Concerning the Role of the CEA, COWPS, and RARG in EPA and OSHA Rulemaking

GGD-78-116: Published: Oct 4, 1978. Publicly Released: Oct 29, 1979.

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A review was made of the role of the Council of Economic Advisers, the Council on Wage and Price Stability, and the Regulatory Analysis Review Group in rulemaking by the Environmental Protection Agency (EPA) and the Department of Labor's Occupational Safety and Health Administration (OSHA). The following areas were examined: (1) why the economic units intervene in federal rulemaking proceedings; (2) the efforts to develop regulations on a cost-benefit basis and the extent to which the intervening units have assessed the total direct and indirect costs of preventable, environmentally-related diseases; (3) the legality of the Wage and Price Council's intervention if it does not measure the inflationary impact of the failure to undertake maximum feasible efforts to prevent such diseases; (4) the steps taken to improve the intervention process; (5) the legality of the economic units' efforts to influence OSHA and EPA rulemaking other than filing formal submissions for the rulemaking record; and (6) the extent to which the Wage and Price Council reviews its proposals to ensure that they could be lawfully implemented by OSHA and EPA.

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