OSHA’s Rulemaking Timeline: Causes of Delay and Options for Improving Efficiency

The length of the Occupational Safety and Health Administration (OSHA) air contaminants rulemaking process impairs the agency’s capacity to protect workers from exposure to toxic chemicals and increases the burdens of the regulatory process to all participants. My researchevaluates several strategies to shorten OSHA’s rulemaking timeline using a networked process model based on information gathered from in-depth interviews with rulemaking experts to simulate a key stage of OSHA’s rulemaking process. From the results of this analysis, Irecommend that OSHA should take steps to streamline its process for developing a Notice of Proposed Rulemaking by designing templates for components of its rules and taking steps to reduce the length of time required to perform key regulatory analyses. OSHA should complement this effort with rulemaking strategies that address worker exposures to multiple chemicals simultaneously.