Under the Administrative Procedure Act there must be 'an adequate statement of . . . findings and conclusions, and the reasons or basis therefor, on all the material issues of fact, law, or discretion presented on the record.' 5 U.S.C. § 557(c) (1988).
The purposes of the APA provision requiring specific findings and conclusions are to prevent arbitrary agency decisions, provide parties with a reasoned explanation for those decisions, settle the law for future cases, and furnish a basis for effective judicial review. 4 STEIN, MITCHELL & MEZINES, ADMINISTRATIVE LAW § 39.05 (June 1991). Third Circuit Court of Appeals precedent emphasizes the need for adequate findings to ensure effective judicial review and eliminate appellate speculation. See Wensel v. Director, Office of Workers' Compensation Programs, United States Dep't of Labor, 888 F.2d 14, 16 (3d Cir. 1989) (stating that the APA requires sufficient findings and reasoning to enable a reviewing court to understand how the ALJ reached the decision, particularly when the ALJ has rejected relevant evidence or there is conflicting probative evidence in the record); Bethlehem Steel Corp. v. Occupational Safety & Health Review Comm'n, 607 F.2d 1069, 1073-74 (3d Cir. 1979) (holding ...