Commentary Archive


Review Necessary to Ensure FDA’s Food Transport Rule Actually Drives Results

June 18, 2014

FDA's proposed Sanitary Transportation of Human and Animal Food rule is intended to ensure that food will not become contaminated during the transportation process. Although the rule will cost businesses hundreds of millions of dollars, FDA could not identify any tangible benefits that will result from the regulation. Given the uncertainty of the underlying data used to formulate the provisions of the rule, it is far from clear that the rule will have its intended effect. FDA should commit to using the data it collects during the implementation of the rule to annually review whether the standards are having their desired effect. If the rule is creating unnecessary costs without producing any tangible benefits, some or all of the regulations implemented by FDA could be rescinded.


Going Global- Should benefits assessments include effects on other nations?

June 11, 2014

Recent assessments of climate change policies have shifted from a domestic to a worldwide benefits approach, leading to a substantial increase in the estimated benefits. Examination of the justification of benefits assessments for GHG emission reductions suggests that government officials have gone outside the typical practice for defining the scope of benefits assessment. The justifications offered by the Interagency Working Group on Social Cost of Carbon offer weak justification for this approach. Our review suggests more convincing justification in which explicit reciprocity would justify giving economic standing to citizens of other countries and demonstrable feelings of altruism would justify partial economic standing to citizens of other countries.

Regulatory costs by agency

OMB: Both Costs and Benefits of New Regulations Down in FY 2013

June 03, 2014

Over the weekend, the Office Management and Budget (OMB) released its annual Draft Report to Congress on the Benefits and Costs of Federal Regulations (“the Report”), which provides a window into regulatory activity conducted by federal agencies in Fiscal Year 2013. The Report indicates that the new regulations issued last fiscal year involve lower annual costs and benefits than in FY 2012, and that the Environmental Protection Agency (EPA) is by far the largest contributor to both regulatory costs and benefits in this Report.