This article is based on comments that I submitted to the Office of Management and Budget (OMB) as one of eight peer reviewers of OMB’s 2023 draft revisions to Circular A-4, “Regulatory Analysis.” Since that time, OMB issued a final version of Circular A-4, which was then rescinded in January 2025. This article summarizes some of my main comments on the 2023 draft version that I submitted as a peer reviewer, along with a “prologue” that summarizes some of the main issues raised in my peer review and an “epilogue” recognizing both the initial revision of Circular A-4 that was initially adopted, as well as the 2025 decision to rescind the revised version and return to the 2003 version of the circular. The 2003 Circular continues to provide useful guidance, but could have been improved by expanding the scope of regulatory impact analysis in ways discussed in my peer review comments.

This article argues for domestic legislative regulation of global value chains to protect offshore workers. First, it outlines the policy reasons necessitating such legislation. Empirical evidence confirms that global value chains are a dominant feature of the global economy. It is contended that lead firms wield influence in global value chains in a manner which leads to poor outcomes for offshore workers. Second, the article sets out the minimum steps necessary for a domestic state to attribute the responsibility for transparency of global value chains to lead firms. Then, it proceeds to explore the possibilities and limits of the proposed scheme of regulation. Despite some complexities with implementing the scheme, it is argued that if domestic legislative regulation of global value chains strengthens even to a small extent the monitoring of global labour issues, it is worth pursuing.