Law School Case Brief
Am. Textile Mfrs. Inst. v. Donovan - 452 U.S. 490, 101 S. Ct. 2478 (1981)
"Feasible" means capable of being done, executed, or effected.
Respondents, Secretary of Labor and labor organizations, acting through the Occupational Safety and Health Administration (OSHA), promulgated a standard limiting occupational exposure to cotton dust. Petitioners, representing the interests of the cotton industry, challenged the validity of the standard pursuant to § 6(f) of the Occupational Safety and Health Act of 1970, 29 U.S.C.S. § 655(f). Petitioners argued that the Act required OSHA to demonstrate a reasonable relationship between the costs and benefits associated with the standard. The lower court held that the Act did not require OSHA to compare costs and benefits.
Under the Occupational Safety and Health Act of 1970, was OSHA required to compare costs and benefits?
The United States Supreme Court held that in promulgating a workplace health standard pursuant to 6(b)(5) of the Occupational Safety and Health Act of 1970, the Secretary of Labor was not required to determine that the cost of the standard bears a reasonable relationship to its benefits where by virtue of the plain meaning of the word "feasible," which is "capable of being done," Congress itself has defined the basic relationship between costs and benefits, by placing the "benefit" of worker health above all other considerations. According to the Court, the Act's legislative history demonstrated conclusively that Congress was fully aware that the Act would impose real and substantial costs of compliance on industry, and believed that such costs were part of the cost of doing business.
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