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A pandemic is no time to roll back public protections.

Yet despite calls from lawmakers, advocacy organizations and even some businesses to suspend nonroutine rulemaking unrelated to the coronavirus, President Donald Trump has directed agencies to press forward with his dangerous, unpopular and corrupt deregulatory agenda as if it’s business as usual.

This administration appears eager to take advantage of the crisis and ram through deregulatory policies while the rest of the country is distracted. These actions have come despite guidance from the White House Office of Management and Budget directing agencies to prioritize their resources on contributing to the administration’s pandemic response.

Contrary to claims by opponents of effective safeguards, rolling back public protections will do nothing to stimulate economic recovery. Stronger safeguards are key to promoting public confidence and participation in normal, daily economic activity.

While the Coalition for Sensible Safeguards has taken no formal position on rulemaking moratoria, we are alarmed that so many of the rollbacks listed below will worsen and protract the current crisis – and set in motion easily prevented deregulatory disasters that will plague our nation and our world long after the pandemic has ended.

The tables below track nonroutine rulemakings unrelated to the coronavirus that the administration has actively advanced since March 13, 2020 – the date a national emergency was declared in response to the pandemic. The rules are divided into two tables: (1) final rules that the White House has cleared to take effect and (2) rules still under development for which agencies have begun the process of gathering public comments.

Federal action on both types of rules is concerning when they harm the public, workers or our environment. Proposed rules that move forward during the national emergency are problematic, because affected parties are less able to provide input as required by law and should have additional time to provide comments. Finalizing rules unrelated to the pandemic saps agency resources that should be directed toward the ongoing crisis.

Please contact David Rosen at with questions or to connect with a policy expert.

Pandemic Rollback Tracker

Table of Final Rules
Final Rule Name Agency Arrived at OIRA Date Finalized Federal Register
Nationwide Wetlands Modification Permit LooseningArmy Corps of Engineers12/12/202001/04/202101/13/2021
Independent Contractor RedefinitionDepartment of Labor12/21/202012/31/202001/07/2021
Censored Science RuleEnvironmental Protection Agency 09/14/202012/29/202001/06/2021
Migratory Bird Protection RollbackDepartment of Interior 11/09/202012/31/202001/04/2021
Ozone Pollution Standards Environmental Protection Agency 12/08/202012/22/202012/31/2020
Tip Pooling Rule Department of Labor 11/25/202012/21/202012/30/2020
Clean Air Act Cost-Benefit Analysis RevisionEnvironmental Protection Agency 10/21/202012/07/202012/23/2020
Industrial Soot Pollution StandardsEnvironmental Protection Agency 11/04/202012/04/202012/18/2020
Endangered Wildlife Critical Habitat RedefinitionFish and Wildlife Service/ National Oceanic and Atmospheric Administration11/12/202012/15/202012/18/2020
Revised Investment Advice Rule Department of Labor 11/24/202012/14/202012/17/2020
Faith-based Right to Discriminate (EO 13831) Department of Justice (and nine other agencies) 11/16/202012/03/202012/17/2020
Asylum Adjudication and ApplicationDepartment of Justice 11/24/202012/03/202012/16/2020
Immigration Proceedings Appeals Restrictions Department of Justice 11/10/202012/03/202012/16/2020
Shareholder Voting Limitation (Proxy Advisors)Department of Labor 11/25/202012/09/202012/16/2020
The Showerhead Rule Department of Energy 11/16/202012/07/202012/16/2020
Clothes Washer/Dryer Efficiency Reduction StandardDepartment of Energy 11/16/202012/02/202012/16/2020
Energy Efficiency Test WaiverDepartment of Energy 10/14/202011/05/202012/11/2020
Asylum Procedures Revision (Death to Asylum Rule)Department of Justice 10/29/202011/24/202012/11/2020
Federal Contractor Religious Exemption from Anti-discrimination Protections Department of Labor11/03/202011/24/202012/09/2020
Defining Airlines Unfair and Deceptive Practices Department of Transportation10/01/202011/24/202012/07/2020
NEPA Natural Gas ExemptionDepartment of Energy 12/04/2020
Disability Benefit Eligibility Social Security Administration 12/17/201911/10/202012/03/2020
Polluter Cleanup Financial Responsibilities Environmental Protection Agency 10/09/202011/23/202012/02/2020
Debt Collection Rule Consumer Financial Protection Bureau 11/30/2020
NEPA Process Changes (Forest Service) Department of Agriculture04/07/2020 11/10/202011/19/2020
Clean Air Act Major Sources (Once In, Always In Rescission)Environmental Protection Agency 07/16/2020 09/21/202011/19/2020
Pesticide Worker Protection Standard ExclusionsEnvironmental Protection Agency07/31/2020 10/02/202010/30/2020
Dishwasher Energy Efficiency Standards ExemptionDepartment of Energy 06/30/202010/19/202010/30/2020
Alaska Wilderness Protection Removal (Roadless Rule)Department of Agriculture 06/29/2020 09/25/202010/29/2020
Egg Product Inspection RevisionsDepartment of Agriculture 05/12/202008/13/202010/29/2020
Mineral Extraction Royalty Rate Reduction Department of Interior 04/22/2020 08/18/2020 10/26/2020
Asylum Procedures/Eligibility RestrictionsDepartment of Justice 06/19/2020 10/06/202010/21/2020
Coal Ash Rule Environmental Protection Agency 09/04/202010/08/202010/15/2020
Power Plant Toxic Wastewater Environmental Protection Agency 07/15/202008/28/202010/13/2020
Fair Housing Accountability Rollback (Disparate Impact Standard)Department of Housing and Urban Development 05/07/2020 09/02/202009/24/2020
Shareholder Rights Procedural Limits Securities and Exchange Commission 09/23/2020
Faith-based Right to Discriminate (EO 13831) Department of Education 06/17/202009/08/202009/23/2020
Methane Emissions from Oil/Natural Gas Sources Limit Rollback (Reconsideration Rule)Environmental Protection Agency 06/02/202008/10/202009/15/2020
Methane Emissions from Oil/Natural Gas Sources Limit Rollback (Review Rule)Environmental Protection Agency 06/02/2020 08/10/2020 09/14/2020
Proxy Advisor Rule Securities and Exchange Commission 09/03/2020
Occupational Exposure to Beryllium Department of Labor 08/27/201909/24/201908/31/2020
Appliance Energy Efficiency Economic Justification RuleDepartment of Energy04/16/2020 06/01/2020 08/19/2020
Affirmatively Furthering Fair Housing Rule ReversalDepartment of Housing and Urban Development 08/07/2020
Volcker Rule Repeal (Banking Speculation)Comptroller of the Currency (Treasury) et al. 07/31/2020
Hazardous Materials/LNG by Rail (Bomb Trains Rule)Department of Transportation 04/30/2020 06/18/2020 07/24/2020
Payday Lending Protections RemovalConsumer Financial Protection Bureau 07/22/2020
National Environmental Policy Act (NEPA) RevisionCouncil on Environmental Quality 06/01/2020 06/30/2020 07/16/2020
Removal of TRICARE Providers from Civil Rights EnforcementDepartment of Labor05/11/202005/27/202007/02/2020
Asylum Processing Changes Department of Homeland Security06/03/2020 06/16/2020 06/26/2020
Asylum Processing Changes: 30-Day Employment VerificationDepartment of Homeland Security04/22/2020 06/16/2020 06/22/2020
Removal of Nondiscrimination Protections Department of Health and Human Services04/23/2020 06/02/2020 06/19/2020
Overtime Half-Time Pay CalculationDepartment of Labor04/14/2020 05/13/2020 06/08/2020
OCS Oil and Gas Operations Air Quality StandardsBureau of Ocean Energy Management 06/04/201905/08/202006/05/2020
Anti-Redlining Legal Protection RemovalComptroller of the Currency (Treasury)06/05/2020
Truckers Hours of Service Limit RevisionDepartment of Transportation 03/02/2020 05/14/2020 06/01/2020
Nondisclosure of Dark Money Political DonationsInternal Revenue Service 05/28/2020
Mercury Air Toxics Standards (MATS)Environmental Protection Agency10/04/2020 04/15/2020 05/22/2020
Title IX Sexual Assault Cross-Examination on College CampusesDepartment of Education11/04/2020 03/27/2020 05/19/2020
Clean Car Standards RewriteEnvironmental Protection Agency / National Highway Traffic Safety Administration01/14/2020 03/30/2020 04/30/2020
Clean Water Act Scope Redefinition (WOTUS rewrite)Environmental Protection Agency /Army Corps of Engineers12/05/2019 01/02/202004/21/2020
Chemical Data Reporting RevisionsEnvironmental Protection Agency12/12/2019 03/13/2020 04/09/2020
Coal Royalty and Civil Penalty Reduction Department of Interior12/16/202001/05/2021
Seismic Surveys for Oil & Gas Exploration National Oceanic and Atmospheric Administration11/05/202012/04/2020
School Lunch Meal Pattern and Monitoring Rollback Department of Agriculture 12/15/2020
Removal of Same-Sex Marriage Nondiscrimination in GrantsDepartment of Health and Human Services05/26/2020


Table of Proposed Rules
Proposed Rule Name Agency Arrived at OIRA Review ConcludedFederal Register
Exploratory Drilling on the Arctic Outer Continental ShelfDepartment of the Interior04/24/202010/22/202012/09/2020
School Lunch Nutrition Standards Weakening Department of Agriculture 10/26/202011/17/202011/25/2020
Environmental Reviews (NEPA Rollback) Department of Transportation 09/22/202011/05/202011/23/2020
Oil & Gas Financial Assurance Department of the Interior 11/20/201908/28/202010/16/2020
Coal Royalty and Civil Penalty Reduction Department of the Interior07/23/202007/28/202010/01/2020
Independent Contractor Redefinition Department of Labor 08/28/202009/18/202009/25/2020
Asylum Adjudication and Application Department of Justice 07/24/201908/31/202009/23/2020
Nationwide Wetlands Modification Permit Loosening Army Corps of Engineers01/29/201907/31/202009/15/2020
Global Gag Rule Extension to ContractsDefense Department3/11/20205/27/202009/14/2020
Oil & Gas Site Security, Oil & Gas Measurement Department of the Interior 08/14/201906/10/202009/10/2020
Endangered Wildlife Critical Habitat RedefinitionFish and Wildlife Service/National Oceanic and Atmospheric Administration 05/13/202007/17/202009/08/2020
Shareholder Voting Limitation (Proxy Advisors) Department of Labor 07/13/202008/28/202009/04/2020
Oil/Gas Development in National ForestsDepartment of Agriculture03/26/202007/31/202009/01/2020
Immigration Proceeding Appeals Restrictions Department of Justice 05/19/202008/03/202008/26/2020
The Showerhead Rule Department of Energy 02/13/202005/20/202008/13/2020
Clothes Washer/Dryer Efficiency Reduction Standard Department of Energy 02/18/202005/20/202008/13/2020
Homeless Transgender Anti-discrimination Protections Department of Housing and Urban Development 04/24/201906/04/202007/24/2020
Revised Fiduciary Rule for Investment ManagersDepartment of Labor 06/01/202006/25/202007/07/2020
Migrant Asylum Procedures Revisions Department of Justice 05/14/202005/29/202006/15/2020
Clean Air Act Cost-Benefit Analysis RevisionEnvironmental Protection Agency04/14/202006/03/202006/11/2020
Pipeline Safety: Gas Pipeline Regulatory ReformDepartment of Transportation 10/21/201905/22/202006/09/2020
Air Quality Standards for Particulate MatterEnvironmental Protection Agency03/04/202004/15/202004/30/2020
Removal of Firearm Ban at Water Resource ProjectsArmy Corps of Engineers11/22/201903/13/202004/13/2020
Automated Vehicle Crashworthiness StandardsNational Highway Traffic Safety Administration12/13/201903/13/202003/30/2020
Censored Science RuleEnvironmental Protection Agency11/12/201903/02/202003/18/2020
SNAP Work RequirementsDepartment of Agriculture12/03/201903/03/202003/17/2020
Environmental Review Streamlining Department of Housing and Urban Development 09/21/202012/18/2020
Poultry Inspection Speed IncreaseDepartment of Agriculture 11/06/2020
Housing Discrimination Liability Narrowing Department of Housing and Urban Development 09/23/2020


Calls to Pause Rulemaking and Extend Comment Periods


Public Interest Groups

Leadership Conference on Civil and Human Rights – May 7, 2020

Coalition for Sensible Safeguards – April 23, 2020

National Low-Income Housing Coalition (housing) – April 10, 2020

47 Public Interest Groups – March 24, 2020

Chesapeake Bay Foundation – March 23, 2020

170 Public Interest, Labor and Grassroots Organizations – March 19, 2020


Lawmakers and Regulators

18 U.S. Senate Democrats (EPA) – April 14, 2020

U.S. House Committee on Financial Services Democrats (financial) – April 7, 2020

U.S. House Committee Chairs – April 1, 2020

21 State Attorneys General – March 31, 2020

National Associations of Governors, State Legislatures, Mayors, Counties and Cities – March 20, 2020

U.S. Sen. Sherrod Brown (D-Ohio) (financial) – March 17, 2020


Regulated Industries and Businesses

Independent Community Bankers Association – March 30, 2020