Michael Karl McNeil writes for regulators, journals and clients. This page lists the public comments, journal correspondence, white papers and articles that carry his name, and the categories of technical documents he writes for clients through McNeil Safety Consulting. Where a document is public it is linked. Where it is a client document, only the type is described.
Regulatory public comments
Comments filed with a federal agency during rulemaking become part of the public record and are published by the agency and by the submitting organization. Michael served as a contributing drafter on the following as a member of the American College of Occupational and Environmental Medicine (ACOEM), working under the direction of ACOEM’s Council on OEM Science.
- Reforming and Modernizing the NRC’s Radiation Protection Framework. ACOEM comments to the U.S. Nuclear Regulatory Commission on the proposed rule published at 91 Fed. Reg. 43456 (July 15, 2026), Docket NRC-2025-1140. Drafted by Michael Karl McNeil with a second ACOEM member for the Council on OEM Science, approved by ACOEM’s Executive Committee and submitted 28 August 2026. The comments address each of the nine major provisions of the proposal, including the proposed removal of the ALARA standard in favor of a graded approach, occupational dose limits, the dose limit for the lens of the eye, caregiver dose under 10 CFR Parts 20 and 35, and the effluent constraint. A companion submission on the related proposal, Reducing Barriers to Medical Use Licensing (91 Fed. Reg. 47042, Docket NRC-2025-1237), was drawn from the same drafting work. Read the submitted comments on Docket NRC-2025-1140 (PDF, acoem.org) and the companion comments on Docket NRC-2025-1237 (PDF, acoem.org).
Journal correspondence and review
Michael is a contributor to the Journal of Occupational and Environmental Medicine (JOEM), ACOEM’s peer-reviewed journal, and serves as a reviewer for ACOEM.
- A Longitudinal Health Surveillance Gap for Battery Energy Storage Systems: A Call for a Research Agenda. Letter to the editor, submitted to JOEM in August 2026 and under editorial consideration. The letter identifies the absence of any longitudinal health surveillance framework for the three populations exposed to battery energy storage systems — construction and operations workers, responding firefighters, and downwind communities — and calls for a formal research agenda.
White papers
- Battery Energy Storage Systems: Occupational and Public Health Hazards, Exposure Toxicology, and the Evolving Regulatory Framework (2026). A review of the occupational and public health hazards of utility-scale battery energy storage, the exposure toxicology of the substances released in a thermal-runaway event, and the regulatory framework that applies to the facilities. Written from Michael’s own project experience on utility-scale energy construction and commissioning in four Western states. Available on request.
Articles
Michael writes the McNeil Safety Consulting blog, which covers Cal/OSHA and federal OSHA compliance, citation defense and appeal deadlines, industrial hygiene, hazardous materials and emergency planning. Every article is listed on his author page. He also publishes under his own name at McNeil Safety Consulting on Substack and keeps a professional record at michaelkarlmcneil.link.
Technical documents written for clients
Most of Michael’s writing is not public. It is prepared for a client and belongs to that client. The document types are listed so that a prospective client or retaining attorney knows what he writes; none is reproduced here and none is attributed to a client.
- Site-specific health and safety plans for hazardous waste operations and contaminated-soil work under 8 CCR §5192, including plans written as addenda to an existing Injury and Illness Prevention Program.
- Injury and Illness Prevention Programs under 8 CCR §3203 and the written programs that sit beneath them — hazard communication, heat illness prevention, respiratory protection, lockout, confined space and emergency action.
- Caltrans lead compliance plans and construction stormwater pollution prevention plans, the latter prepared as a Qualified SWPPP Developer.
- Hazardous Materials Business Plans, filed on the client’s behalf through the California Environmental Reporting System.
- Cal/OSHA citation responses, replies to a Form 1AY document request, and appeal filings before the Occupational Safety and Health Appeals Board.
- Expert reports and declarations for retaining counsel, prepared to Federal Rule of Civil Procedure 26 where the forum requires it, and findings reports from site inspections.
- Industrial hygiene sampling reports, indoor air quality assessments and post-fire indoor environmental assessments.
Requests and invitations
Public comments are cited to the agency docket. Client documents are not released. A question about a publication, or an invitation to contribute to a comment letter, position paper or review, can be sent to mike@mcneilsafetyconsulting.com or made by phone at (626) 546-9384. The credentials page lists the registrations behind this work, and the professional memberships page lists the organizations through which the comment and journal work is done.