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The report provides an overview of the Site Specific Targeting Program (SST11) and a random assignment evaluation design implemented by Occupational Safety and Health Administration (OSHA) to assess the short-term impacts of the program. Based on reviews of relevant program documentation and interviews with OSHA Federal and Area Office staff, the paper describes the implementation of the SST11 program, including: (1) the process used by the OSHA Federal Office to select establishments for SST11 participation; (2) the random assignment evaluation design implemented by the OSHA Federal Office to assess the program’s short-term impacts; and (3) the processes used by OSHA Area Offices to inspect SST11 establishments and issue citations to violators of OSHA standards.

The evaluation assesses the direct impact of receiving letters or inspections. It also assesses the indirect impact of being assigned by OSHA to these enforcement actions, which allows measuring potential deterrent effects that fear of inspections may have on regulatory compliance and health and safety. Researchers apply both a randomized controlled trial (RCT) design and a regression discontinuity design (RDD) to assess impacts.

Key Takeaways

• Overall, neither the RCT nor the RDD study found statistically significant impacts. Across the RDD and the RCT studies, high-rate letters did not decrease worksites DART (days away, restricted, transferred) rates by more than 1.5 case-rates (or 22% of the control group mean), and that inspections did not decrease DART rates by more than 2.9 case-rates (or 40%) in the three years following the treatment.
• Inspections decreased post-treatment DART-rates for Primary worksites across all designs and subgroups, although none of these estimates were statistically significant.

Research Gaps

• Finally, the paper presented the proposed impact analyses plan for Study A (The impact of a High Rate Letter sent to establishments that exceed an injury/illness rate threshold urging them to take corrective action) and Study B (The impact of a High Rate Letter plus Inspection). The impact analyses for Study A should rely on multivariate regression models that compare the SST12 violation outcomes and injury/illness rates for Treatment Group A and Control Group A establishments. These analyses will be conducted separately for primary list and secondary list establishments and will provide unbiased estimates of the impact of the high rate letter on violation outcomes and injury/illness rates. Similarly, the impact analyses for Study B should rely on multivariate regression models that compare the SST14 violation outcomes and injury/illness rates for Treatment Group B and Control Group B establishments. The analyses will be conducted separately for the primary list and secondary list establishments and will provide unbiased estimates of the impact of the high rate letter plus inspection on violation outcomes and injury/illness rates. (page iii)

Citation

Michaelides, M., Davis, S., Mbwana, K. (2014). IMPAQ International. The Evaluation of the Occupational Safety and Health Administration Site-Specific Targeting Program Implementation and Random Assignment Evaluation of the OSHA SST11 Program. Chief Evaluation Office, U.S. Department of Labor.

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The Department of Labor’s (DOL) Chief Evaluation Office (CEO) sponsors independent evaluations and research, primarily conducted by external, third-party contractors in accordance with the Department of Labor Evaluation Policy and CEO’s research development process.