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Assuring that all workers in the United States have safe and healthful working conditions is the mission of the U.S. Department of Labor’s (DOL) Occupational Safety and Health Administration (OSHA). The Site-Specific Targeting (SST) program, a planned inspection program managed by OSHA, aims to improve health and safety of workplaces under OSHA's jurisdiction by targeting enforcement actions on establishments with historically high injury and illness rates. The enforcement actions of the SST program include: (1) high-rate letters, which warn workplaces about their high injury-illness rates, and (2) inspections of worksites for compliance with safety and health regulations. In 2013, OSHA targeted 9,400 worksites nationwide using these enforcement actions.

To determine whether the SST program has an impact on improving regulatory compliance and workplace health and safety, the DOL’s Chief Evaluation Office (CEO) and OSHA contracted Summit Consulting LLC (Summit) to evaluate the program. This evaluation, started by IMPAQ International in 2010 and taken over by Summit in late 2013, assesses the impacts of SST on two main outcomes of interest: Regulatory Compliance, measured by the probability of OSHA citing a worksite for a violation during a follow-up inspection; and Health and Safety, measured by the follow-up injury/illness rate [i.e., the DART (days away, restricted, transferred) rate].

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.

As indicated in the report, researchers apply both a randomized controlled trial (RCT) design and a regression discontinuity design (RDD) to assess impacts. The original research design and analysis plan included only the RCT. Summit supplemented the experimental study with a quasi-experimental design to offset implementation and data limitations of the RCT and to capitalize on data OSHA had already collected.

Research Questions

• RCT
  • What are the impacts on regulatory compliance and health and safety outcomes of being on the SST high-rate-letter list compared to not being on either the SST high-rate letter list or the SST inspection list?
  • What are the impacts on regulatory compliance and health and safety outcomes of being on the SST high-rate-letter and SST inspection lists compared to not being on either list?
• RDD
  • What impact does being on the high-rate letter list have on injury/illness rates?
  • What impact does receiving a programmed inspection have on injury/illness rates? 2b. What impact does being on the SST inspection list have on injury/illness rates?

Key Takeaways

• Overall, neither the RCT nor the RDD study found statistically significant impacts.
• Promising results were found in a few of the treatment-outcome combinations. Namely, researchers estimated that inspections decreased post-treatment DART-rates for Primary worksites across all designs and subgroups, although none of these estimates were statistically significant. In other treatment-outcome combinations and subsets of the sample, researchers found the direction of the impacts to be sometimes negative as expected, and at other times positive, which was unexpected, but again, none were statistically significant.
• The lack of statistically significant impacts from the RCT and RDD studies does not mean that OSHA’s enforcement actions had no beneficial impact on workplace health and safety. The results of this study only imply that if the enforcement actions had any impact on worksites’ regulatory compliance and health and safety, that impact is unlikely to be larger than what the estimated confidence intervals indicate.

Citation

Peto, B., Hoesly, L., Cave, G., Kretch, D., Dieterle, E. (2016). Summit Consulting. Evaluation of the Occupational Safety and Health Administration’s Site-Specific Targeting Program: Final Report. 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.