Administration Sending Wrong Message on Regulatory Review

Disappointing “Cumulative Effects” Memo Incorrectly Frames Safeguard Issue

March 20, 2012

Contact: Rich Robinson, Public Citizen, (202) 588-7773 or
Brian Gumm, OMB Watch, (202) 683-4812 or

WASHINGTON, D.C. – The Coalition for Sensible Safeguards (CSS) criticizes the “Cumulative Effects” memo released today by Cass Sunstein, administrator at the Office of Information and Regulatory Affairs (OIRA). The CSS is disappointed with the message the memo sends to federal agencies, and with OIRA’s misplaced focus on this guidance when so many crucial public health, safety and environmental rules have been stalled at the agency.

“The AFL-CIO is deeply troubled by this latest regulatory review memo from OMB directing agencies to consider the cumulative impact of their rules,” said AFL-CIO Health and Safety Director Peg Seminario. “This one-sided directive is focused solely on the costs and burdens to businesses, and will only serve to further delay or weaken needed worker and public protections. OMB has been holding up needed rules, for months on end; including a draft proposed OSHA rule to protect workers from silicosis, which has been held by OMB for more than a year. The Obama administration, including OMB, should direct its efforts to improving and strengthening protections for workers and the public.”

Anastasia Christman, Senior Policy Analyst at National Employment Law Project added, “While the National Employment Law Project supports a federal regulatory process that is efficient, coordinated and inclusionary, we are distressed that today’s OIRA guidance memo starts with the premise that safeguards put in place to protect American workers are ‘burdensome.’ Protecting workers from injuries on the job and ensuring that wages earned are wages paid are, in fact, critical to the ideal of work as opportunity and a pathway to self-sufficiency and should be characterized as such.”

“It can easily take close to a decade for agencies like the Environmental Protection Agency to put needed health protections into place, said Scott Slesinger, legislative director at the Natural Resources Defense Council. “The Environmental Protection Agency is already years overdue in missing innumerable Clean Air Act statutory deadlines and in issuing rules protecting Americans from toxic products and protecting our waters. This directive from the Office of Management and Budget adds another series of unnecessary burdensome requirements that will delay health protections and give solace to anti-government zealots who think businesses should be able to pollute as much as they want.”

OMB Watch President and CSS Co-Chair Katherine McFate added, “If agencies are distracted from their core missions of protecting the public because they have to endlessly analyze the cumulative effects of regulation, everyone loses. Health, safety, environmental and financial safeguards are critical to protecting American families and sustainable economic growth.”


The Coalition for Sensible Safeguards is an alliance of consumer, small business, labor, scientific, research, good government, faith, community, health, environmental, and public interest groups, as well as concerned individuals, joined in the belief that our country’s system of regulatory safeguards provides a stable framework that secures our quality of life and paves the way for a sound economy that benefits us all. For more information about the coalition, go to