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Gossman Consulting, Inc.

Regulatory Review and Commenting

Service Description

Gossman Consulting Inc. (GCI) performs extensive reviews and prepares comments on draft regulations and other technical/policy documents made available by the government for public comment. In recent years GCI has assisted our clients in preparing comments on draft hazardous waste regulations, EPA guidance documents and various EPA studies including those on dioxins.


David Gossman

Jim Woodford


GCI has prepared a number of papers commenting on EPA draft regulations. Although portions of these comments may have been prepared on behalf of a client, the comments presented in these papers are GCI's. In many cases the tone reflects GCI's unique position outside of industry thus allowing us to make statements or present materials that might not be appropriate as part of a comment coming from industry. GCI prepares comments on behalf of our clients that represent the client's position with a tone representative of the desires of our client's.

"Burning Waste in Kilns in the United Kingdom A Comparison of Regulations in the United Kingdom versus the United States EPA Regulations"

"EPA Regional Variances in the Interpretation and Implementation of the BIF Regulations"

"The Added Risk to Health, Safety and the Environment Due to the BIF Regulation"

GCI Tech Notes "Hazardous Waste Combustor Review - Chapter 1 Applicability of the HWC Regulation to Cement Kilns” Oct-96

GCI Tech Notes "Comments on Draft SW-846", Jan-96

GCI Tech Notes "Subpart CC Voc Emission Controls”, Oct-95

GCI Tech Notes "Dioxin Health Assessment Document Review and Comment, (EPA/600/BP-92/001a,b & c)”, March-95

GCI Tech Notes "EPA Dioxin Exposure Assessment Comments”, Feb-95

HWF Notes "Municipal Waste Combustion and MACT”, Dec-94

HWF Notes "Review of EPA’s Sham Recycling “Policy”, Nov-94

HWF Notes "Review of Guidance on Trial Burns”, Aug-94

HWF Notes "Comments on the New EPA Waste Analysis Plan Guidance Manual”, July-94

HWF Notes "Review of EPA-454/R-93-032 Entitled National Air Pollutant Emission Trends”, April-94

HWF Notes "CKD Report to Congress Comments”, Feb-94

HWF Notes "Review of EPA Draft 'Implementation of Exposure Assessment Guidance for RCRA Hazardous Waste Combustion Facilities'", Nov-93

HWF Notes "The EPA Proposed Hazardous Waste Identification Rule (Potential Impact on Cement Kiln Dust)”, July-92

USEPA BIF Regulations Summary For Compliance