The Industrial Union Department of the AFL-CIO (AFL-CIO) (plaintiff), a labor union, sued James Hodgson (defendant), the secretary of the Department of Labor (DOL), in the United States Court of Appeals for the District of Columbia Circuit. The AFL-CIO challenged: (1) the DOL's interpretation of the Occupational Safety and Health Act (OSHA), and (2) a rule the DOL implemented under OSHA to regulate asbestos dust in the workplace. Although OSHA specified general policy objectives and provided a procedure for setting standards, OSHA left most of the implementation details to the DOL. The DOL made extensive and highly technical fact findings in support of its asbestos rule. However, many issues required the DOL to make its own policy judgments. Two judgments made by the DOL were: (1) to give all industries the same target date for compliance with the rule, and (2) to require different retention periods under the rule for different types of records.