Is OSHA’s Emergency Response Standard Too Expensive?

This NPR story (https://www.kcur.org/news/2024-10-14/volunteer-fire-departments-worry-about-proposed-safety-rules) highlights a particular issue that often arises in regulatory scenarios: costs of a new regulation can be disproportionately high for small organizations like volunteer fire departments or small companies. When we are talking about small companies within a larger industry, we either exempt small businesses from the regulation, or we decide to live with the consequences of putting some companies out of business because the overall benefits of the regulation are very large in comparison to the costs to the industry as a whole.

OSHA found that this rule had $2.6 billion in annual benefits (54 fewer fatalities per year and numerous fewer cases of cancer and injuries) and $545 million in annual costs, which means that somewhere in the United States as a whole there is enough benefit to cover the cost, but those benefits may not be in the hands of these volunteer fire departments. If that is the case, and these values hold up to scrutiny and justify the new rule, governments should find a way to offset these costs, so that they can comply and reap the benefits along with the better funded professional fire departments.

Finally, a pet peeve… The proposed regulation together with its justification including all of the safety, health, and economic analysis ran to 608 pages with the required formatting of the federal register (the length mentioned in the article as a critique of its complexity), this is not the text of the rule itself, which is much shorter and concise. You can see this justification document for yourself here (https://www.federalregister.gov/documents/2024/02/05/2023-28203/emergency-response-standard?utm_campaign=subscription+mailing+list&utm_medium=email&utm_source=federalregister.gov).