Recent Research

Susan Dudley

Will the Occupational Safety and Health Administration's Proposed Standards for Occupational Exposure to Repsirable Crystalline Silica Reduce Workplace Risk?Dudley & Morriss in Risk Analysis

The CPSC's Off-Road Adventure, Joseph Cordes & Blake Taylor, March 23, 2015

Achieving Regulatory Policy Objectives: An Overview and Comparison of U.S. and EU Procedures, Susan Dudley & Kai Wegrich, March 2015

Improving Weight of Evidence Approaches to Chemical Evaluations, Lutter et al. in Risk Analysis, February 2015

Improving Regulatory Accountability: Lessons from the Past and Prospects for the Future, Susan Dudley, January 21, 2015

Public Comment: CO2 Emission Guidelines for Existing Stationary Sources – Electric Utility Generating Units, Brian F. Mannix, December 2, 2014

Public Interest Comment on DOE's Proposed Efficiency Standards for Commercial Heating and Cooling EquipmentSofie E. Miller, December 1, 2014

Stakeholder Participation and Regulatory Policymaking in the United States, Steven J. Balla & Susan E. Dudley, November 7, 2014

Public Interest Comment on the Proposed Definition of "Waters of the United States" Under the Clean Water Act, Tracy Mehan, November 7, 2014

Public Interest Comment on the CFPB's Proposed Home Mortgage Disclosure (Regulation C)Lindsay M. Scherber, October 29, 2014


The George Washington University Regulatory Studies Center

Susan Dudley with Kathryn Newcomer

The GW Regulatory Studies Center's mission is to improve regulatory policy by raising awareness of regulations’ effects through research, education, and outreach.

The Center is a leading source for applied scholarship in regulatory issues, and a training ground for anyone who wants to understand the effects of regulation and ensure that regulatory policies are designed in the public interest.

EVENT: From Accessibility to Comprehensibility: Comparing the Views of Patients and Doctors on EMA’s Transparency Policies

Friday, May 1, 2015 - 10:00am to 11:30am
The George Washington University

The GW Regulatory Studies Center, U.S. Department of Agriculture Office of Risk Assessment and Cost-Benefit Analysis, and the National Capital Area Chapter of the Society for Risk Analysis invite you to join us on May 1, 2015 for a conversation with Dominic Way as he discusses the results of his forthcoming paper, “From Accessibility to Comprehensibility: Comparing the Views of Patients and Doctors on EMA’s Transparency Policies.”

EVENT: Regulatory Reform Lessons from the Land Down Under

Thursday, May 7, 2015 - 2:00pm to 3:30pm
Warren Mundy

Please join us on May 7, 2015 for "Regulatory Reform Lessons from the Land Down Under." Australian Productivity Commissioner Warren Mundy will share his experiences on regulatory reform in Australia - what has worked, what hasn't, and what challenges remain. In this interactive forum, we will then explore what lessons the U.S. can draw from Australia's experience.

Public Interest Comment on the Department of Labor's Proposed Rule: Discrimination on the Basis of Sex

Pregnant woman
April 16, 2015
By Lynn White, Esq.

In this proposed rule, the Office of Federal Contract Compliance Programs (OFCCP) attempts to clarify the requirements that contractors must fulfill to ensure nondiscrimination on the basis of sex. The OFCCP understated the total costs of the proposed rule, limiting the regulatory analysis to rule familiarization and new costs associated with providing pregnancy accommodations to a limited number of contractor employees. However, actual costs could reach an estimated $130 million or more per year, according to the author's analysis.


Does Reducing Ozone Really Improve Human Health?

April 08, 2015
by Louis Anthony (Tony) Cox, Jr.

In revisiting the National Ambient Air Quality Standards (NAAQS) for ozone, EPA recently concluded that current standards do not fully suffice to protect public health with an adequate margin of safety and that further reductions would probably further reduce mortalities and morbidities in the population. Central to this conclusion is EPA's determination that "O3 exposures are causally related to respiratory effects, and likely causally related to cardiovascular effects, and that long term O3 exposures are likely causally related to respiratory effects." Remarkably, this key conclusion is not supported by any reliable, objective statistical tests for potential causality. It rests solely on the subjective judgments of selected experts, applied to associational data that show that both ozone levels and adverse health effects are higher in some times and places than in others.


GW Regulatory Policy Capstone Team Featured in GW Today

GW Capstone Group with members of the Virginia Cyber Security Commission

Over the past four months, Trachtenberg School Master of Public Policy candidates Ewan Compton, Andrew Kim, Lindsay Scherber and Nadia Yassin have put their regulatory policy training to good use while conducting a comparative analysis of Virginia’s cyber security laws on behalf of the Virginia Cyber Security Commission. The group’s capstone project and findings are discussed in greater detail in this GW Today article.

CFPB Should Consider a More Dynamic Approach to Prepaid Debit Card Regulation

April 01, 2015
by Blake Taylor, Policy Analyst

Last December, the Consumer Financial Protection Bureau proposed rules intending to improve consumers’ understanding of their choices in the prepaid debit card market and to protect them from unreasonable fees. There is little to no evidence that the proposal will have desirable consequences related to either consumer or seller behavior. What is likely is that the rule will increased compliance burdens for sellers and limit consumer choice.


Improving Weight of Evidence Approaches to Chemical Evaluations

Weight of Evidence
March 31, 2015
by Randall Lutter, Linda Abbott, Rick Becker, Chris Borgert, Ann Bradley, Gail Charnley, Susan Dudley, Alan Felsot, Nancy Golden, George Gray, Daland Juberg, Mary Mitchell, Nancy Rachman, Lorenz Rhomberg, Keith Solomon, Stephen Sundlof, and Kate Willett

Federal and other regulatory agencies often use or claim to use a weight of evidence (WoE) approach in chemical evaluation. Their approaches to the use of WoE, however, differ significantly, rely heavily on subjective professional judgment, and merit improvement. We review uses of WoE approaches in key articles in the peer-reviewed scientific literature, and find significant variations. We find that a hypothesis-based WoE approach, developed by Lorenz Rhomberg et al., can provide a stronger scientific basis for chemical assessment while improving transparency and preserving the appropriate scope of professional judgment. Their approach, while still evolving, relies on the explicit specification of the hypothesized basis for using the information at hand to infer the ability of an agent to cause human health impacts or, more broadly, affect other endpoints of concern. We describe and endorse such a hypothesis-based WoE approach to chemical evaluation.


Justices debate benefits and costs of EPA mercury power plant rule

Power plant
March 31, 2015
by Susan E. Dudley, Director

The Supreme Court last week heard oral arguments in Michigan v EPA regarding “whether the Environmental Protection Agency unreasonably refused to consider costs in determining whether it is appropriate to regulate hazardous air pollutants emitted by electric utilities.” The regulation being considered is a key part of the Obama administration’s environmental agenda and would require coal-fired power plant operators to install equipment to reduce mercury and other air pollutants. Section 112 of the Clean Air Act directs the EPA to issue regulations that are “appropriate and necessary” to control hazardous air pollutants, including mercury. Thus, one area of debate is whether a standard that imposes very large costs relative to benefits is “appropriate” under the meaning of the statute.


Public Comment: Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z)

Debit card
March 23, 2015
by Blake Taylor, Policy Analyst

This Consumer Financial Protection Bureau (CFPB or “Bureau”) proposed rule would extend various consumer protections to prepaid account products. Protections for traditional bank account and credit products now exist through Regulation E, which governs electronic funds transfers, and Regulation Z, which governs the use of consumer credit. However, prepaid accounts such as debit cards that can be pre-loaded with funds are currently unregulated. CFPB proposes to amend Regulation E and Regulation Z to apply existing and new protections to these relatively new financial products by imposing various information disclosure, limited liability, error resolution, and consumer credit requirements. Before proceeding, CFPB should gather more updated information on the prepaid debit card market about sellers and buyers of prepaid cards, as required by statute. As this proposal stands, it is likely to increase costs and may reduce access with little or no discernible benefits for card users.


Will the Occupational Safety and Health Administration's Proposed Standards for Occupational Exposure to Respirable Crystalline Silica Reduce Workplace Risk?

Crystalline 200
March 26, 2015
by Susan E. Dudley & Andrew P. Morriss in Risk Analysis

This article finds that OSHA's proposed rule would contribute little in the way of new information, particularly since it is largely based on information that is at least a decade old—a significant deficiency, given the rapidly changing conditions observed over the last 45 years. The article concludes with recommendations for alternative approaches that would be more likely to generate information needed to improve worker health outcomes.


The CPSC's Off-Road Adventure

Side by side
March 23, 2015
by Joseph Cordes and Blake Taylor

This article raises issues with the Consumer Product Safety Commission's proposal to regulate recreational off-highway vehicles, commonly referred to as side by sides. CPSC issues rules to mitigate "unreasonable risks." In order to deem a risk as either reasonable or unreasonable, it is necessary to have information on the risk rate. The CPSC, however, proposed this rule without reliable information on the rates of injury and death associated with use of side by sides. Additionally, it is possible that the proposal rule, if enacted, would have a negative impact on consumer surplus if the safety standards make the products undesirable. Such a loss, however, is absent in the Commission's assessment of expected benefits and costs.


Public Comment: National Ambient Air Quality Standards for Ozone

Ozone image
March 17, 2015
by Louis Anthony (Tony) Cox, Jr.

EPA’s quantitative risk estimate (QRA) provides no legitimate reason to believe that the proposed action is “requisite to protect public health” or that reducing the ozone standard further will cause any public health benefits. Given EPA’s information and the unquantified model uncertainty that remains, there is no sound technical basis for asserting with confidence, based on the models and analyses in EPA’s ozone risk assessment, that an ozone standard of 65 ppb would be any more protective than 70 ppb, or that 80 ppb is less protective than 60 ppb. To the contrary, available data suggest that further reductions in ozone levels will make no difference to public health, just as recent past reductions in ozone have had no detectable causal impact on improving public health.


Achieving Regulatory Policy Objectives: An Overview and Comparison of U.S. and EU Procedures

Susan Dudley with Kai Wegrich
March 10, 2015
By Susan E. Dudley & Kai Wegrich

This paper aims to provide a descriptive analysis of procedural differences in regulatory development between the United States and the European Union to serve as a factual basis for understanding the regulatory challenges and opportunities for transatlantic trade. It summarizes regulatory procedures in each jurisdiction, dividing the process for establishing regulations into four stages: 1) agenda setting, 2) regulatory development, 3) final determination and opportunities for challenge, and 4) implementation and enforcement. After presenting the procedures in the U.S. and EU, the paper compares how the shared goals for achieving a regulatory system that is evidence based, transparent, and accountable are achieved in the two jurisdictions.