American Textile Manufacturers Institute v. Donovan

Facts

Byssinosis, known as “brown lung disease” in its severe form, is a serious respiratory disease caused by inhalation of cotton dust in textile mills. The disease progresses from mild symptoms (chest tightness, shortness of breath) to potentially severe disability and can contribute to death from heart failure. Studies showed that at least 35,000 textile workers suffered from the most disabling form of byssinosis, with over 25% of active cotton workers experiencing some form of the disease.

In 1978, after extensive rulemaking proceedings including hearings and collection of over 105,000 pages of evidence, OSHA promulgated the Cotton Dust Standard. The standard established permissible exposure limits (PELs) of 200 μg/m³ for yarn manufacturing, 750 μg/m³ for slashing and weaving operations, and 500 μg/m³ for other processes. It required implementation of engineering controls within four years, with interim reliance on respirators. OSHA determined the standard was both technologically and economically feasible, though it would impose substantial costs on the industry.

The textile industry challenged the standard, arguing that OSHA must demonstrate that the benefits of reducing health risks bear a reasonable relationship to the costs of the standard. OSHA contended that Congress had already balanced costs and benefits in the Act itself, requiring the agency to set the most protective standard feasible.