Writing a Regulatory Punch List

Everyone needs to clean out the attic from time to time.  Through that process, you often come across things that you want to keep, that need to be repaired in order to be useful and that are just out of date and can be tossed. Featured image

With that in mind, this past week the CPSC published a draft plan for retrospective review of its existing rules—that is, a plan to develope a punch list for rules that need review.  The agency is asking for comments on the draft plan and those comments are due by December 28, 2015.  The draft review plan pushes forward the commitment the commissioners made earlier this year to engage in meaningful review of rules that are already on the books to identify regulations that are obsolete, excessively burdensome, counterproductive, ineffective or in need of modernizing.  Unlike the Commission’s earlier effort in 2012, this plan makes clear that all rules are potential candidates for review.  And it provides a mechanism for getting the public’s suggestions for rule review candidates.

The draft plan shows a commitment on the part of the agency to undertake a serious review of its rules.  But it remains to be seen whether this will be a plan with any teeth behind it or just another empty head-nod to good administrative practice. I do note that the plan does not include dedicated resources for implementation. And, importantly, it does not include a continuing commitment to provide for a review plan and metrics for that review in all new rules the agency issues.  That would be a helpful addition to assure that this plan does not just get stuffed back up into the regulatory attic to languish.

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