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Risk-Risk Analysis: OMB's Review of a Proposed OSHA Rule

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Report Type Reports and Testimonies
Report Date July 2, 1992
Report No. PEMD-92-33
Subject
Summary:

The Office of Management and Budget (OMB) recently suspended its review of a rule proposed by the Occupational Safety and Health Administration (OSHA) entitled "Air Contaminants Standard in the Construction, Maritime, Agriculture, and General Industries." OMB's decision to suspend its review was based on a model developed by a University of Southern California professor. GAO reviewed OMB's application of this procedure, which attempts to estimate increased mortality risk indirectly attributable to the costs associated with implementing the rule. GAO concludes that OMB's application of risk-risk analysis to the OSHA regulation (1) was based on a theory that is controversial in several respects, (2) employed a model that is as yet incomplete, (3) misinterpreted the model in several important ways, and (4) appears to be inconsistent with both Supreme Court and appellate court decisions.

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