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A PP END I X
MATERIAL SUBMITTED FOR THE HEARING
TESTIMONY BY JOHN MENDELOFF
AND HOUSING, JUNE 20, 1984
I am pleased to be asked to testify before the Subcommittee about
occupational safety and health information systems.
Much of my work has focused
on how better information could allow OSHA to make more intelligent regulatory
I have conducted evaluations of OSHA's effectiveness in preventing
injuries, worked on redesigning its inspection program to improve its cost
effectiveness, and recently have been examining the potential uses of the data
on OSHA', health inspections, which reside in the agency's computerized
Management Information System (MIS).
I have published Regulating Safetyi An
Esgnonis and Political Analysis of Occupational Safety and Health Policy and
several articles about the topics described above.
I have been supported in
this research by OSHA, NIOSH, the Department of Labor, the Office of Technology
Assessment, and the Federal Interagency Task Force on Workplace Safety and
I now teach at the University of California at San Diego.
I will divide my testimony into sections on safety and health.
will be on ideas that could provide more useful information.
The Bureau of Labor Statistics survey of occupational injuries and
illnesses was established to identify differences in injury rates among
thus the total recordable rate) are much less reliable because of employer
uncertainty about where the line between recordable cases and "first aid" cases
is to be drawn.
Unfortunately, the data from the survey have very limited value for
They provide almost no insight into causal factors in
accidents, in particular into the role of OSHA standards and OSHA enforcement.
As a partial remedy, BLS has been developing its "supplementary data system"
(SDS), essentially a compilation of somewhat upgraded and standardized data sets
from state workers' compensation programs.
These do include information about
the type of accident as well as some characteristics about the accident victims
and will prove useful for accident researchers.
Policymakers are often confronted by "information systems" that generate
massive amounts of data, but very little useful information.
In part, the
problem is that no one has thought through what questions were important to
answer and what data might help to answer them.
This is exacerbated because the
information policymakers need is extremely specific and detailed.
Let me give
When OSHA is considering the promulgation of new safety standards, it needs
to know very precisely what the likely effects of the required changes would be.
Again and again, hearings on these standards reveal that the needed information
is not available.
The BLS survey is no help.
State workers' compensation data
can provide some insight into the number of times a certain type of injury has
occurred--1.g., how many times forklift trucks have overturned and killed the
driver. However, OSHA needs to know whether all forklift trucks overturn or only smaller ones, at what speeds they overturned; and other similar facts. One strategy would be for OSHA to co-operate with one or two of the larger states
which have good workers' compensation data systems and piggyback an inter
disciplinary team on that system.
For example, suppose that OSHA knew the four
or five most likely standards that it would be addressing over the next few
years and some of the key factual issues that they would raise.
This team of
engineers and biostatisticians could be reviewing the relevant accident reports, and following up--either by phone or by site visits--to gather the detailed
information that would be needed to resolve those issues.
No state has the
financial incentive to conduct the proper level of research on its own.
are two more general insights raised by this example.
The first is that
improving existing data sources will often be more productive than setting up
entirely new ones.
In its standard on punch presses, OSHA tried to require
reports of all punch press accidents to federal OSHA.
Employers didn't comply
and the system collapsed, even while routine reporting of such accident to state
WC systems continued.
The second point is that federal agencies, including
OSHA, often have a view that the only data that is worth analyzing is national
data and they thus fail to invest in strategies that enrich the analysis of
The effectiveness of OSHA's safety program has been the subject of many
studies, whose conclusions range from those that found small effects to those
that found none.
For policymakers, even the former provided few insights
because they were designed to give "summative" evalutions--i.e., was there an
effect?--rather than "formative" evaluations--which would provide insights about
which programs worked better in different circumstances.
studies may generate more insights, especially if they can tie together the
particular violations that are cited in inspections and the specific types of
injuries that occur before and after inspections.
This will require linking
together, in at least one state, the inspection data in the MIS with the
accident data in the WC reporting system. However, an even more important
change is needed:
a willingness on OSHA's part to conduct true enforcement
experiments in which the evaluation design is considered before the program is
The few experimental programs that have been attempted were not
carried out in ways that would facilitate evaluation:
the number of sites were
too few and the length of time too short to draw clear conclusions. Sadly, as a result we have learned remarkably little about which programs will be most
effective in detecting and deterring violations, much less in preventing
One difficulty is that OSHA has very little information about the relation
between violations of standards and accidents.
One of the only sources for this
information comes from accident investigations, which include a review of what
role violations may have played. Currently, OSHA only conducts them in the case
of fatalities and accidents causing more than 4 hospitalizations. Even with these, it has conducted very little analysis. California has covered many more
hospitalizations in its investigations.
In a recent article (Journal of
Occupational Medicine, May 1984) I have shown that analysis of that data
illuminates issues such as the following:
which violations should be cited
as "serious"; 2)
in which industries and size classes of plants are violation
related serious injuries occurring; 3) which violations can be detected by
inspectors; and 4) for which types of serious accidents are current standards
This type of information can be used to inform standard-setting
and enforcement practices, and can be provided to employers and workers to help them focus on the most serious violations in their industries.
The BLS survey is generally conceded to have little value as an indicator
of the magnitude of the occupational illness problem.
Its central weakness
comes with diseases with long latency periods--e.g. cancer and obstructive lung
diseases--but even with more acute problems--e.g. lead poisoning--few believe
that it captures more than a fraction of the cases.
Especially for the long
latency diseases, what is needed is a measure of current exposurez. Ideally, we
would be able to track whether exposures were decreasing, in what types of plants they were highest, and whether they declined after inspections. In later