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Friday, August 25, 2006

Bill Berkowitz: Dudley Do-Wrong
In a column for WorkingForChange, Bill Berkowitz compiles a pretty damning case against Susan Dudley. Berkowitz interviews a variety of advocates for public health, safety and the environment, all of whom express deep concerns about the nomination:

"If Dudley is confirmed by the Senate, she will further strip them of their ability to stand up to government secrecy, politicization and corporate interests," said Public Citizen President Joan Claybrook. "Throughout her career, Dudley has consistently fought against government safeguards and advocated a radical, hands-off approach.

"Dudley would be the most anti-regulatory zealot within the Bush Administration, bar none," Scott Silver, the executive director of Wild Wilderness told me in an e-mail exchange. "Her ideology is based upon a core belief that regulations are generally bad and there should be no regulation unless it can be proven to be cost effective and supported from within the market place."

Visit Dudley Watch and find out more about Bush's radical nominee.

Posted by Genevieve Smith, 10:35:39 AM



Dudley's Disturbing Views on Worker Health and Safety
Former OSHA and MSHA policy analyst Celeste Monforton blasted OIRA nominee Susan Dudley in yesterday’s Courier-Journal for her “disturbing” position on worker health and safety. Dudley recently wrote a law review article on OSHA’s regulation of respirable crystalline silica, a breathable dust that causes silicosis, an irreversible and potentially fatal lung disease. According to the CDC 1.7 million U.S. workers in occupations such as construction, sandblasting and mining are exposed to crystalline silica. Despite this evidence, Dudley claims that more information is needed before OSHA can regulate silica exposure to protect workers. Says Monforton:

Despite the authors' assertions, physicians, toxicologists and other experts have known for nearly a century that microscopic particles of SiO{-2} (silicon dioxide, or quartz), when inhaled, can penetrate deep into the lung's alveoli. The body's natural defense mechanisms attack the tiny silica particle, thereby creating scar tissue -- and with too much exposure and too much scar tissue, silicosis develops. . . . This is all well-known, indisputable science.

Dudley and her co-author are following the script first popularized many decades ago by the tobacco industry: When faced with regulation to protect the public health, always raise doubt and manufacture uncertainty about the scientific evidence.

Instead of cigarette smoking, the topic is now silica. The authors assert that a workplace regulation to prevent silicosis would be premature because "we do not know whether particular forms of silica are harmful" and the scientific evidence "comes from extremely limited sources."

Not true. The American Thoracic Society's 1997 official statement on the health effects of exposure to respirable crystalline silica includes more than 140 references, and the National Institute for Occupational Safety and Health's health hazard review lists nearly 500 scientific papers and documents to support its findings. Claims of scientific uncertainty by two law professors do not make it so.

15 miners have died in Kentucky in 2006. As Monforton points out, Dudley’s approach of questioning the underlying science could be used to delay needed protections for mine workers. “[S]tranger things have happened when ill-qualified ideologues are appointed to decision-making posts for the sole purpose of delaying or stopping all regulations,” says Monforton.

Visit Dudley Watch and find out more on Bush’s radical nominee.

Posted by Genevieve Smith, 10:16:19 AM



Friday, August 18, 2006

White House Again Fails to Correct Enormous Errors
The White House's annual draft "regulatory accounting" report once again fails to correct enormous errors that have been pointed out repeatedly over the years. There has been a very nice improvement: finally, many of the cost-benefit analyses used in the report are identified and in some cases linked to. There's more for OIRA to do to make it easier for the public to comment on the report, but at least on that end they're making some efforts.

Click here for OMB Watch's comments on OIRA's 2006 annual draft report on the costs and benefits of regulation.

Posted by Robert Shull, 02:11:32 PM



Thursday, August 10, 2006

Dudley: The Missing Docs
Well, it didn't take too long at all -- the Mercatus Center has silently restored the documents OMB Watch identified as missing from Susan Dudley's profile page.

Now you can read for yourself why she hates the Davis-Bacon Act, thinks that giving the public a right to know about the toxic hazards it is exposed to should be eliminated or weakened in the name of fighting terrorism, and believes that improving standards for arsenic in the drinking water is an unwelcome distraction from the task of protecting the water supply. That, and more.

Posted by Robert Shull, 12:40:28 PM



Tuesday, August 08, 2006

Keep Your Eye on Dudley
... with DudleyWatch, your home for analysis, background, news, and more about the White House's decision to nominate industry-backed extremist Susan Dudley to the chief regulatory policy job in the White House.



Posted by Robert Shull, 08:56:38 PM



Monday, August 07, 2006

Pro-Cost-Benefit but Anti-Dudley
Be sure to check out Brad DeLong's Semi-Daily Journal on the Dudley nomination. DeLong supports the role of cost-benefit analysis in regulatory decisionmaking, but he is nonetheless not a kindred spirit of Dudley:
I had always thought that the benefit-cost ratio from flame-retardant pajamas was high. The fact that Susan Dudley sees this as an example of government overreach.... As someone who believes in getting the benefit-cost analysis right, I find this... disturbing.

Stay tuned for the upcoming issue of OMB Watch's biweekly newsletter, The Watcher, for more on the White House's decision to nominate the radical Dudley.

Posted by Robert Shull, 10:16:04 AM



Sunday, August 06, 2006

How Important is This Dudley Nomination?
It's an obscure office that most people have never heard of, but the post of administrator of the White House OMB's Office of Information and Regulatory Affairs wields enormous power over regulatory policy. Susan Dudley promises to be ten times worse in that job than her predecessor, John Graham.

So how bad is that? Take a look back at Graham's tenure with The Graham Files.

Posted by Robert Shull, 07:41:44 PM



Saturday, August 05, 2006

A Look at Risk Assessment
Click here for Rachel's Precaution Reporter's reprint of a Nature magazine article covering the White House's Proposed Risk Assessment Bulletin.

Posted by Robert Shull, 07:12:29 PM



Wednesday, August 02, 2006

Industry-Backed Radical Named as White House Reg Czar
OMB Watch and other public interest groups have been following rumprs for the last several months that the White House intended to nominate industry-funded extremist Susan Dudley, currently housed at anti-regulatory think tank the Mercatus Center, to become the White House reg czar. The White House just made it official.

Click here for a statement from OMB Watch, and here for commentary from Public Citizen.

Meanwhile, here is PR Watch's take, under the headline Free-Market Fox Nominated to Henhouse Post:

Susan E. Dudley, the "Regulatory Studies Director" at the anti-regulatory think tank the Mercatus Center and a self-proclaimed "free-market environmentalist," has been nominated by the White House to "a little known but powerful post at the Office of Management and Budget." If confirmed by the Senate, Dudley will head the Office of Information and Regulatory Affairs (OIRA), which "reviews major agency regulations with an eye toward reducing compliance costs, and according to critics, easing burdens on companies." Dudley and Mercatus have been "very active" on OIRA issues, notes the Wall Street Journal. "Ultimately, 14 of the 23 rules the White House chose for its 2001 'hit list' were Mercatus entries."

Website: Wall Street Journal (sub req'd), August 1, 2006
[Via Center for Media and Democracy - Publishers of PR Watch]

Stay tuned for more as Dudley's nomination advances.

Posted by Robert Shull, 05:26:47 PM




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