2. Unfortunately, the language of safety debates often clouds the real issues. It would be inopportune for UL to say that a significant hazard scenario is "the consumer's fault." Similarly, few people outside of the economics profession are comfortable arguing that a proposed safety measure might be effective but still not worth the cost. As a result, many arguments are cloaked in technical terms. Stated opposition to the CPSC's gas space heater standard, for example, concentrated on alleged technical problems with the oxygen depletion sensor. That none of the predicted problems have come to the attention of the Gas Appliance Manufacturers Association in the four years since this rule was adopted suggests that unvoiced concerns were probably most significant. Other arguments are cloaked under the ambiguous rubric of "a false sense of security." This argument manages to come up on both sides of many safety arguments. Opponents asserted that each of the four public sector standards in this study would lead to "a false sense of security." This is an interesting rhetorical device for arguing from a pro-safety point of view against proposed improvements in safety standards. The argument, in my view, is really directed at the philosophy (or "sense")of safety (or "security") that underlies the standard, not the perceptions that consumers might have. [BACK]

3. The five-page "worksheets" provided by the NGFA to allow operators to "better understand the financial impact of the standard" included various assumptions that inflated the results. For example, under housekeeping—the most expensive category—the worksheet combined the estimated cost of pneumatic dust control and manual dust removal, even though the rule would require only one. See National Grain and Feed Association, "The OSHA Grain Handling Safety Standard: Understanding the Financial Impact on Your Operations" (mimeographed, n.d.). [BACK]

4. Viscusi, Regulating Consumer Product Safety, 96-99. [BACK]