Rulemaking as Seen Through the Eyes of Part 37

“Those that respect the law and love sausage should watch neither being made.” This Mark Twain quote ("borrowed" from Otto von Bismarck) may also be applied to rule making. As a working group member new to the process, the development of the proposed rules in Part 37 was an eye-opening experience. The first part of this presentation will discuss some of the proposed rule language, points of contention, and the review process. The second part will deal with two issues: (1) as the regulators of more than two-thirds of the materials licensees in the United States, the continued inclusion and meaningful involvement of the Agreement States in all aspects of the oversight of radioactive materials, especially in rulemaking, will become even more important in the future; and, (2) the Agreement States - individually and collectively through OAS - must be aggressive and take a proactive approach moving forward.