Three Case Studies of OSHA's Regulatory Impact Analysis in Support of RecentRulemaking

摘要

This purpose of this research document is to analyze the issue in depth byperforming case studies of OSHA's Regulatory Impact Analyses (RIAs) in support of three of the agency's recent standards: (1) OSHA's 1987 revised standard for occupational exposure to formaldehyde; (2) OSHA's 1992 rule on process safety for hazardous chemicals, explosives, and blasting agents; and (3) OSHA's 1992 standard for occupational exposure to cadmium. The examination is selective rather than comprehensive, with the focus on (1) those industrial sectors that had the largest number of exposed workers, that were projected to have the most severe regulatory impacts, or that were the subject of major debate during the rulemaking; (2) elements of the RIA that are of methodological significance; or (3) other specific features that illuminate OSHA's analytic performance. Based on the examination of the RIAs for the three recent standards, the final section provides some preliminary conclusions about OSHA's performance in terms of addressing the estimation problems encountered in support of earlier standards.