at 949. East urges that, having found CPL 2.25B to be a procedural rule, we should nevertheless not give effect to the APA’s procedural rules exemption from informal rulemaking requirements because the rule has substantial impact on those regulated. We disagree. OSHA’s inspection plan casts not the stone of substantial impact. We add our voice to the court’s in Stoddard Lumber Co. v. Marshall, 627 F.2d 984 (9th Cir.1980), where the Ninth Circuit concluded that a previous version of the plan now before us did not merit notice and comment procedure. Id. at 987-88; see In re Trinity Industries, No. Misc.-J-83-131-12 (M.D.Fla.1984); In re Establishment of Chicago Aluminum Castings Co., 535 F.Supp. 392, 397 (N.D.Ill.1981); cf. Donovan v. Wollaston Alloys, Inc., 695 F.2d 1, 9 (1st Cir.1982) (<HOLDING>). CPL 2.25B has no cognizable impact,
holding that a plan provision stating that the summary plan description and summaries of material modifications  are hereby incorporated by reference and constitute a part of the plan acted to incorporate into the plan a limitations provision found only in the summary plan description holding that plan did not comply holding previous osha inspection plan did not have significant impact on substantive rights of employers within publication provision of 5 usc  552a1 1976 holding that plan administrator of an erisa health plan did not have to anticipate the confusion of a plan participant holding that employers have standing to sue