American Textile Manufacturers Institute, Inc. v. Donovan

1981-06-17

Headline: Court allows OSHA to set the strictest feasible cotton‑dust limits without requiring formal cost‑benefit balancing, upholds feasibility findings but rejects employer wage‑guarantee transfer rule.

Holding: The Court held that the Act does not require OSHA to perform a cost‑benefit test, upheld the Cotton Dust Standard’s feasibility findings, and invalidated the wage‑guarantee transfer requirement for lack of proper justification.

Real World Impact:

Affirms OSHA may set health standards limited by technological and economic feasibility.
Keeps stricter cotton‑dust exposure limits in many workplaces.
Strikes the wage‑guarantee transfer rule; agency must justify it further.

Topics: workplace safety, cotton dust and lung disease, regulatory costs and feasibility, respirators and worker transfers

Summary

Background

Workers, unions, and the cotton industry fought over a nationwide OSHA rule limiting exposure to cotton dust, a cause of a lung disease called byssinosis. OSHA issued a Cotton Dust Standard with specific exposure limits and a mix of engineering controls, work practices, and respirator use. Industry challengers argued OSHA had to show the rule’s benefits were reasonable compared to its costs; unions and the agency said Congress required the most protective rule that is technologically and economically feasible.

Reasoning

The Court read the statute’s phrase “to the extent feasible” to mean limits set by technological and economic feasibility, not a mandatory cost‑benefit balancing by the agency. It held Congress placed worker health above other concerns except where achieving protection was infeasible. The Court found the agency’s record‑level analyses support its cost and economic‑impact conclusions and therefore affirmed most of the Cotton Dust Standard.

Real world impact

OSHA’s exposure limits and many of the safety measures remain in force, affecting cotton mills, related workplaces, and thousands of workers at risk of byssinosis. The Court rejected one requirement that employers guarantee transferred workers’ wages and benefits when they cannot wear respirators because OSHA did not adequately explain how that wage guarantee related to health protection; the case was sent back for further agency action on that point.

Dissents or concurrances

Two dissenting Justices objected: one would have reversed because the agency lacked substantial evidence for its cost estimates; another warned the “to the extent feasible” language is too vague and risks an improper delegation of legislative policy choices.