It does allow up to six hours for inpatient and outpatient continuity and transfer of care. However, interns and residents may not assume responsibility for a new patient after 24 hours. The US Occupational Safety and Health Administration (OSHA) rejected a petition filed by the Committee of Interns & Residents/SEIU, a national union of medical residents, the American Medical Student Association, and Public Citizen that sought to restrict medical resident work hours. OSHA instead opted to rely on standards adopted by ACGME, a private trade association that represents and accredits residency programs. On 1 July 2003, the ACGME instituted standards for all accredited residency programs, limiting the workweek to 80 hours a week averaged over a period of four weeks. These standards have been voluntarily adopted by residency programs. Though re-accreditation may be negatively impacted and accreditation suspended or withdrawn for program non-compliance, the number of hours worked by residents still varies widely between specialties and individual programs. Some programs have no self-policing mechanisms in place to prevent 100+ hour workweeks while others require residents to self-report hours. In order to effectuate complete, full, and proper compliance with maximum hour work hour standards, there are proposals to extend US federal whistle-blower protection to medical residents. Criticisms of limiting the work week include disruptions in continuity of care and limiting training gained through involvement in patient care. Similar concerns have arisen in Europe, where the Working Time Directive limits doctors to 48 hours per week averaged out over a 6-month reference period. Recently, there has been talk of reducing the work week further, to 57 hours. In the specialty of neurosurgery, some authors have suggested that surgical subspecialties may need to leave the ACGME and create their own accreditation process, because a decrease of this magnitude in resident work hours, if implemented, would compromise resident education and ultimately the quality of physicians in practice. In other areas of medical practice, like internal medicine, pediatrics, and radiology, reduced resident duty hours may be not only feasible but also advantageous to trainees because this more closely resembles the practice patterns of these specialties, though it has never been determined that trainees should work fewer hours than graduates. In 2007, the Institute of Medicine was commissioned by Congress to study the impact of long hours on medical errors. New ACGME rules went into effect on 1 July 2011, limiting first-year residents to 16-hour shifts. The new ACGME rules were criticized in the journal "Nature and Science of Sleep" for failing to fully implement the IOM recommendations.