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By Robert William Hahn, Robert W. Hahn

This research into regulatory reform indicates that technological affects at the financial merits and prices of rules and a deeper knowing of the social results of the regulatory establishment are using policymakers to question the commonplace and to suggest bold adjustments.

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Perhaps because of the politicized nature of the debate over regulatory reform, however, those reform efforts have come about in a piecemeal fashion, and the requirements for analysis have some overlap. For example, under both the Unfunded Mandates Reform Act and Executive Order 12866, executive branch agencies must prepare benefit-cost analyses for major rules. Second, the major aims of the efforts to date have been to require more information on the benefits and costs of regulations and to increase the oversight of regulatory activities and agency performance.

While the Department of Health and Human Services, the Department of Housing and Urban Development, and the Consumer Product Safety Commission monetized benefits for all rules, agencies reported monetized benefits for only about one-fourth of all rules. 19 Less than a third of the rules with quantified benefits include monetized benefits. I relate the difference, in part, to specific agency policies stemming from statutory limitations restricting the consideration of benefits or costs. OSHA, for example, is restricted from using a benefit-cost framework as a basis for health standards.

To calculate the total benefits of a rule, I combined the benefits from health and safety risk reduction with the benefits from air pollution reduction. The estimates of air pollution reduction benefits may, however, include some benefits from morbidity and mortality risk reduction in addition to environmental protection. Consequently, a possibility of overlap exists between the air pollution reduction estimates and the health and safety risk reduction estimates because both may include benefits from reducing mortality and morbidity.

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