Nominations for Review and Reform: The Second Year of the r3 Initiative

It’s that time again, so this year, don’t miss it! The Office of Advocacy of the U.S. Small Business Administration is once again seeking nominations of federal rules in need of review and reform. This is your chance to nominate a rule that you feel needs to modified or pulled off the books entirely. The 2009 “Top 10” rules nominated by small business owners, trade associations, and others will be transmitted to appropriate federal agencies for their action.

“Changing markets, technology, and competition make it imperative that federal agencies periodically review how their current regulations affect small business,” said Thomas M. Sullivan, Chief Counsel for Advocacy. “Only with regular evaluation can agencies sift through the enormous number of current regulations to find those that are outdated and ineffective due to rapidly changing conditions. We are calling for nominations of rules needing reform, and we are asking for constructive suggestions about how to improve them.”

You can nominate regulations that you feel need review and reform by visiting the SBA Office of Advocacy Regulatory Review and Reform (r3) initiative website at, by sending an email to, or by calling Keith Holman at (202) 205-6533.

In February, Advocacy announced the 2008 Top 10 Rules for Review and Reform.  The Top 10 were drawn from over 80 rules nominated by small business owners and their representatives.  In order to track agencies’ action on these rules, Advocacy will post their status on its website every six months. Here is the current list of regulations for 2008:

Environmental Protection Agency

Update Air Monitoring Rules for Dry Cleaners to Reflect Current Technology
Flexibility for Community Drinking Water Systems
Simplify the Rules for Recycling Solid Waste
EPA Should Clearly Define “Oil” in its Oil Spill Rules

Department of Transportation/Federal Aviation Administration
Update Flight Rules for the Washington, DC, Metropolitan Area

Federal Acquisition Regulation Council

Eliminate Duplicative Financial Requirements for Architect-Engineering Services Firms in Government Contracting

Department of the Treasury/Internal Revenue Service

Simplify the Home Office Business Deduction

U.S. Department of Labor/Mine Safety and Health Administration

Update MSHA Rules on the Use of Explosives in Mines to Reflect Modern Industry Standards

U.S. Department of Labor/Occupational Safety and Health Administration

Update OSHA’s Medical / Laboratory Worker Rule

Office of Management and Budget/Office of Federal Procurement Policy

Update Reverse Auction Techniques for Online Procurement of Commercial Items

The Bottom Line

American small businesses pay $1.1 trillion per year to complying with federal regulations and that is far too much. The r3 initiative is a non-political SBA program that seeks to reduce this cost burden by working with federal agencies and small business owners to review and reform existing rules that are outdated and ineffective, but the SBA cannot do this without your participation. Help them help you. Visit and get involved today.