Institute for Policy Integrity

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What We Do

Project Updates

Viewing all updates in Safety and Consumer Protection
  • Court Filings

    Brief on EPA Chemical Disaster Rule Delay

    November 1, 2017

    EPA recently delayed the effective date of a rule that would have decreased the severity and number of chemical accidents at manufacturing facilities and refineries. State and NGO plaintiffs sued EPA over the delay, arguing that EPA did not have statutory authority to issue it, and that the delay was arbitrary and capricious. We filed a brief in support of petitioners arguing that EPA did not offer an adequate explanation for choosing to forgo the benefits of the chemical disaster rule.

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  • Court Filings

    Brief on Department of Education’s Borrower Defense Rule

    October 25, 2017

    Under Secretary Betsy DeVos, the Department of Education delayed implementation of the Borrower Defense Rule, which would have helped students who have been defrauded by for-profit educational institutions discharge their federal student loans. In our amicus brief supporting borrower and state challenges to the delay, we argue that the Department violated the Administrative Procedure Act by arbitrarily disregarding the benefits for student borrowers that would be forgone as a result of the delay.

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  • Public Comments

    Comments on Reconsideration of NHTSA Rule to Update Civil Penalties

    October 10, 2017

    In December 2016, the National Highway Traffic Safety Administration (NHTSA) finalized a rule that updates civil penalties for car manufacturers that violate fuel economy standards. NHTSA is now reconsidering the rule, claiming it would have a significant negative economic impact. The agency provides no evidence that economic circumstances have changed since the rule’s finalization to make the rule more costly. Our comments argue that the agency should not proceed with the proposed reconsideration, because it inadequately explained why it changed positions. If the agency does continue with the reconsideration, both the Inflation Adjustment Act and economic cost-benefit analysis would justify an update to the penalties rates rather than maintaining the original penalty rate from 1975.

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  • Public Comments

    Comments on Delay of Department of Labor’s Fiduciary Rule

    September 15, 2017

    The Department of Labor’s Fiduciary Rule requires investment advisors to serve the best interests of their retiree clients. In August 2017, Labor proposed to stay the rule’s enforcement provisions. In our comments on the proposed delay, we argue that the delay violates basic administrative law principles.

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  • Public Comments

    Comments to OSHA on Beryllium Standards Revocation

    August 28, 2017

    In public comments to the Occupational Safety and Health Administration, we highlight some critical problems with the agency’s cost-benefit analysis in its proposed revocation of standards to protect workers from exposure to beryllium. These ancillary standards were designed to protect workers in the construction and shipyard sectors.

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  • Public Comments

    Public Comments to OIRA on Regulatory Review Guidance

    February 10, 2017

    President Trump’s recent Executive Order on reducing regulation directed agencies to identify two existing regulations to repeal when issuing a new regulation, and to offset all incremental costs of new regulations. On February 2, 2017, the Office of Information and Regulatory Affairs (OIRA) released interim guidance on how it plans to implement the Executive Order, and we submitted comments on the guidance.

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  • Public Comments

    Comments on FDA Proposal to Restrict Artificial Tanning

    April 4, 2016

    We recently submitted comments in response to the Food and Drug Administration’s (FDA) proposed rule to restrict the use of sunlamps used for artificial tanning. We concluded that although the proposed rule takes a significant step in reducing the risks of artificial tanning, the FDA should strengthen the justification for this proposed rule.

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  • Public Comments

    Payday Lending Public Comments

    December 7, 2015

    The Consumer Financial Protection Bureau (CFPB) is currently developing regulations that could protect millions of lower-income Americans from predatory payday lenders. We submitted public comments on the agency’s regulatory approach.

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  • Hein Joins Experts to Discuss Oil-by-Rail

    November 13, 2015

    Jayni Hein, our policy director, presented today at a national conference on oil-by-rail policies, “Oil Train Response 2015: Community Risks & Solutions,” in Pittsburgh, Pennsylvania.

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  • Public Comments

    Consumer Product Safety Commission Public Comments

    June 1, 2015

    Since 1996, there have been at least 285 incidents of child strangulation by window covering cords. The Consumer Product Safety Commission is considering a regulation to address this issue, and we recently submitted public comments on the Commission’s advance notice of proposed rulemaking. We offered a number of suggestions for improving upon the Commission’s preliminary analysis of the costs and benefits of eliminating cords from window coverings. These included recommendations that the Commission consider the prevention of parental grief as an unquantified benefit of regulation and that it perform separate cost-benefit analyses for each major category of covering (e.g., vinyl blinds, wood blinds, roman shades).

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