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Blog Author Angelique Sanders

Weekly safety news. Stay in touch with regulations from OSHA, NFPA, and other safety codes. Find out about other companies' best and worst practices. We scour the internet to provide you with helpful training resources and the latest safety information.


Thursday, February 28, 2013

GAO Report States: OSHA Is Not Able To Justify Pollicy Changes

This past week I've noticed a number of articles such as one in Fierce Government, a newsletter published to provide information to federal government managers, that are pointing out that OSHA may be heading in the wrong direction and has no way to measure and determine whether their policies are effective.  The Fierce Government article states:

"In a report published Feb. 25, GAO says that recent revisions of safety measures by OSHA focus on outputs, such as averages of penalties and of violations per inspection, but 'do not provide the type of outcome-oriented information needed to determine which enforcement activities are the most effective.'"

I like going to original source documents to check the information in articles, so I looked up the GAO report. which is titled, "Further Steps by OSHA Would Enhance Monitoring of Enforcement and Effectiveness."

The initial problem the GAO identified is that OSHA is not monitoring the state OSHA programs as closely as it monitors its own regional offices. The GAO report states:

"Questions have since been raised about how closely OSHA monitors its own enforcement efforts. GAO examined 1) how OSHA's monitoring of its own and state enforcement efforts compares, and 2) recent steps OSHA has taken to evaluate the effectiveness of federal and state enforcement efforts"

But, what the GAO found was a deeper, more significant problem. The GAO report points out that OSHA's methods for measuring effectiveness may not be actually measuring the effectiveness of OSHA.  This is because OSHA uses metrics such as the total number of inspections and the number of citations issued to measure OSHA effectiveness. In effect OSHA has established a new policy of increased enforcement, more citations, and greater fines. They then count the number of enforcement actions, the number of citations and the amount of the fines, note that they have gone up and declare the new policies a success.  That's circular reasoning.

The GAO has noticed this fallacy, noting that OSHA is simply measuring output. Instead, as the GAO states, they should be measuring outcomes. They should answering the question: is safety actually improving as a result of these policy changes?  OSHA is not doing that.

"OSHA is taking steps to better assess the effectiveness of both its federal enforcement efforts and of state enforcement efforts, but it is often not clear how these steps will help OSHA demonstrate what efforts result in better outcomes for workers, such as reduced worker injuries, illnesses, and fatalities. For example, OSHA recently revised some of the measures it uses to assess state run programs by adding acceptable ranges of performance. However, the revised measures still largely focus on outputs--such as the average number of violations per inspection--rather than outcomes."

The GAO reports notes states have noticed this problem, and have been reluctant to embrace recent OSHA programs such as increased penalties.

"For example, only two state-run programs raised their penalty amounts in fiscal year 2011 as recommended by OSHA; state-run program representatives stated that OSHA lacked evidence to show that higher penalties are more effective in deterring future employer violations."

The recommendation of the GAO report is that OSHA needs to make some changes, including looking at outcomes in addition to outputs:

"GAO recommends that OSHA standardize guidance for its audit practices, include outcomes in its assessments of its enforcement initiatives, better use data from its audits, and ensure national office participation in audits. OSHA generally agreed with the recommendations but expressed concern about overuse of outcomes to assess effectiveness. GAO continues to believe the recommendations are valid as discussed later in the report."

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posted by Steve Hudgik
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1 Comments:

Anonymous Cor Safety Program said...

Hi,
It is the high time that OSHA must realize its sole purpose of existence. It is not merely to increase the number of inspections or to have multiplied penalties instead it is to ensure a safe working environment for all industries irrespective of nature. Effectiveness of OSHA means lesser no. of penalties that sounds almost opposite to OSHA’s effectiveness policies.

9:59 PM  

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