Risk-Risk Analysis:

OMB's Review of a Proposed OSHA Rule

PEMD-92-33: Published: Jul 2, 1992. Publicly Released: Jul 2, 1992.

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Pursuant to a congressional request, GAO reviewed the Office of Management and Budget's (OMB) decision to suspend a review of a rule proposed by the Occupational Safety and Health Administration (OSHA) based on a reliance on risk-risk analysis, which attempts to estimate increased mortality risk indirectly attributable to the costs associated with implementing the OSHA rule.

GAO found that: (1) OMB determined that the costs of implementing the regulation could indirectly result in more fatalities than its preventive aspects were estimated to avert; (2) the method OMB used in its decision to suspend its review of the OSHA rule was cost-benefit rather than risk-risk analysis; (3) risk-risk analysis theory has a causation problem and a shortage of empirical data to confirm it; (4) OMB misused the model because the outcomes of calculations were not universally applicable and data appropriate to the situation were lacking; and (5) the use of cost-benefit analysis is permissible in the consideration of safety standards, but is prohibited in developing health standards.

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