Key Takeaways

• OSHA’s authority has been shaped through landmark Supreme Court and appellate court decisions.
• The cotton dust case clarified that OSHA standards require feasibility analysis, not strict cost-benefit balancing.
• Judicial interpretation reinforced OSHA’s role in setting health standards despite industry resistance.
• The Mallard Bay case expanded OSHA jurisdiction when other federal agencies fail to actively regulate.
• These rulings collectively established OSHA as a central enforcer of workplace safety law.

Landmark OSHA court cases that defined federal workplace safety authority through feasibility, jurisdiction, and enforcement rulings.

Jeff Rosenblum is a seasoned legal and human capital executive with extensive experience in labor, employment, and administrative law. Over more than a decade with the Federal Deposit Insurance Corporation, he held senior roles that combined legal oversight with workforce leadership, including serving as chief human capital officer. In that position, Jeff Rosenblum oversaw nationwide human resources operations and played a central role in labor relations, compensation policy, and organizational restructuring.

His background also includes senior legal roles at the U.S. Securities and Exchange Commission and the U.S. Department of Justice, where he worked on complex regulatory and employment matters. In addition to his government service, he has spent nearly two decades teaching employment law and related subjects as an adjunct professor.

This professional experience provides relevant context for understanding how federal workplace safety laws, including OSHA, have been shaped through landmark litigation and judicial interpretation.

Landmark OSHA Labor Cases That Defined Its Authority

US labor law protects workers against discrimination and harassment, including the Occupational Safety and Health Act (OSHA), which focuses on workplace safety. Enacted by Congress in 1970, OSHA, a federal employment law, applies to both the private and public sectors.

OSHA regulates workplace safety and health standards, mandating that employers provide safe workplaces without any “recognized, serious hazards.” In instances of noncompliance, it also requires employers to cooperate with OSHA workplace inspections and investigations.

A landmark case arose in December 1978, when OSHA published its intention to change federal standards defining acceptable levels of cotton dust exposure. A 90-day comment period, culminating in two weeks of hearings, accompanied the proposed change. Secretary of Labor Raymond J. Donovan found that exposure to cotton dust presented a significant health risk, warranting a new OSHA standard.

The ruling meant new expenses for the cotton industry interests, which needed to install new equipment and engineering controls, and revamp work practice protocol within four years. The cotton industry petitioned the US Court of Appeals for the District of Columbia, arguing that the new standard had no reasonable or well-defined cost-benefit relationship. They questioned whether the validity of OSHA standards required enough significance to offset expenses associated with new standard adoption.

Justice William J. Brennan, Jr. delivered a 5-3 majority opinion in the Supreme Court, requiring OSHA to complete a feasibility analysis but not a cost-benefit analysis. The court also held that OSHA had undertaken a reasonable feasibility and cost evaluation regarding the implementation of cotton industry standards. Dissenters, including Justice William H. Rehnquist and Chief Justice Warren E. Burger, argued that the Act unconstitutionally delegated policy-making authority, rendering the exact authorities OSHA held in enacting standards unclear. From this perspective, the feasibility requirement was “not a decision, but a compromise.”

A 1997 explosion also helped establish the scope of OSHA’s authority. The explosion resulted in several worker injuries and deaths on the oil and gas exploration barge Mallard Bay Drilling Rig 52 during its offshore well drilling within Louisiana’s territorial waters. The Coast Guard investigation failed to find evidence of wrongdoing against Mallard. However, describing the barge as an un-inspected vessel implied that Rig 52 had not been comprehensively subject to Coast Guard regulations.

OSHA stepped up as the authority issuing a citation against Mallard for violations of workplace safety standards. Mallard refuted these claims, holding that OSHA did not have jurisdiction for issuing such citations, as Rig 52 did not qualify as a “workplace” under the Act’s section 4(a). In addition, Mallard held that 4(b)(1) of the Act gave authority exclusively to the Coast Guard in prescribing and enforcing standards of occupational health and safety on Rig 52 and similar vessels.

An Administrative Law Judge determined that Rig 52 did qualify as a “workplace” under the Act. However, a Court of Appeals ruling reversed this, giving preference to the Coast Guard’s exclusive jurisdiction over conditions for seamen working on vessels. Ultimately, the Supreme Court held, in an 8-0 decision, that OSHA held jurisdiction for issuing the citations. In his opinion, Justice John Paul Stevens noted that the Coast Guard had failed to assert its comprehensive regulatory jurisdiction or affirmatively regulate the working conditions on board. “Mere possession by another federal agency of unexercised authority… is insufficient to displace OSHA’s jurisdiction.”

FAQs

What is OSHA’s core legal authority?

OSHA derives its authority from the Occupational Safety and Health Act of 1970, which mandates safe workplaces. The Act empowers OSHA to set standards and enforce compliance through inspections and citations.

Why was the cotton dust case significant?

The legal case clarified that OSHA must demonstrate feasibility rather than perform a formal cost-benefit analysis. This ruling strengthened OSHA’s ability to issue health standards despite high compliance costs.

How did the Supreme Court define feasibility?

The Court held that feasibility involves whether standards can be implemented technologically and economically. It does not require proving that benefits outweigh costs in precise monetary terms.

What did the Mallard Bay case establish about jurisdiction?

The ruling confirmed that OSHA retains jurisdiction unless another federal agency actively regulates workplace conditions. Unexercised or theoretical authority is not enough to displace OSHA enforcement.

Why do these cases still matter today?

They define how far OSHA can go in regulating workplace safety across industries. Courts continue to rely on these precedents when evaluating modern enforcement and regulatory challenges.

About Jeff Rosenblum

Jeff Rosenblum is a former chief human capital officer of the Federal Deposit Insurance Corporation, where he led nationwide human resources operations and oversaw labor and employment matters. His prior roles include assistant general counsel at the FDIC, deputy general counsel at the U.S. Securities and Exchange Commission, and general counsel within the U.S. Department of Justice. In addition to his public sector work, he has taught employment law, ethics, and legal writing as an adjunct professor at George Mason University Law School for nearly two decades.