Get to Know Susan Dudley
by Guest Blogger, 8/8/2006
In the coming weeks, we will post more straight from Dudley herself. For now, check out this sampler of her positions on important public protections.
- On Davis-Bacon: "The prevailing wage requirement does not offer net benefits to society, but rather reflects a transfer from low-skilled and low-wage workers to skilled and union workers . . . . There is no economic justification for a federal role in defining construction practices and determining wages, as required by the Davis-Bacon Act." DOL's Proposal Governing Helpers on Davis-Bacon Act Projects (June 8, 1999)
- On OSHA regulation generally: "In the case of OSHA regulation, empirical analysis has not found strong evidence that OSHA regulations have had a substantial impact on worker health and safety . . . . OSHA's regulations are costly for the economy. According to recent estimates, OSHA regulations contribute nearly one-half of the total direct cost of workplace regulations--around $41 billion per year in 2000. MSHA regulations cost another $7.4 billion. It is unclear whether these costs produce commensurate benefits. Econometric studies have generally failed to find evidence that OSHA regulations have had a significant impact on job safety." Defining What to Regulate: Silica and the Problem of Regulatory Categorization (August 11, 2005)
- On arsenic in the drinking water: The Clinton standards were "an unwelcome distraction from the task of protecting the water supply. . . . While [EPA] should share information about arsenic levels and hazards, it should not impose its judgment, based on national average costs and benefits, on individual communities as to how best to invest in their own public health." How Not to Improve Public Health (January 11, 2001)
- On food safety: "Unscientific fears, fanned by activists and short-sighted government policies, have led to a regulatory framework that singles out genetically modified crops for greater scrutiny and even prohibition. . . . Policymakers regulating agricultural biotechnology face pressure from well-organized activists to constrain the new technology. Large biotech companies do not speak out aggressively against unscientific policies, either because they don't dare offend the regulators on whom their livelihood depends, or because regulations give them a competitive advantage." Issues in Science and Technology: Forum : Genetically modified Crops (Spring 2005)
- Again on GM crops: "In spite of hundreds of thousands of field tests as well as peer-reviewed research papers, no evidence indicates the presence of any unique environmental or health risks from the products of gene-splicing." States of Fear (April 15, 2005)
- On environmental right to know: "Informing the public about hazards in their community is an intuitively desirable social goal. . . . However, this does not argue that any information on chemical releases is desirable. . . .[I]t is important to recognize that information is costly to produce, and depending on how it is communicated and received, may confuse, rather than inform. Even if we determine that information on the release of certain chemicals has a net social value, we cannot assume that more frequently reported information, or information on a broader range of chemicals would be more valuable. Only when the social costs of information are weighed against the social benefits can a determination be made regarding what and how much information is optimal." TRI Reporting of Lead and Lead Compounds (December 15, 1999)
- On investor right to know: "Concerned that investors are not receiving the information they need regarding the tax consequences of investing in mutual funds, the SEC required mutual funds to report standardized after-tax returns along with the standardized pre-tax returns they already report. . . . The SEC's only stated criterion in developing the rule is that the information be deemed 'helpful' to investors in making investment decisions. But the SEC has no way of identifying information that meets this standard except by observing what information is brought forth by the private sector. It has not identified any market failure that would warrant regulatory action." Comments on OMB's 2002 Draft Report on the Costs and Benefits of Federal Regulation (May 28, 2002)
- On privacy of consumer financial information: "The implicit premise of the rule is that individuals and firms cannot come to a mutually satisfactory agreement as far as privacy is concerned without resort to government assistance. Indeed, if individuals truly value their privacy, and firms desire to maximally satisfy their customers, then a meeting of the minds ought to be achievable without resort to compulsory regulations." Comments on OMB's 2002 Draft Report on the Costs and Benefits of Federal Regulation (May 28, 2002)
- On improved air bag standards: "NHTSA estimates that air bags have reduced fatalities in frontal crashes by about 30 percent. Moreover, judging from vehicle manufacturers' pre-regulation actions and ongoing advertising, which lists dual air bags as a positive attribute in new vehicles, consumers appear to prefer vehicles equipped with air bags. These facts, however, are not sufficient to justify federal regulation requiring air bags. If air bags protect lives, and consumers demand them, it is reasonable to assume that automobile manufacturers would have installed air bags in the absence of federal requirements to do so." Comments on Advanced Air Bags (December 17, 1998)
- On fuel economy: "Worst rule of 2003: The National Highway Traffic Safety Administration corporate average fuel economy (CAFE) standards for light trucks. NHTSA continues to force vehicle manufacturers to achieve higher miles per gallon than the market would offer, or consumers would choose, in the absence of the regulation. Absurdly, its economic model shows large net benefits to consumers even if markets are assumed to operate perfectly, i.e., without counting any externalities. We know this must be false, because any regulatory constraint that forces consumers away from their preferred choices must have negative net benefits (i.e., make Americans worse off)." Quoted in Washington Post by Cindy Skrzycki (December 2003)
