## Facts

- OSHA, acting through the Secretary of Labor, promulgated a health standard limiting workplace exposure to cotton dust in cotton manufacturing.
- Cotton dust exposure can cause byssinosis (“brown lung”), a serious and potentially disabling respiratory disease affecting many workers.
- The standard set permissible exposure limits for different cotton-processing operations, to be achieved mainly through engineering controls and work-practice controls.
- During a multi-year phase-in, employers also had to provide respirators and transfer employees unable to wear respirators to other positions without loss of pay or benefits.
- OSHA estimated industry-wide compliance costs at approximately $656.5 million.
- Industry groups challenged the rule, arguing that § 6(b)(5) required cost–benefit analysis and that OSHA’s feasibility findings lacked substantial evidentiary support.
- The D.C. Circuit upheld the standard, and the Supreme Court granted certiorari.

## Issues

1. Whether § 6(b)(5) of the Occupational Safety and Health Act requires OSHA to conduct cost–benefit analysis when setting health standards for toxic materials or harmful physical agents.
2. Whether OSHA’s findings that the cotton dust standard was technologically and economically feasible were supported by substantial evidence on the record as a whole.
3. Whether OSHA had statutory authority to require wage-guaranteed job transfers for workers unable to wear respirators during the phase-in period.

## Decision

- The Supreme Court affirmed the judgment upholding the cotton dust standard.
- The Court held that § 6(b)(5) requires OSHA to set the standard that most adequately protects worker health to the extent feasible, not to balance costs against quantified benefits.
- The Court concluded OSHA’s determinations of technological and economic feasibility were supported by substantial evidence.
- The Court upheld the wage-guaranteed transfer requirement as within OSHA’s authority to require necessary practices and conditions to implement a health standard.

## Legal Principles

- Under OSH Act § 6(b)(5), OSHA must select the most protective standard that is technologically and economically feasible; the statute does not require a cost–benefit test.
- “Feasible” operates as the limiting principle on stringency and includes both technological achievability and economic practicality, as supported by the record.
- In judicial review under § 6(f), OSHA’s determinations are conclusive if supported by substantial evidence in the record considered as a whole.
- OSHA may require ancillary measures (including interim practices and job-transfer conditions) that are reasonably tied to implementing and achieving the health standard’s protective requirements.

## Conclusion

The Court held that OSHA’s duty under § 6(b)(5) is to issue the most health-protective standard achievable within technological and economic feasibility constraints, without undertaking cost–benefit balancing, and it sustained both the cotton dust exposure limits and the wage-guaranteed transfer provision as supported by substantial evidence and within OSHA’s statutory authority.


Am. Textile Mfrs. Inst., Inc. v. Donovan, 452 U.S. 490 (1981)