OSHA is part of the U.S. Department of Labor. OSHA issued a "directive"under which each employer in selected industries was to be inspected unless it adopted a "Comprehensive Compliance Program"-a safety and health program designed to meet standards that in some respects exceeded those otherwise required by law. The Chamber of Commerce of the United States objected to the directive and filed a petition for review with the U.S. Court of Appeals for the District of Columbia Circuit.

The Chamber claimed, in part, that OSHA did not use proper rulemaking procedures in issuing the directive. OSHA argued that it was not required to follow those procedures because the directive itself was a "rule of procedure." OSHA claimed that the rule did not alter the rights or interests of parties, "although it may alter the manner in which the parties present themselves or their viewpoints to the agency." What are the steps of the most commonly used rulemaking procedure? Which steps are missing in this case?