Cost of Delay

Delaying vital public protections has a cost -- both in dollars and in human lives.

The figures below represent cost-of-delay estimates for several recently completed rules. As the figures show, delays for individual rules can total in the millions or billions of dollars, put public health and safety at risk and result in significant loss of life.

To inquire about the methodology, please email Amit Narang at anarang@citizen.org.


RULE

FOREGONE BENEFITS
(millions of U.S. dollars) 

Application of the Fair Labor Standards Act to Domestic Service
$7.30
Electric Power Transmission and Distribution; Electrical Protective Equipment $163.10
Energy Conservation Standards for Commercial Refrigeration Equipment $1,101.60
Energy Conservation Standards for General Service Fluorescent Lamps and Incandescent Reflector Lamps $102.30
Energy Efficiency Standards for Metal Halide Lamp Fixtures $332.40
Occupational Exposure to Crystalline Silica $10,498.90
Produce Safety Regulation $334.90
Require Installation of Seat Belts on Motorcoaches, FMVSS No. 208 $47.66

TOTAL

$12,588.16




Application of the Fair Labor Standards Act to Domestic Service

$7.3 million in foregone benefits

RIN: 1235-AA05
Received: 1/15/2013
Completed: 9/17/2013
245 days at OIRA, 155 days delayed


Electric Power Transmission and Distribution; Electrical Protective Equipment

$163.1 million in forgone benefits
24 deaths could have been prevented
146 injuries could have been prevented

RIN: 1218-AB67
Received: 6/27/2012
Completed: 12/20/2013
541 days at OIRA, 451 days delayed


Energy Conservation Standards for Commercial Refrigeration Equipment

$1.1016 billion in forgone benefits

RIN: 1904-AC19
Received: 2/17/2012
Completed: 5/31/2013
468 days at OIRA, 378 days delayed


Energy Conservation Standards for General Service Fluorescent Lamps and Incandescent Reflector Lamps    

$100.5 million in forgone benefits from general service fluorescent lamps
$1.8 million in forgone benefits from incandescent reflector lamps

RIN: 1904-AC43
Received: 12/3/2013
Completed: 4/9/2014
127 days at OIRA, 37 days delayed


Energy Efficiency Standards for Metal Halide Lamp Fixtures

$332.4 million in forgone benefits

RIN: 1904-AC00
Received: 2/17/2012
Completed: 8/12/2013
541 days at OIRA, 451 days delayed


Occupational Exposure to Crystalline Silica

$10.4989 billion in forgone benefits
1,564 silica-related mortality cases could have been prevented
3,604 cases of silicosis morbidity cases could have been prevented

RIN: 1218-AB70
Received: 2/14/2011
Completed: 8/23/2013
920 days at OIRA, 830 days delayed


Produce Safety Regulation

$334.9 million in forgone benefits
1.44 million food-borne illnesses could have been prevented

RIN: 0910-AG35
Received: 12/9/2011
Completed: 1/4/2013
391 days at OIRA, 301 days delayed


Require Installation of Seat Belts on Motorcoaches, FMVSS No. 208

$47.66 million in forgone benefits
3 deaths could have been prevented
104 moderate and severe injuries could have been prevented
171 minor injuries could have been prevented

RIN: 2127-AK56
Received: 2/2/2013
Completed: 11/20/2013
291 days at OIRA, 201 days delayed




Further Reading on the Cost of Regulatory Delay

For more information about the cost of regulatory delay, please consult these reports.


Down the Regulatory Rabbit Hole: How Corporate Influence, Judicial Review and a Lack of Transparency Delay Crucial Rules and Harm the Public

Coalition for Sensible Safeguards: June 2013

The Perils of OIRA Regulatory Review: Reforms Needed to Address Rampant Delays and Secrecy

Public Citizen: June 2013

Public Safeguards Past Due: Missed Deadlines Leave Public Unprotected

Public Citizen: June 2012

The Cost of Regulatory Delay

Demos: August 2011