Soyka & Company conducted a detailed review and critique of an Economic Impact Analysis (EIA) supporting an OSHA proposed rule that would have widespread and severe effects. On a quick-turnaround basis, we reviewed the 1,200 page EIA and 200+ page rule and preamble, identified methodological and data problems, and proposed an approach to address them. We then developed extensive new data, constructed new quantitative analysis methods, corrected flaws in OSHA’s costing methods, re-estimated the compliance costs and their implications for businesses in the client customer’s industry, and drafted a comprehensive report. The report was endorsed by the client and legal counsel, and served as key evidence in persuading OSHA to not pursue major rule provisions, preventing severe nationwide economic impacts.
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