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GGD-78-116 1 (1978-10-04)

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           by th-e i    ~   ~  -
               COMPTROLLER GERAL OF T&T4 STATES
                        WASHINGTON. D.C. 20548
                                         RELEASED

               B-163:7LM110802
           B-1637~OCT                            4 1978


The Honorable Paul G. Rogers
Chairman, Subcommittee on Health
  and the Environment
Committee on Interstate and Foreign
  Commerce                                               110802
House of Representatives

Dear Mr. Chairman:

     Your letter of June 14, 1978, asked for our opinion on
the role of the Executive Office economic units and the
legality and adequacy of the intervention of .such units--
the Council of Economic Advisers, Council on Wage and Price
Stability, and the Regulatory Analysis Review Group--in rule-
making by the Environmental Protection Agency (EPA) and the
Department of Labor's Occupational Safety and Health Admini-.
stration (OSHA).

     More specifically, we examined into, as agreed with your
Office, (1) why the economic units intervene in Federal rule-
making 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 or being taken to improve the intervention process;
(5) the nature, extent, and legality of the economic units'
efforts to influence OSHA and EPA rulemaking other than filing
formal submissions for the rulemaking record; and (6) the ex-
tent to which the Wage and Price Council reviews its proposals
to insure that they could be lawfully implemented by EPA and OSHA.

     As agreed, we examined the economic units intervention in
OSHA's coke oven and cotton dust standards and EPA's fossil
fuel-fired boilers standard. We also examined the interaction
between the economic units and OSHA on its acrylonitrile regula-
tion because, according to all involved, it represents a good case
of the process working in accordance with established procedures.


                                                      GGD-78-116
                                                        (41910)

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