Institute for Policy Integrity

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Project Updates

Viewing all updates in Safety and Consumer Protection
  • 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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  • Public Comments

    Oil Train Safety - Public Comments

    September 26, 2014

    Driven by growth in the production of oil in the U.S. and Canada, there has been a significant increase in rail transportation of crude oil over the past five years, with a corresponding increase in the number of accidents. Many oil trains pass through sensitive environmental habitats and densely populated areas, and even share track with commuter trains in some regions.

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  • Public Comments

    Tobacco Products and Consumer Welfare - Public Comments

    August 8, 2014

    Policy Integrity recently submitted public comments to the Food and Drug Administration (FDA) on its proposed rule to deem certain tobacco products, such as electronic cigarettes and cigars, subject to regulation. We believe the FDA may be dramatically understating the benefits from consumer behavior changes due to regulation of new tobacco products.

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