American Mining Congress v. Mine Safety and Health Administration
United States Court of Appeals for the District of Columbia Circuit
995 F.2d 1106 (1993)
- Written by Eric Cervone, LLM
Facts
The Mine Safety and Health Administration (MSHA) (defendant) maintained regulations—known as Part 50 regulations—that covered the notification, investigation, reports, and records of accidents, injuries, illnesses, employment, and coal production in mines. Under these regulations, which were adopted via notice-and-comment rulemaking, mine operators were required to report occupational illnesses that occurred within a mine to MSHA within 10 days of the illness occurring or within 10 days of it being diagnosed. The agency issued three Program Policy Letters (PPLs) regarding the interpretation of when X-ray results constituted a diagnosis of one of the lung diseases covered by the Part 50 regulations. The PPLs were issued without notice and comment and were not published in the federal register, but they were distributed to all mine operators and other relevant parties. The American Mining Congress (plaintiff) argued that the Administrative Procedure Act (APA) required notice and comment prior to the promulgation of the PPLs. Petitions for review were brought before the federal court of appeals, which considered whether the PPLs were interpretive rules under the APA.
Rule of Law
Issue
Holding and Reasoning (Williams, J.)
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