Rebecca Rosser, Past-President
On June 24, 2011, a special meeting of the Clinical Laboratory Technology Advisory Committee [CLTAC] was held. This meeting was called to allow the Personnel Regulation Subcommittee of CLTAC to report their recommendations to the whole CLTAC committee.
As you may recall on August 12, 2010, CAMLT was notified by Laboratory Field Services that the long awaited Personnel Regulations DPH 08-001 were available for review and comment. CAMLT, along with many other interested parties, submitted comments to Laboratory Field Services. The comment period ended on September 27, 2010.
In the mean time, the CLTAC committee determined that a subcommittee should be formed to review the Personnel Regulation packet, despite that fact that the comment period had already expired. Jim Ottosen, Leslie Revier and I represented CAMLT on that subcommittee. Along with 17 other members, we met a number of times and formulated a recommendation to be presented to the CLTAC committee. The CLTAC committee is charged with providing advice and making recommendations to Laboratory Field Services.
Fast forward to June 24, 2011. The CLTAC meeting was convened and the first agenda item was Departmental News reported by Pam Dickfoss, who is the Acting Deputy Director.
As part of her report, she stated that there were more than 300 responses and 15,000 [yes, you read that right] comments received during the comment period. Based on those comments Laboratory Field Services reviewed and amended the regulations. At that point, they felt that because of the number and complexity of the comments, a decision was made to withdraw the original Personnel Regulation Packet, DPH 08-001, which will occur by mid July and resubmit an amended regulation packet by Sept. 2011.
Jim Ottosen, then commented that the function of the CLTAC committee was to “assist the Department by providing advice and making recommendation for the establishment of rules and regulations…” and that by refilling the new packet in September without the CLTAC’s input, would bypass the function of the committee, as stated in B&P Sec. 1228. Ms. Dickfoss then agreed that the CLTAC should see the draft regulation packet prior to the submission to allow input.
Ms. O’Keefe wanted to ensure that everything was done according to rule, so she wanted to verify with the Office of Regulation that this indeed can occur. According to Ms. Dickfoss, after the regulation packet is officially submitted, it then becomes confidential, but prior to the submission, in draft form, it can go the CLTAC.
If this indeed happens, the CLTAC subcommittee, would meet to review this draft regulation packet to give a recommendations to the full CLTAC and those recommendations could be used as part of the re-vamp.
The meeting finally turned to having the recommendations of the subcommittee on the original packet [the one being withdrawn] presented for acceptance and approval from the CLTAC. This was accomplished and then there was a comment that even though this packet was being withdrawn, Laboratory Field Services could use these recommendations for the re-vamp.
Stay tuned for more information on the Personnel Regulations Packet. When the revised packet is filed, there will be a new comment period open and CAMLT will be looking to you for your input.