Industrial Union Department, AFL-CIO v. American Petroleum Institute [1980] 448 U.S. 607

INDUSTRIAL UNION DEPARTMENT V. AMERICAN PETROLEUM INSTITUTE

Whether the Occupational Safety and Health Administration (“OSHA”) exceeded its authority by implementing a benzene exposure standard without adequate proof of a significant risk to workers?

Under the Occupational Safety and Health Act, OSHA can only impose workplace safety standards if it identifies a “significant risk” of material health impairment and supports the standard with substantial evidence.

The Occupational Safety and Health Administration (OSHA) implemented a new benzene exposure limit for workers, setting a significantly lower threshold from 10 per million parts of air (ppm) to 1 ppm.
However, OSHA did not present clear data proving that exposure at the prior threshold posed a substantial health risk.
The defendant American Petroleum Institute (“API”) challenged OSHA’s new standard, arguing that it was too stringent and lacked scientific backing.
API further contended that OSHA’s action exceeded its regulatory powers by failing to prove the existence of a significant risk requiring such a reduction.
The Court of Appeals held the standard invalid as it was based on findings that were unsupported by the administration.

The U.S. Supreme Court held that OSHA had overstepped its authority by setting a standard without adequately demonstrating a significant risk, ruling that regulatory actions should be based on substantiated evidence of necessity.
The Court further noted that OSHA had not shown the 1 ppm exposure limit was “reasonably necessary or appropriate to provide safe and healthful employment” as required by Section 3(8) of the Act. The Court emphasized that Congress had not delegated unbridled discretion to OSHA to regulate without demonstrating a direct link between exposure levels and significant risk.
The Supreme Court affirmed the judgment of the Court of Appeals.