All California’s agencies conduct important work that protects and provides for the public, and all are held accountable to the people by conducting the SRIA. Cal/OSHA’s process is not different and does not warrant a special exemption. SB 772 excuses Cal/OSHA from this important analysis, allowing regulations having a significant impact on the economy to avoid the close scrutiny that would reveal their true costs and any unintended consequences.
The bill’s proponents suggest that the cost and benefit analysis of a regulation is completely satisfied by the debate in the Legislature, advisory meetings, and the public notice and comment process required by the Administrative Procedure Act (APA). This is not true – The regular rulemaking process does not adequately address economic impacts and alternative policy approaches.