Jim Sullivan was quoted in Bloomberg Law discussing the OSHA ETS on the COVID-19 vaccine. The Biden administration’s choice to have OSHA develop the shot-or-test rule “is so unprecedented that people are finding all kinds of ways to attack this,” said Jim. Giving OSHA the “unrestricted discretion” to further the White House’s policy priorities through emergency rulemaking “creates some serious constitutional delegation of authority questions,” he said.

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