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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