John Graham and Phony Numbers

As the nation’s regulatory gatekeeper, John Graham would use his position as OIRA Administrator to force federal agencies to place significantly more weight on the results of cost-benefit analysis. Unfortunately, Graham’s form of cost-benefit analysis systematically overstates the costs of regulation to industry. This overstatement occurs, in part, because federal agencies often have little alternative but to uncritically accept inflated industry cost estimates.

The most ambitious retrospective analysis of regulatory cost estimates ever undertaken bares this out. A 1995 congressional Office of Technology Assessment (OTA) report shows that the actual costs of many important regulations that protect worker safety cost industry much less than was originally estimated.

Because cost-benefit analysis systemically overestimates industry compliance costs, the safeguards listed below may not have survived a regulatory review by John Graham:

If the OTA had conducted a similar study of environmental regulations, the results would probably have been the same. To mitigate against the use of such phony numbers please vote against the Graham nomination.


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