GINA-related Notice model comments on proposed rulemaking

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Center releases model comments on GINA-related Notice of Proposed Rulemaking

The Equal Employment Opportunity Commission (EEOC) recently released a Notice of

Proposed Rulemaking (NPRM) implementing Title II of the Genetic Information

Nondiscrimination Act (GINA), which regards employment.

The Genetics and Public Policy Center, in collaboration with Gruber at

the Council for Responsible Genetics, has developed model comments in response

to this proposed regulation. Our draft comments are available for other

organizations' and individuals' use; comments are due to EEOC by May 1, 2009.

Comments may be submitted at www.regulations.gov.

We are pleased with the approach taken by EEOC in most areas of the NPRM.

However, we believe that a few aspects of the NPRM require additional attention,

as detailed in our comments:

strong and unambiguous definitions of key terms,

narrowly-crafted exceptions to the rule against employer acquisition of genetic

information, and, clarification by all federal agencies regulating under GINA of

the interaction of Title I and Title II of GINA to ensure that both Titles are

implemented and enforced with consistency and clarity.

This document is a working draft.