The Center for Progressive Reform works to protect and improve the quality of public debate on environmental, health and safety issues by promoting a sound regulatory process. Toward that end, CPR scholars file comments with regulatory agencies, testify before congressional committees, publish opinion articles, and prepare white papers and reports. These products build on the academic scholarship and research conducted by CPR scholars. Recent CPR work on issues concerning the regulatory process includes:

• In January 2007, President Bush issued Executive Order 13,422, amending a previous order (EO 12,866) to impose a series of steps aimed at making it harder for administrative agencies of the government to adopt regulations protecting health, safety and the environment.
  
  
  • Read CPR Member Scholar David Vladeck's February 13, 2007 testimony on EO 13,422 before the Committee on Science and Technology Subcommittee on Investigations and Oversight, U.S. House of Representatives.
  
  
  
• Regulatory 'Underkill'. The Bush Administration's ongoing effort to weaken regulatory safeguards for health, safety, and the environment has taken many guises. Read about it in "Regulatory Underkill: The Bush Administration's Insidious Dismantling of Public Health and Environmental Protections," by William W. Buzbee, Robert L. Glicksman, Sidney A. Shapiro and Karen Sokol. White Paper 503, February 2005.
  
  
• OMB and Risk Assessment. In early 2006, the White House Office of Management and Budget's Office of Information and Regulatory Affairs issued a Proposed Risk Assessment Bulletin that would weaken statutory protections by circumventing congressional authority, demand reproducibility of results in risk assessments, and prioritize risk management options before settling on the risk to be assessed. In additional, the proposal would establish an onerous set of rules for all government-generated risk assessments while establishing absolutely no standards for agency activities typically characterized by industry-generated risk assessments.
  
  
  • Read Rena Steinzor's May 23, 2006 "The Legacy of John Graham: Straight-Jacketing Risk Assessment," a Guest Perspective in the May 23, 2006 Inside EPA's Risk Policy Report, posted here by permission of Risk Policy Report.
    
    
  • Read the cover story on the risk assessment bulletin in the March 2006 issue of CPR Quarterly News.
    
    
  • Read the Proposed Risk Assessment Bulletin as published by OMB in January 2006.
  
  
  
• Peer Review. A September 15, 2003 proposal from the Office of Management and Budget would require peer review of some studies used in the regulatory process. In CPR’s view, the proposal exceeds OMB’s statutory authority, would severely hinder the regulatory process, and by not requiring peer review of industry research, would badly tilt the regulatory process in favor of polluting industries.
  
  
  • Read Sidney Shapiro's comments on OMB's Revised Information Quality Bulletin on Peer Review, filed on May 27, 2004.
    
    
  • Read CPR's Sidney Shapiro's reaction to OMB's April 15, 2004 revised Peer Review Guidelines.
    
    
  • Read CPR’s December 7, 2003 comments on OMB’s Proposed Bulletin on Peer Review and Information Quality
    
    
  • Read comments of other organizations on OMB's Proposed Bulletin on Peer Review: the Natural Resources Defense Council, OMB Watch, Rep. Henry Waxman and colleagues, Professor David Michaels of George Washington University, Sheila Jasanoff of Harvard University, the Association of American Medical Colleges and the Federation of American Societies for Experimental Biology (jointly submitted), the American Association for the Advancement of Science, former EPA official Victor Kimm, the Federation of American Scientists, the American Public Health Association, and Public Citizen.
    
    
  • Read OMB’s Proposed Bulletin on Peer Review and Information Quality.
    
    
  • Read CPR's Sidney Shapiro's "OMB’s Dubious Peer Review Procedures," published in the January 2004 Environmental Law Reporter.
    
    
  • Read a letter from a bipartisan group of 20 former regulators to the OMB, protesting the peer review proposal.
    
    
• OMB and Cost-Benefit Analysis. CPR believes that cost benefit analysis (CBA) has many methodological and conceptual deficiencies when applied to regulations aimed at protecting the quality of the environment and reducing risks to human health, whether those risk come from workplace exposures, general environmental conditions, or from other sources. (See the CPR Perspective on CBA) CPR's commentary on OMB's Cost Benefit Reporting includes
  
  
  • Read Amy Sinden and Sidney Shapiro's comments on OMB's "Draft 2007 Report to Congress on the Costs and Benefits of Federal Regulations."
    
    
  • Read Amy Sinden's July 2006 comments on OMB's draft report to Congress on the Costs and Benefits of Federal Regulations.
    
    
  • Read the CPR News Release on John Graham's departure from OIRA, "CPR's Steinzor on John Graham's Departure from OIRA: 'Graham Legacy is Weaker Safeguards, Cozier Relationship with Industry,'" January 27, 2006.
    
    
  • Read David Driesen's June 2005 White Paper, "Is Cost-Benefit Analysis Neutral? An Analysis of the Bush Administration's Approach to Environmental, Health, and Safety Protection."
    
    
  • Read Thomas McGarity and Amy Sinden's comments on OMB's 2005 Draft Report to Congress on the Costs and Benefits of Federal Regulations.
    
    
  • Read Sidney Shapiro's April 12, 2005 congressional testimony on OMB's regulatory "hit list."
    
    
  • Advocates of cost-benefit analysis frequently claim that rational regulation requires CBA and suggest that all other ways of setting standards are irrational. CPR believes that several competing approaches to standard-setting are rational, and ethically superior to CBA. CPR’s rationality series explains why these alternatives offer rational approaches to limiting pollution. Read the first in this series of white papers, David Driesen's "Feasibility Principle."
    
    
  • Read "Responsible Regulation Sabotaged," by Sidney A. Shapiro and Thomas O. McGarity, published September 22, 2004 on the Center for American Progress website.
    
    
  • Read Lisa Heinzerling and Frank Ackerman's "Applying Cost-Benefit Analysis to Past Decisions: Was Protecting the Environment Ever a Good Idea?," with Rachel Massey. A CPR White Paper, published July 24.
    
    
  • Frank Ackerman and Lisa Heinzerling’s comments on OMB’s 2004 Draft Report to Congress on the Costs and Benefits of Federal Regulations
    
    
  • Read Frank Ackerman and Lisa Heinzerling's April 26, 2004 op-ed in the San Jose Mercury News on the Bush Administration's use of cost-benefit analysis to foil California environmental laws.
    
    
  • Testimony by Robert Verchick on OMB's 2004 Draft Report to Congress
    
    
  • Read Lisa Heinzerling and Frank Ackerman's February 25, 2004 Op-Ed in the LA Times on the failings of cost-benefit analysis.
    
    
  • Listen to Ackerman and Heinzerling discuss cost-benefit analysis with Jim Tozzi of the Center for Regulatory Effectiveness, and former OMB official Sally Katzen, at a forum sponsored by the Center for American Progress on February 25, 2004. (This link takes you to the website of the Center for American Progress.)
    
    
  • Comments on OMB's 2003 Draft Report to Congress
    
    
  • Comments on OMB's 2002 Draft Report to Congress
    
    
  • Testimony by Lisa Heinzerling on OMB's 2003 Draft Report to Congress
    
    
  • August 2002 Comments on EPA's proposal to incorporate Cost-Benefit Principles into the Technology Based Standards for Cooling Water Intake Structures
    
    
• Information Quality Act. The Information Quality Act has potentially profound implications for the ability of federal agencies to act in advance of conclusive evidence that environmental harm or adverse health effects are being caused by private polluters. (See the CPR Perspective on the Data Quality Act)
  
  
  • Read Sidney A. Shapiro, Rena Steinzor and Margaret Clune's "Ossifying Ossification: Why the Information Quality Act Should Not Provide for Judicial Review," CPR White Paper #601, published February 2006.
    
    
  • Read Sidney Shapiro's "Case Against the Information Quality Act," The Environmental Forum (the policy journal of the Environmental Law Institute), July/August 2005. (Posted by permission.)
    
    
  • Read Sidney Shapiro's July 20, 2005 IQA testimony before the Subcommittee on Regulatory Affairs of the House Government Reform Committee.
    
    
  • Read "Truth and Science Betrayed: The Case Against the Information Quality Act," by CPR Scholars Thomas O. McGarity, Sidney A. Shapiro, and Rena I. Steinzor," CPR former Senior Policy Analyst Joanna Goger, and CPR Policy Analyst Margaret Clune, published March 2005. Read CPR's news release on "Truth and Science Betrayed."
    
    
  • In January 2005, CPR Scholars Robert Verchick, Rena Steinzor, and Sidney Shapiro, joined by CPR Policy Analyst Margaret Clune, called on EPA to take a series of steps to protect the health of East Baton Rouge-area residents whose food supply has been poisoned by PCB pollution in the Devil's Swamp Lake. Among industry's many efforts to avoid taking responsibility for cleaning up its mess: an Information Quality Act challenge. Read more.
    
    
  • October 2004 article by CPR scholars John Applegate, Don Hornstein, Tom McGarity, Sid Shapiro, Rena Steinzor, and Wendy Wagner, "Data Quality Or Scientific Censorship?" Published in Risk Policy Report, and posted here by permission. (The article reflects the views of the authors. Neither Risk Policy Report nor Inside Washington Publishers condones any particular public policy viewpoint.)
    
    
  • Read CPR's Sidney Shapiro and Rena Steinzor's August 3, 2004 response to the paint industry's Information Quality Act challenge to state rules on volatile organic compounds (VOCs) in paint.
    
    
  • May 21, 2003 letter to EPA and OMB on the Center for Regulatory Effectiveness' effort to censor NRDC comments, and CPR's accompanying news release
    
    
  • May 2002 Comments on OMB's Draft Information Quality Guidelines
    
    
• The 'Senior Discount.' OMB has directed federal regulatory agencies are to calculate the value of lives lost as a result of pollution or other regulated activity using a discounting system that cheapens the value of the lives of seniors and children. CPR's work on the issue includes:
  
  
  • CPR's reaction to EPA Administrator Christine Whitman's disavowal of "senior discounting" for cost-benefit analysis.
    
    
  • Lisa Heinzerling on May 5, 2003 NPR's Morning Edition.
    
    
  • Lisa Heinzerling's May 2003 op-ed on senior discounting.
    
    
• Tort Reform. The Bush Administration is working to limit consumers rights to sue manufacturers of faulty and defective products. CPR's work in this area includes:
  
  
  • Read CPR's White Paper, "Stealth Tort Reform: How the Bush Administration's Aggressive Use of the Preemption Doctrine Hurts Consumers."
    
    
  • Read "Tort Law, Texas Style," on the merits of regulation through litigation, by Douglas A. Kysar, published October 20, 2004 on the Center for American Progress website.