Rulemaking should not be based on conditions that existed in the past, but should be based on conditions as they exist now...we believe a temporary emergency standard would result in polarization rather than constructive definition of areas of concern and constructive problem solving.
And current enforcement procedures are penalty-oriented…. This does not square with notions of due process and fair play.
Everyone is affected by its [OSHA’s] pervasive coverage, orientation toward imposing penalties and its incredibly complex regulations and standards.…However, OSHA standards are complex and often require expert interpretation. For smaller businesses, the cost of deciphering which regulations apply to them and then determining if they conform can be excessive.
Employers do not deliberately allow work conditions to exist which cause injury or illness. Safety is good business… The goal is to have meaningless standards eliminated and achieve a law which recognizes business efforts to provide safe work places and provides fair treatment for all.
Prior to the passage of this legislation [the OSH Act], certain special-interest groups (i.e. unions) testifying in support of punitive legislation attempted to describe American business management as irresponsible and unsympathetic to safety on the job….We continue to maintain that standard setting should be carried out by an independent board of experts who are not subject to the pressures of special-interest groups.
One month [after the law took effect] a special edition of the Federal Register was published containing close to 250 pages of safety and health standards. Businessmen were given three months to familiarize themselves with these standards before the majority of them were to be effective.
We are particularly intrigued by the term byssinosis a thing thought up by venal doctors who attended last year’s ILO [International Labor Organization] meetings in Africa, where inferior races are bound to be afflicted by new diseases more superior people defeated years ago...As a matter of fact, we referred to the ‘cotton fever’ earlier, when we pointed out that a good chaw of B.L. dark would take care of it, or some snuff...Well, we want to tell Mr. [James] O’Hara [D-MI] that, and for all our life, we have hated federal interference in our lives businesses…Congressman O’Hara is typical of the lousy representation we get from time-serving Northern Democrats who sell their souls to the venal labor leaders.
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