The costs imposed by federal regulatory activities serve as banner and litmus test for those seeking to curtail government involvement in the economy. Interest in deregulation encompasses both economic and environmental/public health regulation, although the purposes of each are quite different, as are the criteria appropriate to their assessment. The focus on costs has stimulated an effort to demonstrate the magnitude of benefits provided through regulation. This effort encounters serious methodological difficulties in the environmental/ public health area, including the imputation of economic value to human life, and poorly defined health outcomes.

The Occupational Safety and Health Administration (OSHA) has resisted pressures to quantify the benefits expected from more stringent standards for occupational exposures, but recent and imminent Supreme Court decisions or congressional action may compel the agency to incorporate procedures for weighing benefits and costs to justify exposure standards.

This essay is an examination of some of the pros and cons of this possible development in OSHA's regulatory process. In particular, it argues that benefit–cost methodology is insufficiently developed for handling major elements of regulatory decisions in this area; that its use can only extend the range of controversy, and that the focus of the benefit–cost/efficiency paradigm ignores important aspects of social structure, discouraging efforts to enhance the health resource base of particular groups and neglecting the consequences of the form in which certain costs are imposed.

The past decade has been marked by legislation aimed at controlling human exposure to toxic substances. This legislation includes numerous acts that address various substances in diverse exposure settings.