by Jerry Ellig, Richard Williams
July 30, 2014
The U.S. Food and Drug Administration (FDA) has proposed a regulation to ensure that livestock feed is not “adulterated.” The Regulatory Impact Analysis (RIA) accompanying the proposed regulation provides scant assessment of the nature, cause, and significance of the animal food problem the regulation seeks to solve. In the absence of such an assessment, the RIA has no basis for estimating the benefits of the proposed rule. Our own estimate of the monetized benefits suggests that the proposed rule’s costs – as estimated by the FDA – of between $87 million and $129 million annually substantially outweigh our best estimate of $17 million in annual benefits.