased funding in FY 2020 for the Health Resources and Services Administration submitted for the record to the Senate Appropriations Subcommittee on Labor, Health and Human Services, and Education, and Related Agencies (June 6)
  • APHA testimony supporting increased FY 2020 funding for CDC and HRSA submitted for the record to the Senate Subcommittee on Labor, Health and Human Services, and Education, and Related Agencies (May 24)
  • APHA testimony before the Subcommittee on Environment and Climate Change, House Energy and Commerce Committee, in support of H.R. 1603, the Alan Reinstein Ban Asbestos Now Act of 2019 (May 8)
  • APHA testimony supporting increased FY 2020 funding for CDC and HRSA submitted for the record to the House Subcommittee on Labor, Health and Human Services, and Education, and Related Agencies (April 8)
  • CDC Coalition testimony supporting increased FY 2020 funding for the Centers for Disease Control and Prevention submitted for the record to the House Appropriations Subcommittee on Labor, Health and Human Services, and Education, and Related Agencies (April 8)
  • Friends of HRSA Coalition testimony supporting increased funding in FY 2020 for the Health Resources and Services Administration submitted for the record to the House Appropriations Subcommittee on Labor, Health and Human Services, and Education, and Related Agencies (April 8) 

2018 Testimony

  • Health organization comments to CDC and the Surgeon General sharing evidence, examples, and recommendations that can help promote and sustain private sector investment in community health (Nov. 5)
  • APHA testimony to the Senate Appropriations Subcommittee on Labor, HHS, Education and Related Agencies regarding FY 2019 funding for CDC and HRSA (June 1)
  • APHA testimony to the House Appropriations Subcommittee on Labor, HHS, Education and Related Agencies regarding FY 2019 funding for CDC and HRSA (April 24)

2018 Comments

  • Organization comments to U.S. EPA expressing opposition to the proposed changes to the Emission Standards for New, Reconstructed, and Modified Sources within the Oil and Natural Gas Sector (Dec. 17)
  • APHA comments opposing the U.S. Department of Homeland Security's proposed rule, "Inadmissibility on Public Charge Grounds" (Dec. 10) 
  • APHA comments opposing the U.S. Department of Labor’s Wage and Hour Division's proposal to change the existing child labor regulation under Hazardous Order No. 7 (Dec. 6)
  • Health organization comments requesting that the final U.S.-Japan free trade and investment agreement include provisions to ensure that both countries are able to adopt public health measures to protect their citizens from the death and disease caused by tobacco products without fear of litigation by tobacco companies (Nov. 26) 
  • Health organization comments to U.S. EPA opposing the Affordable Clean Energy rule to replace the Clean Power Plan (Oct. 31)
  • Health organization comments opposing the Notice of Proposed Rule Making issued by U.S. EPA and NHTSA to reduce the stringency of existing vehicle emission and efficiency standards and to revoke states’ Clean Air Act authority to adequately protect citizens from harmful pollution (Oct. 26)
  • APHA comments submitted to the U.S. Food and Drug Administration in response to FDA's Multi-Year Nutrition Innovation Strategy (Oct. 11) 
  • APHA comments to OSHA opposing the proposed rule, Tracking of Workplace Injuries & Illnesses (Sept. 27)
  • Health organization comments to U.S. EPA opposing the proposed rule Strengthening Transparency in Regulatory Science (Aug. 15)
  • APHA comments to U.S. EPA on Problem Formulation Documents for Risk Evaluations Conducted under the Toxic Substances Control Act as amended and the Application of Systematic Review in TSCA Risk Evaluations Guidance Document  (August 10)
  • APHA comments to U.S. EPA regarding the Problem Formulation of the Risk Evaluation for Asbestos under the Toxic Substances Control Act as amended (August 10)
  • APHA comments submitted to the U.S. Department of Health and Human Services opposing proposed changes to the Title X family planning program (July 30)
  • Health organization comments submitted to the U.S. Food and Drug Administration in support of FDA's refusal to exempt premium cigars from regulation (July 25) 
  • Health organization comments submitted to the U.S. Food and Drug Administration urging the agency to publish and finalize a rule prohibiting characterizing tobacco flavors in all combusted and smokeless tobacco products (July 19) 
  • Health organization comments submitted to the U.S. Food and Drug Administration in support of a proposed rule to reduce nicotine levels in combustible tobacco products (July 16) 
  • Health organization comments submitted in response to the U.S. Food and Drug Administration's draft paper entitled, "Illicit Trade in Tobacco Products after Implementation of an FDA Product Standard" (July 16) 
  • Health and medical organization comments to the U.S. Environmental Protection Agency opposing the proposed repeal of the Clean Power Plan (April 26)
  • APHA comments to the U.S. Environmental Protection Agency opposing the proposed repeal of the Clean Power Plan (April 20)
  • Health organization comments opposing the U.S. Department of the Interior’s proposal to revise and essentially dismantle the Bureau of Land Management's methane waste rule (April 17)
  • Health organization comments in response to U.S. EPA notice titled "Guidance: Expanded Access to TSCA Confidential Business Information" (April 16)
  • Health and medical organization comments on OMB's draft 2017 Report to Congress on the Benefits and Costs of Federal Regulation and Agency Compliance with the Unfunded Mandates Reform Act (April 6)
  • APHA comments submitted to the U.S. Departments of Agriculture and Health in response to the proposed topics for the development of the 2020-25 Dietary Guidelines for Americans (March 30) 
  • APHA comments submitted to the U.S. Department of Labor in response to the proposed regulation on small business health plans (March 1) 
  • Health organization comments to the U.S. Environmental Protection Agency regarding EPA's proposal to replace the Clean Power Plan (Feb. 26)
  • APHA comments to the U.S. Environmental Protection Agency regarding EPA's proposal to replace the Clean Power Plan (Feb. 26)
  • APHA comments to the U.S. Department of Agriculture regarding the proposal to weaken school nutrition standards (Jan. 29)
  • Health organization comments to USDA opposing weakening nutrition standards for school meals (Jan. 29) 
  • APHA comments to the U.S. Environmental Protection Agency regarding implementation of the New Chemicals Review Program (Jan. 19) 
  • Health organization comments to EPA on proposed repeal of emission requirements for glider vehicles, glider engines and glider kits (Jan. 5)

2018 Briefs

  • Health organization brief in support of the lawsuit filed by the American Academy of Pediatrics and others against the U.S. Food and Drug Administration for its delay in reviewing e-cigarettes and cigars (July 17)
  • Public health brief in support of the Affordable Care Act in the case Texas vs. the United States (June 14)
  • Health organization brief in support of petitioners' challenges to U.S. EPA rules implementing the Toxic Substances Control Act (April 23)
  • APHA brief filed before the U.S. Court of Appeals for the Sixth Circuit challenging a Kentucky law that imposes restrictions on the provision of safe and legal abortion without medical justification (March 29)
  • Health and medical organization amicus brief urging the U.S. Supreme Court to reinstate the injunctions against implementation of the Proclamation barring individuals from entering the U.S. on the basis of nationality (March 27)
  • Health organization brief to the U.S. Court of Appeals for the Second Circuit in support of requiring discharge planning for to individuals with serious mental illness held in government custody (Feb. 20)
  • Health organization brief supporting a decision directing the Environmental Protection Agency to revoke all tolerances for the pesticide chlorpyrifos (Feb. 13)
  • Health organization brief in support of Planned Parenthood before the U.S. Court of Appeals for the Eight Circuit (Feb. 1)

More Testimony, Comments and Briefs