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13. OSHA Formaldehyde (pp. 27, 28, Special Report)

OMB Watch states that "OIRA forced OSHA to remove from the rule any provision that would require employers to tell their workers that formaldehyde might cause cancer.

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Response. The allegation implies that OMB disapproved the hazard communication requirements for formaldehyde, including the cancer warning. This is untrue, as even a cursory examination of OMB's five-page letter to OSHA would have revealed. OMB disapproved the hazard communication requirements in the Formaldehyde Standard in order that the broader Hazard Communication Standard would continue to apply to formaldehyde. In fact, as OSHA stated on the record, the Hazard Communication Standard requires more hazard warnings than the Formaldehyde Standard; hence, OMB's decision led to more hazard warnings, not fewer.

OMB's disapproval was not based on the number of warnings, but, rather, on the substantial confusion voiced by the public over the specific language of the formaldehyde standard, which was not clear about when and where warnings were to be given. We note that, when OMB later approved the Formaldehyde Standard provisions, OSHA decided to stay these requirements administratively "in response to numerous public comments which indicated confusion about the hazard warning provisions...." (54 FR 35639). OSHA requested comments on alternatives that "would be less confusing to the public." Meanwhile, the Hazard Communication Standard remains in effect for formaldehyde.

14. FERTILITY SUPPLEMENT TO THE CURRENT POPULATION SURVEY (Special Report)

OMB Watch stated: "OIRA reduced this annual supplement that matches women's fertility patterns with important socioeconomic and demographic data to a biennial supplement because 'the changes from year to to year are not statistically significant.' Bureau officials and other outside the agency disagreed (especially as Congress has begun considering child-care legislation). Delays in OIRA's review of an appeal forced the Bureau to withdraw it, guaranteeing that the survey will be biennial, at least temporarily, because of procedural problems."

Response. The Current Population Survey is an important economic survey that collects primarily labor force data to produce monthly employment and unemployment figures. То ensure that respondent cooperation and data quality are maintained, in this survey, OMB weighs the potential impact of all CPS Supplements on the primary data collection. The data from the Fertility Supplement did not show statistically significant changes from year to year. In addition, other Federal surveys collected similar fertility data. For these reasons, we did not believe that collecting these data annually could be justified.

APPENDIX II

Table II.1: Background Statistics on OIRA Employees as of June 1989

APPENDIX II

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