Abstract
In the area of chemical regulation, where twelve statutes authorize regulation by four agencies, the need for evaluation and review is particularly apparent. Benzene, which is of interest to three agencies, the Enviromental Protection Agency, the Consumer Product Safety Commission, and the Occupational Safety and Health Administration, is the subject of this case study.
The proposed benzene standards (except for intentional use in consumer products) would be difficult to justify on a benefit-cost basis using benefit values based on willingness-to-accept risks or implicit values of previous regulations. A reasonably high value for saving a human life based on willingness-to-accept risk is $1 million per life. It would have to be $5 million per life to justify the maleic anhydride standard and more than an order of magnitude greater to justify the workplace, gasoline storage and automobile refueling standards. In spite of these findings, these standards would be justified by some because they reduce the lifetime probability of dying from benzene exposure.
Alternative control levels would result in a more appropriate balance of benefits and costs. For example, if OSHA set its revised standard at 3 ppm rather than 1 ppm, the cost per death averted would be approximately $6 million rather than $22 million. If EPA limited the maleic anhydride standard to either two plants with no control, or to those two plants plus two other plants (with approximately 90% control), rather than all plants, the costs per death averted would be $2 or $3.5 million rather than $5 million.