Workplace Safety and Randomized Controlled Trials: Another Weapon of Delay?

Editor’s Note:  OMB Watch’s contention that there is a “fundamental principle of modern workplace safety laws” which holds that indications which “suggest” risk justify regulation is simply not true.  Among other problems with this unsupported contention is that it contradicts President Obama’s Executive Order 13563 on improving regulation and regulatory review.  The January 2011 Executive Order explicitly reaffirmed the long-standing principle that agencies must “propose or adopt a regulation only upon a reasoned determination that its benefits justify its costs….”

From: OMB Watch

A New Measure of the Quality of Regulatory Analysis

From: RegBlog

Jerry Ellig and Patrick A. McLaughlin

How well do federal agencies conduct the regulatory analysis required in Executive Order 12866 and use it to make decisions?

Agency Aims to Curb Rules by Lame-Duck Presidents


WASHINGTON — It is a political tradition that is almost as old as the White House: a president on the way out, unconstrained by electoral considerations, fast-tracks a flurry of contentious regulations in the waning hours of his term, sometimes even cutting short review from industry or the public.

As he was leaving, President George W. Bush expanded Justice Department surveillance powers, relaxed rules on certain types of coal mining and altered protections for endangered animals. President Bill Clintonpushed through new rules on chemicals in drinking water and on workplace injuries caused by repetitive movements.

Regulation in the Pulp and Paper Industry: Costs and Consequences

Editor’s Note:  The complete paper is attached below.

From: Mercatus Center

by Colleen Haight, Derek Thieme


Scott Rafferty on A-119


Federal Participation in the Development and Use of Voluntary
Consensus Standards and in Conformity Assessment Activities

See the comments of Scott Raferty attached below.

Rafferty Comment OMB-2012-0003

Upcoming Event: Regulatory Lookback — An Independent Review of the EU’s Health and Safety Legislation

Editor’s Note:  The Regisration link for the event is here

From: The George Washington University Regulatory Studies Center

Instruct Us Again on the Immigration Rules

From: Immigration Daily

by Angelo Paparelli

With the 2012 presidential campaign in full throb, candidates Obama and Romney are embracing “the vision thing” — that nemesis of the first President Bush whose reelection effort reportedly failed because he did not “frame his positions on individual issues in a compelling and unified manner.” The two de factonominees paint a starkly different picture of where each would take America and of government’s role in getting us there. Surprisingly, however, on one point they agree: The cumulative burden of federal regulations is simply overwhelming.

Letter to ACUS: Committee on Regulation—Comments on Proposed Recommendations for Review of Regulatory Analysis Requirements

Letter from Institute for Policy Integrity/New York University School of Law to Committee on Regulation, Administrative Conference of the United States.

Subject: Committee on Regulation—Comments on Proposed Recommendations for Review of Regulatory Analysis Requirements (posted April 24, 2012)

The Institute for Policy Integrity at NYU School of Law submits the following comments on the ACUS Committee on Regulation’s proposed recommendations for review of regulatory analysis requirements. Policy Integrity is a non‐partisan think tank dedicated to improving the quality of government decisionmaking through advocacy and scholarship in the fields of administrative law, cost‐benefit analysis, and public policy.

Complete Letter: Policy_Integrity_Comments_on_Draft_ACUS_Recs_on_Regulatory_Analysis_Reqs

Progressive Groups Vent on Executive Order

From The Hill

Lefty groups fear White House reg reform plan will slash green protections

By Ben Geman

Several progressive groups are warning that White House plans to better align U.S. regulations with other countries’ could weaken environmental and public health protections.

The Center for Progressive Reform (CPR), the Union of Concerned Scientists, OMB Watch and Public Citizen have all issued statements that are critical or at least highly skeptical of the White House executive order issued Tuesday.

Here’s OMB Watch on Thursday: