American Mining Congress v. Mine Safety & Health Administration
United States Court of Appeals for the District of Columbia Circuit
995 F.2d 1106 (1993)
Relevant factsFree
MSHA (defendant) issued Program Policy Letters, without notice and comment, interpreting when x-ray results constituted a "diagnosis" triggering mine operators' reporting duties under its existing Part 50 regulations; the American Mining Congress (plaintiff) challenged the PPLs as legislative rules requiring notice-and-comment rulemaking.
IssueFree
Whether agency policy letters are interpretive rules within the meaning of the APA where the letters do not have the full force of law.
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