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I certainly believe you that Mendeloff is exagerrating his claims, his line about the lowest feasible level just seemed minor to me compared to his + the other interviewed subjects' main argument about ever-increasing procedural requirements.
Definitely interested in the idea that the procedural requirements are less of a time burden than the data digging required by overambitious regulatory targets - though can those really be separated? It seems like a ton of the procedural load is specifically around data collection and review.
Where do you access the timeline / breakdown of how the time was used for the Benzene process? I couldn't seem to find it in the EHP writeup.
At least for the data collection side, my argument's that they're doing a lot of stuff that's very time-consuming and difficult specifically so they can promote very low targets and limited thresholds of economic feasibility, and they don't have to do that and still be useful as a regulatory agency. It's still a time burden to prove, even for low standards of certainty, obvious signals and straightforward risks, but it's a lot easier to go "Professor, Fire Hot" than it is to isolate a one-in-a-million risk that only a thousand people got exposed to.
I'm afraid the best approach is to look through the procedural history for court cases and the sources used to promote the final rules: Industrial Union Department v. American Petroleum Institute makes clear that OSHA had requested a study in "spring of 1976", received a preliminary result in April, 1977. While they had diddled the figures to make them match what OSHA wanted (by incorrectly assuming that the historic leukemia deaths were from <25 ppm exposures, when at least some of the exposures were probably much higher), the data was strong for exposures around 100 ppm. OSHA just didn't want to push that or even a reasonable safety factor from that because it had begun accepting a zero-threshold model for most carcinogenic materials, and because there wasn't much space below the (then-voluntary) 10 ppm threshold already present.
Getting numbers that precise with any accuracy required a lot of work and a lot of time, simply because the signal was so tiny. OSHA maintained (and afaik, has not been stopped by courts) from treating one-in-a-million risks as 'significant' for regulatory purposes, but you can look at the analysis and watch the studies walk toward the eventual threshold OSHA wanted. That wasn't really done until the mid-1980s, though, arguably the earliest with Crump 1984 but OSHA looked to depend more on Rinsky 1987.
By contrast, again pointing to IFU v API, OSHA asked a consultant to evaluate and estimate the costs of a 1 ppm threshold in October 1976, and that consultant finished the entire economic impact study by May 1977.
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