Organizations Involved: Institute for Policy Integrity
Source: Occupational Safety and Health Administration
Abstract
In these comments, we urge the Occupational Safety and Health Administration (OSHA) to finalize its proposed heat protections for workers (the Proposed Rule). OSHA’s analysis shows that the Proposed Rule is cost-justified and will result in significant health and safety benefits, particularly among groups more likely to labor under high heat conditions like workers of color, low-income workers, and workers lacking immigration status, as well as people more vulnerable to high-heat conditions like pregnant people or people with pre-existing health conditions.
Our comments make the following recommendations and observations regarding OSHA’s economic analysis of the Proposed Rule:
- OSHA properly identified the underreporting of worker fatalities, illnesses, and injuries as an important factor to consider and should further supplement its analysis of underreporting.
- OSHA should consider whether it is overestimating compliance costs.
- OSHA should use a consistent analytical period for its baseline estimates, including its assessments of (1) baseline heat injuries, illnesses, and fatalities (to inform benefits estimates); and (2) annual average number of high-heat days (to inform cost estimates).
- OSHA appropriately considered co-benefits, such as improved productivity.
- OSHA correctly considered unquantified benefits, such as worker comfort.
