This section contains the nature of the case and procedural background.

Byssinosis is primarily caused by the inhalation of cotton dust. In its most severe form, this disease is chronic, irreversible, and severely disabling. It can contribute to death from heart failure. Estimates indicated that 1 in 12 employed and retired cotton workers suffered from the most severe versions of this disease. OSHA adopted a standard of 1000 micrograms per cubic meter exposure limit over an eight-hour workday. In 1976, it proposed to lower that standard to 200 micrograms. It adopted the new standard in 1978. In promulgating the Cotton Dust Standard, OSHA interpreted the Act to require adoption of the most stringent standard to protect against material health impairment, bounded only by technological and economic feasibility. The estimated cost of compliance was $543 million. OSHA interpreted the Act to require adoption of the most stringent standard to protect against health impairment, bounded only by technological and economic feasibility. A lower standard of 100 micrograms was rejected as not within the technological capabilities of the industry. The dispute was over the meaning of the words 'to the extent feasible.' P claimed that this term required cost-benefit analysis.

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