I am also not a lawyer, but my understanding is that the system is not clear in the way that you are describing it. As to "Anyway, Congress delegates authority

I am also not a lawyer, but my understanding is that the system is not clear in the way that you are describing it. As to "Anyway, Congress delegates authority to executive agencies so that it can focus on other things and not have to micro-mange each tiny detail of everything under the sun." - each tiny detail? This is a case of classifying millions of workers. We're not talking about a tiny detail, we're talking about something that is immensely important both to all the people affected by it as well as all the companies that have to operate under these labor laws. This isn't Congress delegating away the details, it's them failing for an extended period of time to address an absolute enormous and critical issue in the labor market.