Reinstate PRO Good Guidance rule; expand small-business regulatory exemptions
Mandate wants DOL’s PRO Good Guidance rule restored, APA limits on guidance, Regulatory Flexibility Act exemptions, higher NLRB jurisdictional thresholds, and OSHA fine exemptions for small first-time non-willful violators.
Mandate
Mandate Ch. 18 (Labor) — Clear Rules on Guidance / Exemptions for Small Business: reinstitute PRO Good Guidance via notice and comment; Congress should limit guidance in APA; agencies should exempt small entities under RFA where possible; raise NLRB jurisdiction revenue thresholds; exempt small first-time non-willful OSHA violators from fines.
Undo plan
1) Keep ability to issue protective guidance rapidly for workers while improving transparency portals.
2) Reject blanket small-business opt-outs from core wage/safety rules.
3) Maintain OSHA deterrence for serious hazards regardless of first-time status when risk is high.
4) Codify guidance indexing without disabling enforcement.
5) Verify: OSHA serious-violation rates; guidance public docket completeness.