Does the Occupational Safety and Health Act mandate that the Secretary of Labor perform a cost-benefit analysis when establishing safety standards for toxic materials or harmful physical agents in the workplace?

In 1978, the Occupational Safety and Health Administration (OSHA) issued the Cotton Dust Standard to regulate occupational exposure to cotton dust, a known cause of byssinosis, commonly referred to as 'brown lung' disease. The standard established permissible exposure limits for various sectors within the cotton industry and mandated that employers implement engineering controls and work practices to reduce cotton dust exposure.

Petitioners representing the cotton industry's interests challenged the validity of the Cotton Dust Standard. They argued that OSHA should have conducted a cost-benefit analysis before implementing the standard. On the opposing side, the Secretary of Labor and labor organizations contended that the Act requires the most protective feasible standard to eliminate significant risks of material health impairment. This disagreement formed the core of the legal dispute surrounding the Cotton Dust Standard.

Petitioners filed a challenge to the Cotton Dust Standard in the Court of Appeals for the District of Columbia Circuit. The Court of Appeals ruled that the Occupational Safety and Health Administration (OSHA) was not required to conduct a cost-benefit analysis under the Act. Subsequently, the Supreme Court granted certiorari to address this significant legal question.

(Brennan, J.)

No. The Occupational Safety and Health Act does not mandate that the Secretary of Labor perform a cost-benefit analysis when establishing safety standards for toxic materials or harmful physical agents in the workplace. The phrase "to the extent feasible" in Section 6(b)(5) of the Act requires the Secretary to set the standard that "most adequately assures... that no employee will suffer material impairment of health," limited only by what is capable of being done. This interpretation is based on the plain meaning of "feasible," the structure of the Act, and its legislative history. Congress itself defined the basic relationship between costs and benefits by placing the benefit of worker health above all other considerations, save those making attainment of this benefit unachievable. The Act's language and purpose demonstrate a clear intent to prioritize worker safety over economic considerations. The Secretary is not required to conduct a formal cost-benefit analysis, but rather to ensure the highest level of protection that is technologically and economically possible. This approach reflects the Act's fundamental goal of preventing occupational health hazards to the fullest extent practicable. The decision to prioritize worker health over economic factors is a policy choice made by Congress in crafting the legislation, and it is not the role of the courts or the Secretary to second-guess this legislative judgment through the imposition of additional cost-benefit requirements not present in the statutory text.

Dissent (Stewart, J.) OSHA failed to justify its estimate of the cost of the Cotton Dust Standard on the basis of substantial evidence. The agency's economic analysis lacks the rigor necessary to support such a far-reaching regulation. This decision sets a concerning precedent for the level of evidence required in future regulatory actions.

Dissent (Rehnquist, J.) Section 6(b)(5) of the Act unconstitutionally delegates legislative authority to the Executive Branch by failing to provide a clear standard for setting safety regulations. This vague delegation violates the separation of powers doctrine and allows unelected officials to make policy decisions of immense economic and social importance without sufficient guidance from Congress.

Dissent (Burger, C.J.) Concurred with Justice Rehnquist's dissent without providing a separate written opinion.