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Assessing the Accuracy of OSHA's Projections of the Benefits of New Safety Standards « Health and safety « Topics « Downloads
|Date posted||April 1, 2010|
|Categories||Health and safety, Working paper, Mendeloff, John, Seong, Si Kyung|
For 6 safety standards issued since 1990, we compare OSHA’s projections of their impact on fatalities with actual fatality changes and explain the reasons for the differences. Accurate projection of impacts is important so that OSHA has a good understanding of both the uses and the limits of its actions.
We reviewed the preambles to OSHA standards and the Regulatory Impact Analyses prepared for them to identify the baseline and the prevention factor that OSHA used to project the number of deaths that would be prevented. We used 3 data sources to track the relevant categories of fatalities: the Census of Fatal Occupational Injuries (CFOI), the National Traumatic Occupational Fatality program, and OSHA’s Fatality/Catastrophe investigations.
In all 6 cases, OSHA appeared to overestimate the number of deaths prevented by the standards. The availability of CFOI led to better estimates of the fatality baseline, but the prevention factor was always overestimated, especially for standards which emphasized training. Part of the problem is that OSHA is required to assess economic and technological feasibility under the assumption of full compliance. It understandably brings the same assumption to projections of effects, despite the unreality of the assumption. We are not able to distinguish here between overestimates due to lack of compliance and overestimates due to the overstated effectiveness of the standard. There is some evidence that the projections were more accurate for standards that were more costly and subjected to more outside scrutiny. However, the low cost standards also tend to be the ones that rely primarily on training provisions; thus the role of the outside scrutiny is not clear.
OSHA needs to invest in developing better methods for projecting injury impacts. In some cases, like non-fatal injuries, new data collection efforts are needed. More generally, there is a need for research that will help OSHA understand the likely consequences of regulations requiring behavioral changes, e.g., on the effects of training.