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Workers across the United States have a right to earn a living without risking their lives. Yet, in 2014, more than 4,800 American workers were killed on the job, and nearly 3 million suffered work-related injuries and illnesses. Previous research suggests that Occupational Safety and Health Administration (OSHA) inspections can reduce the risks workers face. However, for inspections to work as intended, OSHA needs employers to respond promptly when workplace inspections reveal unsafe conditions. When responding to an OSHA citation, employers must document how they have corrected hazards and pay any penalties levied against them. When employers do not respond, OSHA staff cannot confirm whether workers remain at risk. In addition, they must take a more costly step—referring the case to a national debt collection team—to prod employers to resolve their citations.

In 2014, the U.S. Department of Labor’s (DOL) Chief Evaluation Office (CEO) contracted with Mathematica Policy Research and ideas to explore the potential of using insights from behavioral science to improve the performance and outcomes of DOL programs. DOL was especially interested in testing behavioral interventions that would allow for rapid evaluation and analysis of short-term outcomes, and when appropriate, for testing further iterations based on initial results. The DOL Behavioral Interventions (DOL-BI) team partnered with OSHA to explore whether piloting a limited set of changes to the citation process could improve employers’ responsiveness to citations and reduce the number of cases referred to debt collection. From summer 2015 through spring 2016, researchers conducted a trial in two phases that examined the effect of introducing a handout at the conclusion of inspections, revising the citation cover letter, sending a follow-up postcard, and conducting a reminder telephone call.

As noted in the report, results from this randomized controlled trial indicated notable, statistically significant improvements: the pilot changes tested increased the proportion of employers who responded to citations by 3.9 percentage points in Phase 1 and 5.4 percentage points in Phase 2. In the second phase, they reduced the number of cases referred to debt collection by 4.4 percentage points, which translates into approximately 1,000 fewer cases referred to debt collection each year.

Research Questions

• Did changes to the citation process lead more employers to respond to—and ultimately resolve—their citations? Did the pilot changes cause more employers to enter into a settlement agreement (informal settlement agreement or expedited informal settlement agreement) with OSHA, make a payment, or formally contest their citations? Did they reduce the number of citations referred to debt collection or increase the number of citations resolved? Did they increase the number of employers who certified having corrected their violations?
• Did the impact of the changes vary across trial phases? The trial’s second phase eliminated the reminder telephone call, while the trial’s first phase included all four changes. Was there a significant difference in impacts between phases?
• Did the changes work better for certain types of employers, industries, or regions? Did they have a greater effect on small employers or on citations with smaller penalties? Did the effect vary by industry?
• What lessons might help guide similar efforts in other contexts? What challenges did local OSHA staff encounter when implementing changes to the citation process? What solutions did they devise to meet the challenges? How can lessons from the trial be applied when using behavioral science to help other programs, especially those charged with regulatory enforcement, pursue their missions?

Key Takeaways

• The changes tested caused more employers to respond to OSHA citations in both trial phases.
• The changes tested caused more employers to sign settlement agreements and pay penalties in both phases.
• The changes to the citation process reduced referrals to debt collection - and increased resolution of citations - but only during Phase 2.
• The changes did not cause more employers to certify that they had corrected their violations.
• The impact of the changes to the citation process on referrals to debt collection grew as time progressed.

Citation

Chojnacki, G., Deutsch, J., Amin, S., Perez-Johnson, I., Darling, M., Lefkowitz, J. (2017). Mathematica. Using Behavioral Interventions to Help Employers Resolve Occupational Safety and Health Administration (OSHA) Citations Technical 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.