Report to the Subcommittee on Labor, 

Health and Human Services, Education, 

and Related Agencies, Committee on 

Appropriations, U.S. Senate 

United States Government Accountability Office

GAO 

April 2006 WORKPLACE 

SAFETY AND 

HEALTH 

OSHA Could Improve 

Federal Agencies’ 

Safety Programs with 

a More Strategic 

Approach to Its 

Oversight 

GAO-06-379 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-06-379.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robert 

Robertson, (202) 512-9889 or 

robertsonr@gao.gov. 

Highlights of GAO-06-379, a report to the 

Subcommittee on Labor, Health and 

Human Services, Education, and Related 

Agencies, Committee on Appropriations, 

U.S. Senate 

April 2006

WORKPLACE SAFETY AND HEALTH

OSHA Could Improve Federal Agencies' 

Safety Programs with a More Strategic 

Approach to Its Oversight 

Based on a survey of 57 agencies, GAO found that most agencies reported 

having at least one activity for each of the six components generally 

associated with a sound safety program—(1) management commitment, 

(2) employee involvement, (3) education and training, (4) identification of 

hazards, (5) correction of hazards, and (6) medical management (which 

includes having a return-to-work program for injured employees). However, 

agencies faced implementation challenges that cut across the components in 

the areas of data management, accountability, and safety resources. The 

survey results indicated that many agencies do not have automated 

systems for tracking elements of their safety programs, such as training. 

In addition, several of the agencies did not demonstrate that their managers 

are held accountable for maintaining effective safety programs. Finally, 

many agency officials stated that, due to limited resources, they often must 

depend on safety officers with limited professional safety experience. 

Forest Service Smokejumpers Fighting a Blaze at Selway-Bitterroot Wilderness, Idaho 

Source: Buck Nelson.

OSHA’s oversight of federal agencies’ safety programs is not as effective as it 

could be because the agency does not use its enforcement and compliance 

assistance resources in a strategic manner. Although inspections are one of 

OSHA’s primary enforcement tools, it does not conduct many inspections of 

federal worksites or have a national strategy for targeting worksites with 

high injury and illness rates for inspection. Furthermore, although OSHA is 

responsible for tracking violations that agencies dispute and reporting any 

unresolved disputes to the President, OSHA does not track these disputed 

violations or their resolution. In addition, although OSHA is required to 

review agencies’ safety programs annually and submit a report on them to 

the President each year, as of January 2006, the last report submitted was for 

fiscal year 2000. Finally, while OSHA has a range of compliance assistance 

programs designed to help agencies comply with its regulations and improve 

safety, these programs are not being fully utilized. 

Federal workers’ compensation 

costs exceeded $1.5 billion in 

2004, with approximately 148,000 

new claims filed that year. 

Because of concerns for the 

safety of federal workers, as well 

as the costs associated with 

unsafe workplaces, GAO 

described the characteristics of 

federal agencies’ safety programs 

and the implementation 

challenges they face, and 

assessed how well the 

Occupational Safety and Health 

Administration (OSHA) oversees 

and assists federal agencies’ 

efforts to develop and administer 

their safety programs. 

What GAO Recommends

The Secretary of Labor should 

direct OSHA to conduct targeted 

inspections of federal facilities; 

track disputed violations through 

OSHA to their resolution and 

ensure that unresolved disputes are 

reported to the President; conduct 

evaluations of the largest and most 

hazardous agencies as required; 

and include in OSHA’s annual 

report to the President an 

assessment of each agency’s safety 

program and recommendations for 

improvements.

GAO received written and/or 

technical comments from several 

agencies. Labor generally agreed 

with GAO’s findings and 

recommendations. In addition, 

other agencies generally agreed 

with the findings. 
Page i GAO-06-379 Worker Safety 

Letter 1

Results in Brief 3 

Background 5 

Most Agencies Reported Having Many Safety Program 

Components, but Faced Common Implementation Challenges 18 

OSHA Provides Inadequate Oversight of Federal Agencies Because 

It Does Not Use Its Enforcement and Compliance Assistance 

Resources Strategically 25 

Conclusions 36 

Recommendations for Executive Action 37 

Agency Comments and Our Evaluation 38 

Appendix I Scope and Methodology 40 

Appendix II Comments from the Department of Labor 43 

Appendix III Comments from the Department of Homeland 

Security 48 

Appendix IV Comments from the Department of Interior 51 

Appendix V Data Collection Instrument Sent to the Federal 

Agencies 53 

Appendix VI Agencies’ Responses to the Data Collection 

Instrument 59 

Appendix VII GAO Contact and Staff Acknowledgments 61 

Contents 
Page ii GAO-06-379 Worker Safety 

Tables 

Table 1: Six Components of a Sound Safety Program and Their 

Supporting Activities 12 

Table 2: Top Five Types of Injuries Incurred by Federal Workers, 

Fiscal Years 1995 to 2004 16 

Table 3: Federal Agencies’ Strategic Partnerships with OSHA 35 

Table 4: Agency Responses to the Data Collection Instrument by 

Safety Program Component 59 

Figures 

Figure 1: Number of OSHA Inspections, Fiscal Years 2000 to 2004 7 

Figure 2: OSHA’s 10 Regions 8 

Figure 3: Number of Workers’ Compensation Claims of Federal 

Workers, Fiscal Years 1995 to 2004 15 

Figure 4: Percent of Workers’ Compensation Costs for Federal 

Workers by Age of the Case, Fiscal Years 1995 to 2004 17 

Figure 5: Workers’ Compensation Payments for Federal Workers 

by Type of Cost, Fiscal Years 1995 to 2004 18 

Figure 6: Percent of Inspections of Federal Worksites by Type, 

Fiscal Years 2000 to 2004 26 

Figure 7: Average Number of Serious Violations at Federal 

Worksites by Inspection Type, Fiscal Years 1995 to 2004 27 
Page iii GAO-06-379 Worker Safety 

Abbreviations 

OFAP Office of Federal Agency Programs 

OSHA Occupational Safety and Health Administration 

OWCP Office of Workers’ Compensation Programs 

OSH Act Occupational Safety and Health Act 

VPP Voluntary Protection Programs 

SHARE Safety Health and Return to Employment 

This is a work of the U.S. government and is not subject to copyright protection in the 

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reproduce this material separately. 
Page 1 GAO-06-379 Worker Safety 

April 21, 2006 

The Honorable Arlen Specter 

Chairman 

The Honorable Tom Harkin 

Ranking Minority Member 

Subcommittee on Labor, Health and Human Services, 

 Education, and Related Agencies 

Committee on Appropriations 

United States Senate 

In the early to mid 1990s, five Yellowstone National Park employees were 

killed in on-the-job accidents ranging from a snowmobiling accident to a 

drowning. By the time the last death occurred, the Occupational Safety 

and Health Administration (OSHA)—the Department of Labor agency 

responsible for overseeing federal agencies’ safety programs—decided to 

conduct a comprehensive inspection and identified over 500 violations at 

the park. OSHA also worked with park officials to improve safety. As a 

result, Yellowstone transformed its safety program and according to 

Yellowstone officials, OSHA has deemed it a success. However, this 

worksite represents only one of thousands of locations where federal 

employees work. During the past decade, the number of executive branch 

workers killed or injured in work-related accidents at federal worksites 

has fluctuated, although the number has decreased overall.1

 Over this 

period, over 800 workers died from work-related accidents, with 47 deaths 

occurring in 2004. Non-fatal work-related injuries declined over the first 

half of this period and increased over the subsequent 5-year period, with 

approximately 148,000 claims for injuries being filed in 2004. While the 

number of injuries fluctuated, the costs of the claims for these injuries— 

adjusting for inflation—remained constant for most of the decade and rose 

slightly in 2004 to $1.5 billion. In view of these injuries and their affiliated 

costs, you asked us to answer the following questions: (1) What are the 

components of federal agencies’ safety programs and what 

implementation challenges do they face? (2) How well does OSHA oversee 

and assist federal agencies’ efforts to develop and administer their safety 

programs? 

 1

In this report, we use the term “injuries” to refer to workers’ injuries and illnesses. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-06-379 Worker Safety 

To respond to your request, we focused on the executive branch because 

OSHA has more oversight responsibilities with respect to these agencies 

than it does for judicial and legislative branch agencies.2

 We obtained 

information using a data collection instrument from 57 safety managers for 

agencies in the eight largest executive branch departments, which 

represent about 80 percent of the federal workforce.3

 The instrument 

requested information and documentation on six components of sound 

safety programs we identified from previous GAO work: (1) management 

commitment, (2) employee involvement, (3) education and training, (4) 

identification of hazards, (5) following up and correcting hazards, and (6) 

medical management.4

 We reviewed the information in the data collection 

instrument and documentation that the agencies provided, assessing 

whether the documentation supported the agency’s responses and 

identifying the types of activities the agency conducted for each program 

component. In addition, we conducted more detailed follow-up interviews 

with safety officials from 12 of the 57 agencies surveyed. We also 

interviewed employee representatives from 8 agencies and visited 5 

federal worksites, most of which were identified by OSHA as having strong 

safety programs. In addition, we obtained information on workers’ 

compensation claims from the Department of Labor’s Office of Workers’ 

Compensation Programs (OWCP). We also interviewed all 10 of OSHA’s 

regional administrators and federal agency program officers and officials 

 2

The Occupational Safety and Health Act requires all federal agencies, including those in 

the executive, judicial, and legislative branches, to develop and maintain safety programs. 

However, while Executive Order 12196 and OSHA’s regulations provide that OSHA plays a 

key oversight role with respect to executive branch agencies, its role is more limited for 

judicial and legislative branch agencies. Specifically, the executive order indicates that 

OSHA’s role with respect to judicial and legislative branch agencies is to cooperate and 

consult with them to aid them in adopting their safety and health programs. Judicial and 

legislative branch agencies are not subject to OSHA’s regulations unless they have entered 

into an agreement to that effect with OSHA. For the purpose of this work we did not 

include contract employees on federal worksites. Contract employees are not covered by 

federal agency safety programs, but are instead covered by private-sector procedures 

under the act. 

3

The eight largest departments are the Departments of Defense, Veterans Affairs, Homeland 

Security, Treasury, Agriculture, Justice, Interior, and the Social Security Administration. 

We excluded the U.S. Postal Service because, under the Occupational Safety and Health 

Act, it is considered a private-sector employer. For this report, “agency” refers to a division 

within these federal departments. For example, the agencies we reviewed in the U.S. 

Department of the Treasury include the Internal Revenue Service, the Bureau of Engraving 

and Printing, and the U.S. Mint. 

4

For this report, we use the term “safety program” to mean an agency’s occupational safety 

and health program. 
Page 3 GAO-06-379 Worker Safety 

in 10 area offices including the area director, a compliance safety and 

health officer, and, in many cases, a compliance assistance specialist. In 

addition, we examined OSHA’s inspection data from fiscal year 1995 to 

2004 and reviewed, when available, the annual reports that the eight 

largest federal departments provided to OSHA from 2000 to 2004. Finally, 

we reviewed the reports on federal safety programs that OSHA provided to 

the President during this time frame. For a more detailed explanation of 

our methodology, see appendix I. We conducted our work between 

November 2004 and February 2006 in accordance with generally accepted 

government auditing standards. 

Most agencies reported having at least one activity for each of the six 

safety program components. However, we identified common 

implementation challenges that cut across the components in the areas of 

data management, accountability, and safety resources. Of the 57 agencies 

surveyed, 54 reported that their safety programs contain at least one 

activity for each of the six safety program components. Agencies reported 

the fewest activities for the medical management component. For 

example, 12 agencies reported they do not have a program to offer injured 

employees light or restricted duty to help them return to work more 

quickly. Moreover, our analysis of the survey data and interviews with 

agency officials revealed a number of challenges agencies face in 

implementing their safety programs. The survey results indicated that 

many agencies do not have automated systems for tracking elements of 

their safety programs, such as training, and agency officials told us that 

some of their systems are difficult to use. In addition, many agencies did 

not demonstrate that their managers are held accountable for maintaining 

effective safety programs. For example, only 16 agencies (28 percent) 

were able to provide copies of their performance appraisal review forms 

citing safety as a rating element—the remaining agencies provided only 

their policies or other written documentation. Agencies we interviewed 

also reported difficulties in managing resources for their safety programs 

because many do not have a line item for safety in their budgets or face 

production goals that compete with safety priorities. In addition, many 

agencies told us that, due to limited resources, they often must depend on 

safety officers with limited technical or professional safety experience. 

OSHA’s oversight of federal agencies’ safety programs is not as effective as 

it could be because the agency does not use its enforcement and 

compliance assistance resources in a strategic manner. One of OSHA’s 

primary enforcement tools is conducting inspections of federal worksites. 

However, the agency does not conduct many inspections of federal 

Results in Brief 
Page 4 GAO-06-379 Worker Safety 

worksites or have a national strategy for targeting worksites with high 

injury and illness rates for inspection. Instead, OSHA conducts inspections 

of federal worksites mainly in response to complaints from employees. In 

addition, although OSHA is responsible for tracking violations that 

agencies dispute and reporting any unresolved disputes to the President, it 

does not track these disputed violations or their resolution, and OSHA 

regional officials said they can sometimes remain unresolved for years. 

Evaluations, another enforcement tool OSHA has available, entail 

reviewing agencies’ safety policies and programs and assessing the overall 

effectiveness of their safety programs. However, while OSHA is required to 

evaluate certain federal agencies annually, it has not done any evaluations 

in the last 6 years. Moreover, although OSHA is required to review federal 

agencies’ safety programs and submit a report on their programs to the 

President each year, the last report OSHA submitted was for fiscal year 

2000. Finally, although OSHA has a range of compliance assistance 

programs designed to help agencies comply with its regulations and 

improve safety, not all of these programs are being fully utilized. OSHA 

officials acknowledged these problems with their enforcement and 

compliance assistance strategies but noted that they have relatively few 

staff dedicated to federal agency oversight. 

In order to improve OSHA’s oversight of federal agencies’ safety programs, 

we are recommending that the Secretary of Labor direct the Assistant 

Secretary for Occupational Safety and Health to (1) conduct targeted 

inspections of federal worksites; (2) track violations disputed by federal 

agencies and ensure that unresolved violations are reported to the 

President; (3) conduct evaluations of federal agencies as required; and (4) 

include in OSHA’s annual report to the President an assessment of each 

agency’s safety program and recommendations for improvements. In 

responding to a draft of this report, the Department of Labor generally 

agreed with our findings and recommendations. We also received written 

comments from the Departments of Homeland Security and Interior. 

These agencies generally agreed with our findings and conclusions. Copies 

of written comments from these agencies are provided in appendixes II, 

III, and IV. In addition, we received technical clarifications from the 

Departments of Defense, Justice, and Veterans Affairs, which we 

incorporated as appropriate. 
Page 5 GAO-06-379 Worker Safety 

Congress passed the Occupational Safety and Health (OSH) Act in 1970 to 

ensure safe and healthful working conditions for working men and 

women, including federal employees.5

 While OSHA was created to 

administer the OSH Act, the act also gave federal agencies primary 

responsibility for providing federal employees with working conditions 

and workplaces that are free from safety and health hazards.6

 The act 

authorizes OSHA to set mandatory occupational safety and health 

standards, rules, and regulations and to enforce their compliance. In turn, 

each federal agency is required to establish and maintain a comprehensive 

and effective occupational safety and health program that is consistent 

with OSHA’s standards.7

OSHA’s Office of Federal Agency Programs within its Directorate of 

Enforcement Programs has primary responsibility for overseeing federal 

agencies’ safety programs. OSHA’s regulations and an Executive Order 

establish its responsibilities for monitoring federal agencies’ programs.8

OSHA uses two strategies to provide oversight of federal agencies’ safety 

programs—enforcement and compliance assistance. OSHA’s enforcement 

strategy includes inspections and evaluations of federal worksites that 

help ensure that federal agencies are not violating any OSHA standards 

and are complying with the requirements for their safety programs.9

 In 

 5

29 U.S.C. §§ 651–678. 

6

29 U.S.C. § 668. 

7

Executive Order 12196, issued on February 26, 1980, prescribes executive branch agencies’ 

and OSHA’s responsibilities. 29 C.F.R. Part 1960 contains OSHA’s regulations for federal 

agency programs. 

8

Executive Order 12196 and OSHA’s regulations apply to federal executive departments. 

Military personnel and uniquely military activities of executive agencies are not included. 

9

OSHA is generally authorized to conduct announced or unannounced inspections of 

federal agencies that have not established OSH committees that conform to the regulatory 

requirements. OSHA’s inspection authority is somewhat more limited if an agency has 

established an OSH committee. Currently, only six departments have such committees: the 

Central Intelligence Agency, Securities and Exchange Commission, General Services 

Administration, Department of Labor, Tennessee Valley Authority, and U.S. International 

Trade Commission. None of the departments we reviewed had such committees. For those 

agencies with established OSH committees, OSHA may only conduct an inspection if (1) 

half the membership of record of the federal agency’s OSH committee requests an OSHA 

inspection; or (2) an employee reports an imminent danger to the agency’s OSH committee, 

but OSHA determines that neither the committee nor the agency has adequately responded 

to the employee’s complaint. 29 C.F.R. §1960.31. 

Background 

OSHA’s Role 
Page 6 GAO-06-379 Worker Safety 

addition, agencies are required to submit annual reports to OSHA on their 

safety programs, which OSHA uses to prepare an annual report to the 

President on federal agencies’ safety programs. OSHA’s compliance 

assistance strategy consists of a range of programs intended to help 

agencies improve their safety programs. 

OSHA is authorized to conduct inspections of federal agency worksites 

but, as figure 1 illustrates, inspections of federal worksites represent a 

very small percentage of OSHA’s overall inspections. 10

 10 OSHA has enforcement responsibility for all federal worksites in all states, but has 

granted authority to about half of the states for their own enforcement of private-sector 

and non-federal, public-sector worksites. At present, 22 states and territories, including 

Puerto Rico, have been approved by OSHA to operate their own programs; 4 states and 

territories, including the Virgin Islands, are approved for covering non-federal, public 

sector employee worksites only. OSHA directly oversees enforcement for all worksites in 

the remaining states. The number of inspections shown includes those conducted by the 

states and territories. 

Enforcement 
Page 7 GAO-06-379 Worker Safety 

Figure 1: Number of OSHA Inspections, Fiscal Years 2000 to 2004 

Between fiscal years 2000 and 2004, less than 1 percent of OSHA’s 

inspections were of federal worksites in executive branch agencies; the 

remaining 99.5 percent were primarily of private-sector worksites. Federal 

executive branch workers represented about 1.4 percent of the overall 

U.S. workforce between 2002 and 2004. 

Inspections are conducted by OSHA’s 80 area offices in its 10 regions. 

Figure 2 shows the location of OSHA’s 10 regions. 

Number of inspections

Fiscal year

Federal worksites

Non-federal worksites

Source: GAO analysis of OSHA data.

0

2,000

4,000

6,000

8,000

10,000

2000 2001 2002 2003 2004

90,000

92,000

94,000

96,000

98,000

100,000
Page 8 GAO-06-379 Worker Safety 

Figure 2: OSHA’s 10 Regions 

OSHA categorizes inspections as those that are “programmed” and those 

that are “unprogrammed.” Programmed inspections are those that OSHA 

plans to conduct because it has targeted certain worksites for inspection 

due to their potential hazards. Unprogrammed inspections are not 

planned; they are prompted by actions such as complaints, accidents, and 

referrals. OSHA has established a system of inspection priorities that 

relate to these categories, with unprogrammed inspections being a higher 

priority than programmed inspections. Top priority goes to imminent 

danger situations in which death or serious physical harm could occur. 

Source: OSHA.

Alaska

Hawaii

Pa.

Ore.

Nev.

Idaho

Mont.

Wyo.

Utah

Ariz.

N.Mex.

Colo.

N.Dak.

S.Dak.

Nebr.

Tex.

Kans.

Okla.

Minn.

Iowa

Mo.

Ark.

La.

Ill.

Miss.

Ind.

Ky.

Tenn. 

Ala.

Fla.

Ga.

S.C.

N.C.

Va.

Ohio

N.H.

Mass.

R.I.

Conn.

Del.

Md.

D.C.

N.J.

Mich.

Calif.

Wash.

Wis.

N.Y.

Maine

Vt.

W.Va.

American Samoa

Guam

U.S. Virgin

Islands

Puerto

Rico
Page 9 GAO-06-379 Worker Safety 

The next priority for OSHA inspectors is catastrophes and fatal accidents, 

followed by complaints and referrals. Programmed inspections are OSHA’s 

fourth priority. OSHA’s last priority is to perform follow-up inspections, 

which are conducted to ensure that hazards identified during previous 

inspections have been corrected. From fiscal years 2000 through 2004, 

only 40 percent of OSHA’s inspections of federal worksites were 

programmed. During the same period, 54 percent of its inspections of nonfederal worksites were programmed. 

OSHA is required to conduct comprehensive annual evaluations of the 

larger or more hazardous federal agencies.11 Results of these evaluations 

are summarized by OSHA in reports that include information from the 

review of an agency’s safety policies and reports, as well as inspections of 

the agency’s facilities and interviews with agency personnel. 

In addition, OSHA is required to submit to the President an annual report 

on the status of federal employees’ occupational safety and health.12 OSHA 

uses reports submitted annually by federal agencies to OSHA on their 

safety programs—along with the results of any evaluations it has 

conducted of federal agencies’ safety programs—to prepare its annual 

report to the President. The report should also contain recommendations 

for improving agencies’ performance. 

OSHA’s compliance assistance strategy consists of several programs 

available to federal agencies, although some programs have only recently 

been offered to federal employers. OSHA also provides technical support 

to federal agencies, such as conducting studies of accidents and the causes 

of injuries and illnesses, and providing training of agencies’ safety and 

health personnel. Two of OSHA’s compliance assistance programs—Field 

Federal Safety and Health Councils and Agency Technical Assistance 

Requests—specifically target federal agencies, while others are generally 

available to both private- and public-sector employers. Compliance 

assistance programs for private and public sector employers include the 

Voluntary Protection Programs (VPP), alliances, and strategic 

 11Executive Order 12196, §1-401(h). 

1229 C.F.R. §1960.71(b). 

Compliance Assistance 
Page 10 GAO-06-379 Worker Safety 

partnerships.13 Approval as a VPP site is OSHA’s official recognition of 

worksites that have implemented exemplary safety and health programs.14

The VPP was started in 1982 for private-sector companies but was 

expanded to include federal agencies in 1997. The alliance program was 

started in 2002 and includes organizations that have agreements with 

OSHA to focus on training, outreach, and promoting awareness of safety 

and health issues. The strategic partnership program was started in 1998 

and consists of agreements between OSHA and employers to address 

specific safety and health problems. 

OSHA also has been responsible for helping implement Presidential 

initiatives, with the most recent initiative being issued in 2004: the Safety 

and Health and Return to Employment (SHARE) initiative. This initiative 

directs agencies to set and adhere to both safety and workers’ 

compensation goals. Specifically, the initiative directs federal agencies to 

achieve four goals: (1) reduce the overall case rate for these claims, (2) 

reduce the lost-time rate—the number of employees who could not return 

to work per 100 employees in the workforce, (3) improve the processing 

time of workers’ compensation claims, and (4) reduce the lost production 

day rate—the lost days due to injury or illness per 100 employees. OSHA 

works with agencies in addressing the first two goals and helps them 

calculate the rates monitored. 

OSHA’s regulations establish the basic elements of executive agencies’ 

safety and health programs. According to the regulations, agencies’ 

programs must include provisions for 

• top management support, participation, and accountability; 

• safety and health policies, procedures, and standards; 

• goals and objectives; 

• worker involvement; 

 13OSHA’s compliance assistance programs use a mix of different methods designed to 

improve worker safety. They target both exemplary worksites and hazardous ones, and 

influence employers directly by implementing safety and health programs and indirectly 

through collaboration with trade and professional associations. For more information on 

these programs, see GAO, Workplace Safety and Health: OSHA’s Voluntary Compliance 

Strategies Show Promising Results, but Should Be Fully Evaluated before They Are 

Expanded, GAO-04-378 (Washington, D.C.: Mar. 19, 2004). 

14VPP sets performance-based criteria for a managed safety and health system, invites sites 

to apply, and then assesses applicants against these criteria. OSHA’s verification process 

includes an application review and rigorous onsite evaluations by a team of safety and 

health experts. 

Role of the Federal Agencies 
Page 11 GAO-06-379 Worker Safety 

• safety and health training of managers and workers; 

• collection of occupational injury and illness data; 

• self-inspection of workplaces and self-evaluation of the programs; 

• abatement of unsafe and unhealthful working conditions; and 

• adequate budgets, staff, and equipment and materials. 

In conducting self-inspections, agencies must meet certain requirements. 

Inspectors are required to be qualified to recognize and evaluate hazards 

and suggest corrections, and they must conduct inspections of every 

worksite at least once a year. According to the regulations, agencies 

should conduct “sufficient” unannounced inspections and unannounced 

follow-up inspections to ensure the identification and correction of 

hazardous conditions. 

Agencies must also report annually to OSHA on their programs. In 

November 2004, OSHA issued a final rule amending the injury 

recordkeeping and reporting requirements applicable to federal agencies.15

Prior to this time, federal agencies were required to collect only injury 

information related to workers’ compensation claims. OSHA revised the 

recordkeeping requirements in order to improve the quality of the federal 

recordkeeping system and to increase the utility of the data.16 Beginning in 

January 2005, federal agencies were required to record injuries in the same 

manner as private-sector employers and to apply new criteria to determine 

whether an injury must be recorded. Specifically, a work-related injury 

must be reported if, for example, it results in death, 1 or more days away 

from work, restricted work, loss of consciousness, or a significant injury 

or illness diagnosed by a physician.17 The regulations do not require that 

this data be reported to OSHA. However, the regulations state that agency 

heads must submit an annual report to OSHA, containing such information 

as OSHA requests.18 At a minimum, these reports are to describe the 

agency’s safety program and include, among other things, the agency’s 

required self-evaluation findings. OSHA uses these reports, along with any 

evaluations it has conducted to prepare its annual report to the President. 

 1569 Fed. Reg. 68793, codified at 29 C.F.R. §§1960.66-1960.71. 

1669 Fed. Reg. 68796. 

17In addition, unlike prior requirements, agencies must record the annual average number 

of employees employed as well as the total hours worked by all employees. This 

information is needed to calculate injury and illness rates. 

18 29 C.F.R. §1960.71(a). The regulations also provide that the Secretary of Labor must 

provide the agencies with the guidelines and format for the reports. 
Page 12 GAO-06-379 Worker Safety 

Safety experts and federal safety agencies agree that, to build an effective 

safety program, organizations must take a strategic approach to managing 

workplace safety and health. This objective is generally accomplished by 

establishing programs built upon a set of commonly recognized 

components of sound safety programs, which, together, help an 

organization lay out what it is trying to achieve, assess progress, and 

ensure that safety policies and procedures are appropriate and effective. 

Drawing from our prior work, a review of the literature, and OSHA’s 

requirements, we identified six components often found in sound safety 

programs: (1) management commitment, (2) employee involvement, (3) 

education and training, (4) identification of hazards, (5) following up and 

correcting hazards, and (6) medical management.19 Table 1 lists these 

components, along with a description of their supporting activities. 

Table 1: Six Components of a Sound Safety Program and Their Supporting Activities 

Componenta Supporting activities 

Management commitment • Establish goals for the program. 

• Develop activities to communicate the importance of the safety program to staff, 

including management, employees, and contractors. 

• Use management and information systems that allow for trend analysis, risk analysis, 

etc. 

• Establish program responsibilities of managers and employees for safety and health 

in the workplace and hold them accountable for carrying out those responsibilities. 

Employee involvement • Establish procedures for employees to report job-related fatalities, injuries, illnesses, 

incidents, and damage to property or equipment. 

• Establish procedures for employees to report hazards. 

• Provide employee access to the system that captures information on accidents and 

hazards. 

• Ensure employee involvement in safety committees that report on hazards. 

• Allow employees to provide input on safety-related training curricula. 

• Ensure employees participate in walkthroughs of worksites to identify hazardous 

conditions on a daily, weekly, or monthly basis. 

• Allow employee involvement on accident investigation teams. 

 19See GAO, Architect of the Capitol: Management and Accountability Framework Needed 

for Organizational Transformation, GAO-03-231 (Washington, D.C.: Jan. 2003) and 

Private Sector Ergonomics Programs Yield Positive Results, GAO/HEHS-97-163 

(Washington, D.C.: Aug. 27, 1997). 

Six Components of a 

Sound Safety Program 
Page 13 GAO-06-379 Worker Safety 

Componenta Supporting activities 

Education and training • Provide general awareness training to all employees so that they can recognize 

hazards and risks; learn procedures for reporting job-related fatalities, injuries, 

illnesses, incidents, and hazards; and become familiar with the program (nationallevel training). 

• Provide targeted training to specified groups of employees because of the jobs they 

hold, the hazards they face, or their role in the program (agency-level training). 

• Maintain an automated system to track training completed by employees. 

Identification of hazards • Establish procedures for conducting required OSHA inspections. 

• Establish procedures for conducting informal walkthroughs of worksites to identify 

hazardous conditions. 

Following up and correcting hazards • Establish procedures for developing controls for workplace hazards. 

• Establish procedures for following up on inspections to ensure hazards are corrected 

and controls are effective. 

• Maintain an automated system that tracks workplace hazards. 

Medical managementb • Establish procedures to ensure that an injured or ill employee is seen within a 

specified time frame by a medical provider. 

• Maintain an automated system that tracks accident data—including the type, nature, 

and source of injury. 

• Implement a restricted or light duty return-to-work program. 

• Maintain an automated system that tracks the return-to-work status of employees. 

Source: GAO and OSHA. 

a

Different terminology is often used to describe these components. For example, “identification of 

problem jobs” is sometimes referred to as “hazard identification and assessment” and “analysis and 

development of controls for problem jobs” is sometimes referred to as “hazard prevention and 

control.” 

b

Organizations may have a medical management program without necessarily having a safety and 

health program. 

Over the last 10 years, the federal executive branch workforce has 

changed in a number of ways, including its size, demographic 

characteristics, experience levels, and types of occupations. During this 

time, there was a 6 percent decrease in the federal workforce—from 2 

million employees in fiscal year 1995 to 1.9 million in fiscal year 2004. In 

addition, the average age of federal workers increased from 44 to 47 years 

old and the average length of time in service increased slightly, from 16 to 

17 years. Likewise, the average pay grade level of federal workers 

increased from approximately GS-9 to about GS-10. Moreover, the 

percentage of workers in professional and administrative positions 

increased from 85 to 89 percent. 

Federal employees encompass a wide range of professions, ranging from 

low-risk occupations such as office workers to highly hazardous 

occupations such as law enforcement positions. For example, at the U.S. 

Federal Workplace Trends 
Page 14 GAO-06-379 Worker Safety 

Marshals Service, duties of criminal investigators include seizing assets 

and apprehending fugitives. In addition, U.S. Forest Service employees are 

involved in a variety of potentially hazardous activities such as developing 

laboratory products, managing recreational lands, and fighting wildland 

fires, while inspectors with the Food Safety Inspection Service face daily 

hazards such as exposure to the chemicals used to kill pathogens in meat. 

Finally, employees at manufacturing operations such as at the U.S. Mint 

and the Bureau of Engraving and Printing use industrial production 

equipment such as forklifts and presses. 

The impact of demographic changes in the makeup of the federal 

workforce on the number of injuries they sustain is unclear. The number 

of active workers’ compensation claims for work-related injuries declined 

from approximately 154,000 claims in fiscal year 1995 to about 137,000 

claims in fiscal year 1999. 20 However, these claims increased from 

approximately 138,000 claims in fiscal year 2000 to about 148,000 claims in 

2004, as shown in figure 3. 

 20For this report, we define “active workers’ compensation claims” as claims made by 

federal employees who sustained compensable work-related injuries or illnesses. Workers’ 

compensation benefits provided to covered employees can include payment for medical 

treatment, rehabilitation services, death benefits, and replacement of lost wages. 

Injury and Illness Trends in 

the Federal Government 
Page 15 GAO-06-379 Worker Safety 

Figure 3: Number of Workers’ Compensation Claims of Federal Workers, Fiscal 

Years 1995 to 2004 

Although the severity of the injuries changed during this period, the types 

of injuries that federal workers incurred remained the same. Despite the 

fact that the number of traumatic injury claims decreased slightly—from 

76,633 claims in fiscal year 1995 to 74,322 claims in fiscal year 2004, as a 

proportion of total claims, traumatic injury claims increased slightly over 

this same period. However, non-traumatic injury claims decreased by over 

30 percent during this period—from 8,508 claims in fiscal year 1995 to 

5,903 claims in 2004. In addition, the top five types of traumatic injuries 

incurred by federal workers during this period ranged from sprains and 

strains of ligaments, muscles, or tendons to lacerations. Over this same 

period, the five most common types of non-traumatic injuries ranged from 

hearing loss to back sprain or strain. See table 2 for a list of the five most 

common types of traumatic and non-traumatic injuries federal workers 

incurred from fiscal year 1995 to 2004. 

0

25,000

50,000

75,000

100,000

125,000

150,000

175,000

Number of claims

Source: GAO analysis of OWCP data.

Fiscal year

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
Page 16 GAO-06-379 Worker Safety 

Table 2: Top Five Types of Injuries Incurred by Federal Workers, Fiscal Years 1995 

to 2004 

Traumatic injuries Non-traumatic injuries 

1. Sprain/strain—not back 1. Hearing loss 

2.Traumatic injury—unclassified 2. Carpal tunnel syndrome 

3. Back sprain or strain 3. Musculoskeletal condition, other 

4. Contusion 4. Conditions of tendons, etc. 

5. Laceration 5. Back sprain or strain 

Source: GAO analysis of OWCP data. 

While the size of the workforce declined, workers’ compensation costs for 

federal employees remained fairly constant during the most recent 10-year 

period, from about $1.54 billion in fiscal year 1995 to about $1.52 billion in 

2004.21 In addition, the compensation per claim filed during this period 

increased. For example, while there were about 1,800 fewer new claims in 

fiscal year 2004 than there were in fiscal year 1995, the average 

compensation per claim increased by 3 percent from fiscal year 1995 to 

2004, with the average payment per claim rising from $9,958 in 1995 to 

$10,242 in 2004. As shown in figure 4, the largest amount of workers’ 

compensation costs for federal workers paid from fiscal years 1995 to 2004 

was for claims that were over 5 years old. 

 21Amounts shown have been adjusted for inflation, with a base year of 2005. 
Page 17 GAO-06-379 Worker Safety 

Figure 4: Percent of Workers’ Compensation Costs for Federal Workers by Age of 

the Case, Fiscal Years 1995 to 2004 

Finally, the proportion of payments for lost wages, death benefits, medical 

costs, and rehabilitation have remained constant, with wage loss 

compensation being the largest proportion (approximately 70 percent) of 

workers’ compensation payments made from fiscal years 1995 to 2004. 

(See fig. 5.) 

0

10

20

30

40

50

60

70

80

90

100

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Percentage

Fiscal year

Over 5 years

1 to 5 years

0 to 1 year

Source: GAO analysis of OWCP data.

64 66 68 68 69 68 67 66 66 65

23 21 20 20 20 19 19 21 20 21

13 13 12 12 12 13 14 14 14 15
Page 18 GAO-06-379 Worker Safety 

Figure 5: Workers’ Compensation Payments for Federal Workers by Type of Cost, 

Fiscal Years 1995 to 2004 

Information reported by the 57 federal agencies illustrated various ways in 

which agencies carry out activities within the six safety program 

components—management commitment, employee involvement, training, 

identification of hazards, correction of hazards, and medical management. 

However, agency officials we surveyed and interviewed reported they face 

a number of implementation challenges that cut across the components, 

particularly in using automated systems, holding managers accountable 

for maintaining an effective safety program, and making the best use of 

their limited resources. Officials at these agencies also described measures 

they have taken to overcome each of these challenges. 

All of the 57 agencies surveyed reported that their safety programs 

incorporate activities for the management commitment component. 

Activities supporting management commitment include setting goals for 

the program and communicating from upper management to frontline staff 

Most Agencies 

Reported Having 

Many Safety Program 

Components, but 

Faced Common 

Implementation 

Challenges 

Most Agencies Reported 

Having at Least One 

Activity for Each Safety 

Program Component 

0

150,000,000

300,000,000

450,000,000

600,000,000

750,000,000

900,000,000

1,050,000,000

1,200,000,000

1,350,000,000

1,500,000,000

1,650,000,000

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Dollars

Fiscal year

Death benefits

Medical and rehabilitation benefits

Wage loss compensation

Source: GAO analysis of OWCP data.
Page 19 GAO-06-379 Worker Safety 

about the importance of the safety program. Fifty-five of the agencies 

surveyed (96 percent) reported that they had established goals for their 

safety and health programs, and all 57 agencies reported conducting 

activities to communicate the importance of their safety programs to 

employees, such as through newsletters and Web sites. 

Almost all of the agencies we surveyed reported that they conduct 

activities for two other components—employee involvement and training. 

Most agencies reported having policies governing employees’ participation 

in safety committees and reporting injuries and hazards. While 56 (98 

percent) of the agencies provided procedures for employees to report 

hazards, half of these procedures did not specify the right of employees to 

report hazards anonymously, as required by an executive order.22

Consistent with OSHA regulations, 56 of the 57 agencies reported that they 

offer some type of safety training for their employees.23

While many agencies identified a number of methods for identifying 

hazards, fewer had comprehensive procedures for tracking whether 

hazards are corrected—two additional components of safety programs. 

Fifty-five (96 percent) of the agencies reported that they conduct OSHArequired inspections, which must be performed at least once a year, in 

order to identify worksite hazards. However, although an executive order 

requires employee representatives to participate in these inspections, 

seven agencies (12 percent) reported not having any procedures for 

informing employees of their role during safety inspections.24 Furthermore, 

while most agencies reported having some procedures for following up on 

inspections and ensuring that hazards are corrected, we found that the 

procedures are not always adequate because a third of these agencies did 

not specify a reasonable timeframe for correction, as required by OSHA.25

Agencies reported having the fewest activities for the medical 

management component. Eight agencies (14 percent) reported that they 

 22Executive Order 12196, §1-201(h). 

23OSHA regulations require agencies to provide appropriate safety and health training that 

must, among other things, inform employees of the agency’s safety program and their rights 

and responsibilities under the program. 29 C.F.R. §1960.59. 

24Executive Order 12196, § 1-201(i). 

25OSHA regulations require agencies to promptly rectify unsafe and unhealthful conditions, 

and agencies are required to comply with this regulation by documenting the seriousness of 

identified hazards and providing a reasonable time for correcting them. 29 C.F.R §1960.26. 
Page 20 GAO-06-379 Worker Safety 

do not have any procedures designed to ensure that an injured employee is 

seen promptly by a physician. In addition, 12 agencies (21 percent) 

reported they do not have programs for offering injured employees light or 

restricted duty to help them return to work more quickly. Another 11 

agencies reported having such programs but did not provide sufficient 

documentation of them. For example, two agencies reported having 

return-to-work programs, but the documentation they provided showed 

that the programs had not yet been implemented. Although federal 

agencies are not legally required to include these activities in their safety 

programs, the failure to include them may limit the effectiveness of the 

programs. 

We found that agencies face some common challenges in implementing 

their safety programs, particularly in using automated systems to manage 

their programs, holding managers accountable for workplace safety, and 

operating with limited resources. 

The use of automated systems presented challenges for many agencies. 

Some agencies did not use such systems, while others cited difficulties in 

identifying systems that would allow them to collect data relevant to their 

safety programs. For example, 23 agencies (40 percent) reported that they 

do not have automated systems to collect information on hazards that 

have been identified and track whether they have been corrected in a 

timely manner. In addition, 14 of the agencies reporting that they have 

such a system (41 percent) either indicated that their hazard tracking 

systems were not currently operational, or they did not provide sufficient 

documentation to support the existence of such systems. Approximately a 

quarter of the agencies surveyed reported that they did not have 

automated systems for tracking safety training completed by their 

employees. Furthermore, 34 agencies (60 percent) reported they did not 

have an automated system for tracking the status of employees in light or 

restricted duty return-to-work programs, and another 16 agencies did not 

provide sufficient documentation of their systems. While federal agencies 

are not required to use automated data systems, without such a system, 

safety officials would have difficulty tracking broader trends such as 

participation rates in light or restricted duty programs and the effect of 

program participation on worker’s compensation costs. 

Common Implementation 

Challenges Include Data 

Management, 

Accountability, and Safety 

Resources 

Data Management 
Page 21 GAO-06-379 Worker Safety 

Ten of the 12 agencies we reviewed in more detail reported challenges 

with their automated systems, such as ensuring that these systems 

collected appropriate data needed to evaluate the effectiveness of their 

safety programs. For example, an official from the Tobyhanna Army Depot 

told us that their computer technicians were in the process of designing a 

hazard tracking program because no agencywide programs were available, 

and off-the-shelf programs required too much adaptation to be practical. 

She also developed a stand-alone spreadsheet to track all work-related 

injuries because the systems available did not capture injuries that were 

not recordable on the OSHA log (such as injuries requiring only first aid) 

or injuries for which workers’ compensation claims are not filed. 

Furthermore, a National Park Service official stated that entering safety 

meetings and other non-traditional training methods into the agency’s 

automated system is difficult because the system does not have data fields 

for recording these activities. As a result, the agency has difficulty 

determining the extent to which employees have been trained on many 

safety issues. 

Despite these challenges, several agencies told us they have started or are 

in the process of implementing automated safety systems that will allow 

them to collect and analyze data in order to better manage these safety 

programs, including assessing the effectiveness of their programs. For 

example, according to a Transportation Security Administration official, 

the agency is developing a new injury tracking system that will link injury 

and illness data with inspection data, allowing them to identify trends, 

such as where injuries commonly occur and demographic characteristics 

of injured employees. Similarly, officials with the Bureau of Engraving and 

Printing said they are testing a medical management system that will 

aggregate data from a number of different sources including the health 

unit, safety investigation reports, and their workers’ compensation system. 

Collecting these data will allow them to streamline the reporting process 

and better track injury trends. 

Another challenge agencies face is holding managers accountable for 

implementing effective safety programs. While 51 agencies (89 percent) 

reported having policies that establish responsibility for workers’ safety 

and health for all employees, 6 reported that they do not have such 

policies, despite an OSHA regulation requiring them to establish these 

policies for all management officials.26 Of the 51 agencies reporting having 

 2629 C.F.R. §1960.11. 

Accountability
Page 22 GAO-06-379 Worker Safety 

such policies, 11 agencies did not provide sufficient documentation of the 

policies. For example, one agency provided an Employee Performance 

Plan, but there were no performance expectations related to safety 

anywhere in the plan.27 Furthermore, although we asked the agencies to 

provide copies of their performance appraisal review forms citing safety as 

a rating element, only 16 agencies (28 percent) were able to do so. 

Agency officials and employee representatives at 7 of the 12 agencies 

selected for follow-up interviews cited further difficulties in maintaining 

accountability throughout all levels of their organizations. For example, a 

Veterans Health Administration employee representative reported that, 

while there is a high level of commitment to safety at the headquarters 

level, the message is diluted as it reaches lower levels of the agency. In 

another example, the Defense Commissary Agency implemented a 

program that requires regional safety managers to evaluate stores’ safety 

programs. Agency officials stated that regional officials are expected to 

follow up to ensure that stores make timely corrections, but are not 

required to document when hazards are corrected. As a result, the agency 

has little assurance that the safety of store employees is adequately 

protected. In addition, according to an employee representative from the 

Commissary, it is not always clear who is responsible for ensuring that 

hazards are corrected. 

Several agencies reported that they had developed ways to help ensure 

that employees and managers are held accountable for agency safety 

programs. For example, in order to address accountability issues within 

the agency, the Veterans Health Administration initiated a program that 

ties agency safety goals to performance ratings. Moreover, instead of 

simply including safety as a general element of performance review, the 

agency selects two to three specific safety program goals that change 

every few years according to agency needs. Past goals have included 

submitting workers’ compensation claims on time and reducing the 

occurrence of needle stick injuries. According to agency officials, bonuses 

for executive staff members are provided based on their progress in 

meeting these goals. When significant improvement has been made in 

 27We have reported that aligning individual performance expectations with organizational 

goals, such as workers’ safety and health, can help hold individuals accountable for 

contributing to organizational results. GAO, Results-Oriented Cultures: Creating a Clear 

Linkage between Individual Performance and Organizational Success, GAO-03-488 

(Washington, D.C.: Mar. 14, 2003). 
Page 23 GAO-06-379 Worker Safety 

these areas, safety officials set new goals—enabling continuous 

improvement. 

Both agency and OSHA officials cited challenges in funding their safety 

programs, although OSHA regulations require agencies to provide 

adequate resources to implement and maintain these programs.28 One 

agency official we interviewed reported difficulty identifying funding for 

the agency’s safety program because safety funding is not specifically 

designated as a line item in its budget. This lack of information on 

available resources makes it particularly difficult to plan for long-term 

safety issues, such as developing and providing training. For example, 

officials with the National Park Service, which employs a large cadre of 

seasonal workers, reported that the lack of itemized safety funds within its 

budget makes it hard to develop their training plans. OSHA officials cited 

the federal budget process itself as problematic because it requires federal 

agencies to budget months in advance for safety-related equipment 

purchases or other safety devices, long before they may have identified the 

need for this equipment. This was corroborated by a U.S. Mint official who 

reported that it is difficult to correct hazards that require a lot of capital 

investment and planning. 

In addition, a potential consequence of operating with limited resources is 

the use of collateral duty safety officers—employees whose primary 

responsibilities do not involve safety. Nearly all of the agency officials we 

interviewed reported relying on these positions, which are typically filled 

by employees who volunteer or are assigned by the agency. While some 

agency officials reported their collateral duty officers were appropriately 

trained, as required by OSHA, others reported that these officers have 

limited knowledge or experience in safety.29 Some agency officials we 

interviewed said that this lack of experience, as well as the limited amount 

of time collateral duty officers are allotted for safety duties, has made it 

difficult for these officers to learn all of the safety program requirements. 

For example, according to a National Park Service official, collateral duty 

officers at this agency typically spend about 10 percent of their time on 

their safety responsibilities, and this may inhibit their ability to respond 

effectively when safety concerns arise. Moreover, one Forest Service 

official told us that collateral duty officers questioned the feasibility of 

 2829 C.F.R. §1960.7. 

2929 C.F.R. §1960.58. 

Safety Resources 
Page 24 GAO-06-379 Worker Safety 

building safety programs with collateral duty officers, and was concerned 

that the safety duties might detract from their primary job responsibilities. 

Finally, 11 of the 12 agencies selected for follow-up interviews reported 

that competing priorities make it difficult to manage their safety programs. 

For example, a Food Safety Inspection Service official noted that 

completing safety forms and fulfilling data requests can be a burden to the 

agency’s overall mission of meat and poultry inspections. Similarly, an 

employee representative at the Forest Service told us that, because safety 

achievements are not typically recognized or rewarded—even though such 

recognition is encouraged by OSHA regulations—supervisors focus on 

meeting production targets rather than working safely.30

Agencies identified a number of techniques for addressing the difficulties 

associated with managing resources. For example, an official with a 

National Park Service regional office said that they host monthly 

conference calls with the collateral duty safety officers at several national 

parks, which gives these individuals a chance to ask technical questions of 

the regional safety officer and share effective practices among the parks. 

These monthly calls also enable their collateral duty officers, who have 

limited backgrounds in safety, to gain knowledge and experience over 

time. Other agencies maximized their resources by collaborating with each 

other. For example, one official with the Forest Service said that they have 

an informal partnership with the Bureau of Land Management that allows 

them to pool their resources by pursuing joint activities and sharing 

offices and staff. One activity involved jointly developing and teaching an 

accident investigation course and an off-highway vehicle course. 

 30 29 C.F.R. §1960.11. 
Page 25 GAO-06-379 Worker Safety 

OSHA’s oversight of federal agencies’ safety programs is not as effective as 

it could be because it does not use its enforcement and compliance 

assistance resources in a strategic manner. First, OSHA does not routinely 

conduct inspections that target federal worksites with high injury and 

illness rates. In addition, OSHA lacks procedures for tracking and 

resolving violations disputed by federal agencies. Third, OSHA has not 

conducted required evaluations of the larger or more hazardous agencies 

in the last 6 years. Fourth, OSHA has not submitted its own annual reports 

to the President in a timely manner, and they have not included an 

assessment of each agency’s safety program, as required. Finally, while 

OSHA has a range of promising programs for assisting agencies in 

complying with its regulations and improving worker safety, not all of 

these programs are being fully utilized. 

Unlike its enforcement strategy for private-sector employers, OSHA’s 

oversight of federal worksites does not include a national program that 

targets federal worksites with high injury and illness rates for inspection. 

According to its internal guidance, OSHA is supposed to develop a list that 

targets federal worksites for inspection. However, OSHA’s Office of 

Federal Agency Programs has not developed such a list in over 5 years. In 

the past, OSHA used workers’ compensation claims data collected by 

OWCP to identify federal worksites with high numbers of injuries and 

illnesses. Because of limitations in the data, however, it was difficult to 

identify where each injury occurred and, therefore, use this information to 

target federal worksites for inspection.31 OSHA officials at the national 

office reported that they are working to start a new targeting effort but are 

still facing the same difficulties in using workers’ compensation data to 

select federal worksites for inspection. 

 31According to OSHA officials, the database does not include a code for worksite location, 

and the zip code recorded often reflects where the claim was processed instead of where 

the injury occurred. In addition, OSHA officials said that they had to rely on the numbers of 

injuries rather than injury rates because federal agencies were unable to provide a list of 

the number of employees who worked at each worksite—information needed to calculate 

these rates. 

OSHA Provides 

Inadequate Oversight 

of Federal Agencies 

Because It Does Not 

Use Its Enforcement 

and Compliance 

Assistance Resources 

Strategically 

OSHA’s Enforcement 

Strategy Does Not Include 

a Program for Targeting 

Worksites with High Injury 

Rates for Inspection 
Page 26 GAO-06-379 Worker Safety 

As shown in figure 6, OSHA primarily conducts inspections of federal 

worksites as a result of complaints.32

Figure 6: Percent of Inspections of Federal Worksites by Type, Fiscal Years 2000 to 2004 

OSHA’s inspection data of federal worksites show that complaint 

inspections generally result in few violations compared to targeted 

inspections, which generally identify a greater number of serious 

violations (see fig. 7).33 For example, over the last 10 years, unprogrammed 

inspections, which are generally initiated by complaints, uncovered an 

average of one serious violation per inspection, in contrast to an average 

of four serious violations for programmed (targeted) inspections. The 

 32OSHA regulations require that federal agencies have provisions for responding to 

employee reports of unsafe or unhealthy working conditions. However, employees may 

also report hazardous conditions directly to OSHA. If OSHA receives a complaint from an 

employee who works for a federal agency that lacks an established OSH committee, it may 

initiate an inspection or other appropriate action. 29 C.F.R. §1960.28(e). 

33According to OSHA’s internal guidance, a serious violation is defined as one in which 

there is substantial probability that death or serious physical harm could result, and the 

employer knew or should have known of the hazard. 

Source: GAO analysis of OSHA data.

Unprogrammed inspections initiated by complaints

Other unprogrammed inspections (accidents, referrals, etc.)

Programmed inspections

Area Offices without Targeted Programs Area Offices with Targeted Programs

23%

34%

43% 14%

73%

13%

(Total number of inspections =1,658) (Total number of inspections = 826)
Page 27 GAO-06-379 Worker Safety 

small average number of violations for unprogrammed inspections is 

driven by the fact that over half of these inspections result in no violations 

being identified. 

Figure 7: Average Number of Serious Violations at Federal Worksites by Inspection 

Type, Fiscal Years 1995 to 2004 

The new recordkeeping rule, which was implemented in January 2005, 

requires federal agencies to begin collecting the same injury and illness 

data as private-sector employers and could help OSHA develop its 

targeting program, according to OSHA officials. Since the new rule 

requires federal worksites to keep logs that include information that can 

be used to calculate injury and illness rates, OSHA officials said these data 

would be more useful in creating an effective targeting program than the 

workers’ compensation data. While the new rule does not require federal 

agencies to report injury and illness data to OSHA, OSHA officials said 

they could target federal worksites for inspection in the same way they 

target private-sector employers in industries with high injury and illness 

rates for inspection. For its targeting program of private worksites, OSHA 

surveys a sample of worksites in industries with the highest injury and 

illness rates. The survey form requires employers to report on (1) the 

0

1

2

3

4

5

6

7

8

9

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Number of serious violations

Source: GAO analysis of OSHA data.

Fiscal year

Unprogrammed inspections

Programmed inspections
Page 28 GAO-06-379 Worker Safety 

average number of employees who worked for them during the previous 

calendar year, (2) the total hours the employees worked during the 

previous year, and (3) summary injury and illness data from their OSHA 

logs. OSHA then uses this information to compute the worksites’ injury 

and illness rates and sends those with relatively high rates a letter 

informing them that they may be inspected. Finally OSHA develops a list 

of worksites with high injury and illness rates to be targeted for 

inspection. As an alternative to conducting a survey of federal worksites, 

OSHA has the option of requiring federal agencies to report this 

information in their annual reports to OSHA. 

One of OSHA’s regional offices—which includes four area offices—and an 

area office in another region developed their own targeted programs of 

federal agency worksites using the workers’ compensation data. While 

officials reported using the data has been difficult, they said that these 

efforts have resulted in improved safety at federal worksites. In addition, 

they reported that the agencies that were inspected have become more 

aware of OSHA’s role and, in turn, have sought OSHA’s assistance in 

improving their safety programs. Furthermore, agency officials whose 

worksites have been selected for inspection have focused more attention 

on safety and shared information, resulting in further improvements. For 

example, at one worksite in Montana, Forest Service officials reported 

that, after colleagues in Idaho told them OSHA had targeted federal 

worksites in the state for inspection, they were reviewing their safety 

programs and OSHA’s requirements in preparation for possible OSHA 

visits. 

Officials with OSHA’s national office said that they have encouraged 

regions to develop their own programs targeting federal agencies for 

inspection, but we identified some challenges that need to be addressed 

before more regions can successfully develop these programs. For 

example, one regional OSHA official reported requesting workers’ 

compensation data from the national office to start a targeting program, 

but was told the national OSHA office did not have enough time to provide 

the data requested. In addition, regional and area office OSHA officials 

said that the ability to develop and maintain targeting programs depends 

on the resources available. Besides the time and effort required to identify 

worksites, they said the availability of inspectors is also a factor. 

According to OSHA’s policies, OSHA inspectors’ top priority is responding 

to imminent danger situations, followed by accidents, followed by 

responding to complaints; conducting targeted inspections is a lower 

priority. 
Page 29 GAO-06-379 Worker Safety 

OSHA’s procedures for tracking violations disputed by federal agencies 

differ from those for the private sector. Whereas private-sector employers 

can dispute OSHA violations cited during inspections by requesting that 

the violations be reviewed by an independent administrative law judge, 

federal agencies must seek resolution with OSHA officials. In these 

situations, federal agencies may first request an informal conference with 

OSHA area office officials to discuss the violation in question. If the 

dispute is not resolved, it is referred to the relevant OSHA region for 

review and, if necessary, to OSHA’s national office. 

While OSHA’s internal instructions require that area office and regional 

officials be consulted in decisions made by national office officials and an 

Executive Order requires OSHA to submit unresolved violation disputes to 

the President, neither of these things appears to be occurring.34 Although 

national office officials reported that there have not been any unresolved 

disputed violations, and they have not had to report any unresolved 

violations to the President in over 3 years, area office and regional staff 

told us some unresolved disputed violations from federal agencies have 

lingered for years. For example, a regional OSHA official reported that, in 

another region, a federal agency was cited for violating a safety standard 

that did not apply to that particular agency.35 The agency challenged the 

violation, and the dispute reached the national office, where no decision 

was made—leaving the violation unresolved for 7 years. Another OSHA 

official reported a case in which the Bureau of Prisons refused to have 

guards wear special gloves as required while conducting cell searches 

because the guards thought the gloves would not provide them with 

enough sensitivity to feel for objects hidden by prisoners. According to 

this official, it was important for the guards to wear gloves during these 

searches because of the danger of receiving needle sticks or cuts from 

sharp objects. The case reached OSHA’s national office, but it chose not to 

act on the case—leaving the guards at risk and the violation unresolved. 

OSHA could not provide us with a list of all violations disputed by federal 

agencies or the status of their resolution because it does not have a system 

for tracking these disputed violations. OSHA officials at the national office 

indicated that part of the reason the agency has not developed such a 

 34Executive Order 12196, § 1-401(k). 

35According to the OSHA official, the violation involved a military maritime facility that was 

held to a safety standard for general industry; there is no such standard for the maritime 

industry. 

OSHA Lacks a System for 

Tracking Disputed 

Violations 
Page 30 GAO-06-379 Worker Safety 

system is because few federal agencies dispute violations. In addition, 

according to these officials, disputed violations are resolved in a timely 

manner. These officials reported that they seek to review cases in a similar 

manner to the manner in which administrative law judges review privatesector employers’ cases and have considered using either a permanent or 

ad hoc panel to ensure consistency in their review of violations disputed 

by federal agencies. However, without a system for tracking violations 

disputed by federal agencies, OSHA cannot ensure that all disputes have 

been resolved or that they are resolved in a consistent manner. 

Although OSHA is required to conduct annual evaluations of the larger or 

more hazardous federal agencies, and less frequent evaluations for smaller 

and less hazardous federal agencies, it has not conducted any evaluations 

since 1999. OSHA officials reported that because evaluations are so 

resource intensive, they did not have enough staff to support doing them. 

Evaluations are another element of OSHA’s enforcement strategy and 

include both a national-level review of an agency’s safety program and 

site-specific assessments. In the past, OSHA’s national office identified 

federal worksites for evaluations and the area offices inspected them. 

OSHA’s policies require agencies to correct any violations identified 

during inspections conducted as part of its evaluations. In addition, 

OSHA’s internal guidance encourages its officials to coordinate 

evaluations with targeted inspections in order to use its resources more 

efficiently. 

The last evaluation that OSHA conducted, at the Veterans Health 

Administration, resulted in a report that agency officials said they still use 

to improve their safety program. While some OSHA officials told us that 

evaluations are resource intensive and ineffective because agencies have 

not always corrected the problems identified, other OSHA and agency 

officials said OSHA’s evaluation of the Veterans Health Administration 

helped bring management and union officials together for discussions 

during the evaluation process. According to these officials, this improved 

relationship continued after the evaluation was completed. 

OSHA Has Not Conducted 

Evaluations in More Than 

6 Years 
Page 31 GAO-06-379 Worker Safety 

As of February 2006, OSHA had not submitted its annual report to the 

President that summarized and assessed the status of federal agencies’ 

safety programs since 2000 nor provided recommendations of ways for 

federal agencies to improve their safety programs, as required.36 OSHA is 

working to reduce the backlog for these reports, according to the officials 

we interviewed. In addition, OSHA officials told us that they could not 

assess the effectiveness of these programs or make recommendations 

because they do not collect original data on agencies’ safety programs but, 

instead, rely on the reports agencies provide to them on an annual basis. 

According to these officials, they cannot assess or evaluate agencies’ 

programs without collecting independent information on their programs. 

However, we believe that OSHA could use the information provided by the 

agencies in their annual reports to assess agencies’ safety programs, 

including whether they are meeting OSHA’s requirements. For example, 

OSHA could use the agencies’ reports to determine what types of safety 

and health training they are providing to their managers and workers, the 

number and types of self-inspections they are conducting of their 

workplaces, and the measures used to correct unsafe and unhealthful 

working conditions identified during these inspections. In addition, OSHA 

could use these reports to make recommendations for improvement. 

OSHA requires agencies to summarize their injury and illness rates and 

provide information on new initiatives they have started and their 

accomplishments in their annual reports. However, OSHA officials told us 

that they do not systematically review these reports over time to ensure 

that agencies are making progress. Our analysis of the agencies’ reports 

for fiscal years 2000 through 2004 showed that agencies generally 

described the accomplishments of their safety programs but sometimes 

repeated their safety goals across years. For example, one agency reported 

in 2 consecutive years that it had “launched a new e-training program” that 

included safety modules. In addition, agencies generally did not provide 

any follow up information on their prior years’ goals or challenges. For 

example, one agency reported having a goal to develop a database for 

tracking injury and illness trends but made no mention of the system in the 

following year’s report. One OSHA regional official suggested that the 

national office could use regional staff more effectively by requiring each 

region to review selected federal agencies’ annual reports. In this way, 

regional staff could become more familiar with specific agencies’ 

 3629 U.S.C. § 668(b). 

OSHA Has Not Submitted 

Timely Annual Reports on 

Agencies’ Safety Program 

as Required 
Page 32 GAO-06-379 Worker Safety 

programs, which would allow them to more readily identify discrepancies 

and deficiencies in their annual reports. 

Federal agencies can receive compliance assistance from OSHA through 

programs developed especially for federal agencies as well as programs 

initially developed for private-sector employers. The two compliance 

assistance programs developed specifically for federal worksites—Field 

Federal Safety and Health Councils and Agency Technical Assistance 

Requests—have generally been helpful, according to OSHA officials, but 

they are not consistently available to all federal agencies. Some of the 

programs that OSHA initially developed for private-sector employers and 

later expanded to federal agencies—the VPP, strategic partnerships, and 

alliances—have not all been widely used by federal agencies. As of 

January 2006, only 14 federal worksites had joined the VPP and OSHA had 

established few strategic partnerships and alliances with federal agencies. 

However, although only a limited number of federal worksites have used 

these programs, OSHA officials told us many of these efforts have been 

successful and they are encouraging more agencies to participate. 

Regions have anywhere from 2 to 13 active Field Federal Safety and Health 

Councils, depending on the effort regional OSHA officials have made to 

develop and maintain them. These councils, established by OSHA to 

facilitate the exchange of ideas and information about occupational safety 

throughout the federal government, consist of management and employee 

representatives from local federal agencies.37 OSHA officials reported that 

the councils are intended to provide a networking and training forum for 

safety officials from different agencies in a given area, but all agreed that 

maintaining the councils has been a struggle. 

Both OSHA and agency officials cited challenges in maintaining the 

councils. Some OSHA officials reported that federal agencies do not 

always give their representatives time to attend the meetings. Other OSHA 

officials raised concerns that federal agencies have failed to properly train 

their collateral duty safety officials, which has inhibited their 

contributions to the councils. In addition, some officials reported that 

distance makes it difficult for council members to attend meetings. One 

 37OSHA regulations, which established Field Federal Safety and Health Councils to fulfill 

one of the requirements in Executive Order 12196, state that OSHA will charter these 

councils and maintain a liaison with agency heads to facilitate participation in the councils. 

29 C.F.R. §§1960.84–1960.90. 

OSHA Has Used a Variety 

of Compliance Assistance 

Programs for Federal 

Agencies, but None Is 

Widespread 

OSHA’s Regional Offices Have 

Struggled to Set Up and 

Maintain Field Federal Safety 

and Health Councils 
Page 33 GAO-06-379 Worker Safety 

OSHA area director used the state’s library videoconferencing system to 

bring together council members from different areas and suggested that 

OSHA consider similar methods to encourage collaboration. On the other 

hand, a couple of agency safety managers and OSHA officials told us the 

councils are not necessarily an effective tool for agencies because the 

safety concerns are so different among the agencies. For example, a 

Department of Veterans Affairs’ safety manager might be focused on 

preventing needle sticks and identifying violent patients, while National 

Park Service safety staff might be concerned about snake bites and heat 

exhaustion. 

The councils also have limited financial resources. Funding is provided 

solely by OSHA’s regional offices and is not a line item in their budgets. 

While regions attempt to provide training to the councils, any budget 

constraint can quickly eliminate their ability to do so. Until last year, 

OSHA’s national office sponsored an annual conference and the regions 

provided the travel funds for the council presidents to attend the 

conference. However, the conference was canceled in fiscal year 2005, 

partly because the national office did not have the funds to set up the 

meeting and partly because the regions reported not having the travel 

funds required. 

OSHA officials said they sometimes are reluctant to respond to Agency 

Technical Assistance Requests, which can delay this assistance, because 

they consume their limited enforcement resources. An agency can request 

OSHA to provide advice on hazard abatement, training, or program 

assistance. OSHA cannot cite agencies for violations during this process 

but, in making the request, agencies understand they are expected to 

correct any violations OSHA observes. While these requests for technical 

assistance are considered part of OSHA’s compliance assistance strategy, 

rather than enforcement, OSHA area offices and regions must use their 

enforcement budgets and staff to conduct them. Because these offices 

have limited enforcement resources, a regional OSHA official told us that, 

although OSHA responds to all of these requests, this assistance may be 

delayed. 

As of January 2006, there were 14 federal worksites among the more than 

900 private-sector worksites in OSHA’s VPP, which promotes effective 

worksite safety and health. In general, OSHA and agency officials told us 

the program is beneficial for federal agencies and they expect more 

worksites to join. An agency official also said that having one federal 

worksite join often is an impetus for others to consider applying to join the 

program. For example, since the U.S. Mint in Philadelphia became a VPP 

OSHA’s Responses to Agency

Technical Assistance Requests 

Are Sometimes Delayed 

Agencies Have Begun Joining 

OSHA’s VPP 
Page 34 GAO-06-379 Worker Safety 

site in 2005, other agencies within the Department of Treasury have 

considered joining. In addition, some OSHA field staff reported that they 

are in the process of assisting agencies with their VPP applications. While 

a few agency officials told us that the VPP was not feasible for agencies 

because of the resources required, many told us they had worksites 

seeking to join the program. 

Some OSHA officials reported that federal agencies face unique challenges 

in joining the VPP. For example, in order to participate, agencies must 

have an injury and illness rate below the average within their given 

industry. However, some agencies do not fit within a particular industry 

code or definition. This was the case for Yellowstone National Park when 

the worksite first applied to join the VPP. The park was required to classify 

itself in an industry category that included amusement parks and 

miniature golf courses, worksites with much lower injury and illness rates 

than the park. The industry codes were recently changed and now include 

a code for national parks, but Yellowstone is still challenged because its 

injury and illness rates are higher than those of other parks such as 

national monuments with many fewer hazards and injuries. 

OSHA has developed relatively few strategic partnerships and alliances 

with federal agencies, although OSHA officials said those that have been 

formed have generally been beneficial to the agencies in improving their 

safety programs. Strategic partnerships are agreements that employers 

make with OSHA to address specific safety and health problems, while 

alliances are agreements organizations make with OSHA to focus on 

training, outreach, and promoting awareness of safety and health issues. 

OSHA has created a limited number of strategic partnerships with federal 

agencies at the national and regional level. At the national level, OSHA has 

one partnership—an agreement with the Army created in October 2004 

aimed at increasing awareness of safety, reducing ergonomic injuries, and 

sharing best practices. At the regional level, OSHA has 7 current and 10 

completed partnerships with federal agencies. (See table 3.) 

OSHA Has Developed Few 

Strategic Partnerships and 

Alliances with Federal 

Agencies 
Page 35 GAO-06-379 Worker Safety 

Table 3: Federal Agencies’ Strategic Partnerships with OSHA 

 Current Federal agency Completed Federal agency 

National 1 Army 0 

Region 

1 0 0 

2 1 National Park Service San Juan 1 National Park Service Fire Island National 

Seashore 

3 0 0 

4 1 National Park Service Mammoth Cave 0 

5 0 2 National Park Service—Isle Royale & 

Sleeping Bear Dunes 

6 1 Federal Bureau of Prisons, Three Rivers 2 National Park Service Padre Island 

Federal Interagency Training Council 

7 0 0 

8 3 National Park Service—Grand Teton, 

Yellowstone, & Glacier 

1 Veterans Health Administration Cheyenne 

9 0 2 National Park Service—Yosemite & 

Golden Gate 

10 1 Bureau of Land Management-Fremont 

National Forest 

2 Defense Commissary Agency, Ft. Lewis 

Forest Service 

Subtotal -

regional 

partnerships 

7 10 

Total 8 10 

Source: OSHA. 

In general, OSHA officials said that these partnerships have helped 

agencies reduce their injury and illness rates by helping them to develop 

stronger safety programs. However, in two instances OSHA terminated its 

strategic partnerships with federal agencies prior to their completion, 

either because the agency could not agree on the terms of the partnership 

or because the agency lacked the commitment to make the changes 

needed to improve their safety programs. 

Federal agencies have joined two national alliances and formed a total of 

10 regional or local alliances. While most of the alliances have focused on 

general safety issues, more recently Region 10 signed an alliance with the 

Fort Lewis Army Garrison that focuses on improving the training and 

communication for emergency response efforts. According to one OSHA 

official, this alliance has leveraged both agencies’ resources well. OSHA 

has gained training from Fort Lewis on emergency response techniques, 
Page 36 GAO-06-379 Worker Safety 

and Fort Lewis has utilized OSHA’s expertise in properly fitting staff 

members for personal protective equipment to be worn during an 

emergency response. 

OSHA assists federal agencies with SHARE, the Presidential initiative 

begun in 2004 and intended to encourage federal agencies to improve their 

safety programs and reduce federal workers’ compensation costs, but the 

impact of the initiative on agencies’ safety programs is not clear. 

Specifically, OSHA officials reported coordinating with OWCP to provide 

training to the agencies about SHARE, but they had different views on the 

effectiveness of the SHARE initiative. According to some OSHA officials, 

the initiative has encouraged agencies’ national offices to pay more 

attention to safety issues than they otherwise would have. Other officials 

said that they thought SHARE was a paper exercise rather than a tool for 

agencies to improve their safety programs, or that this type of program 

might encourage underreporting of injuries. OSHA’s national office uses 

workers’ compensation data to calculate agencies’ injury and illness rates 

to determine whether they have met their SHARE goals related to workers’ 

safety, but it has not conducted any agency reviews to determine whether 

underreporting has increased, according to OSHA officials. 

OSHA officials at the national office said that they would like to use the 

SHARE data to develop a list of agencies to target for inspection. By 

focusing on agencies that are not meeting their SHARE goals, these 

officials said they thought they could assist agencies in reducing their 

injury and illness rates. OSHA officials said the agency will continue to use 

workers’ compensation data to calculate agencies’ injury and illness rates 

through 2006, but would consider using injury and illness data collected 

under the new recordkeeping requirements after this time. Using this new 

information would allow OSHA to identify trends for each federal agency 

worksite and set more specific goals for improving agencies’ safety 

programs. 

OSHA faces a number of challenges in monitoring federal agencies’ safety 

programs and, over time, has adapted its methods to try to make the most 

of its resources. However, OSHA’s oversight could be further strengthened 

if it took a more strategic approach. Because targeted inspections 

generally uncover more workplace hazards than its other inspections, by 

not targeting its inspection efforts to the most hazardous federal 

worksites, OSHA is not using its limited enforcement staff and resources 

in the best way possible. Now that federal agencies are collecting injury 

Impact of the SHARE 

Presidential Initiative Is 

Unclear 

Conclusions 
Page 37 GAO-06-379 Worker Safety 

data that would make targeting more feasible, OSHA is missing a critical 

opportunity to identify and correct hazards. OSHA could require, as part of 

the federal agencies’ annual reports, that each agency submit certain 

portions or summaries of the data that agencies are required to collect 

under the new recordkeeping requirements. This information could be 

used to target federal worksites for inspection in the same way it targets 

private-sector employers in industries with high injury and illness rates for 

inspection. Alternatively, as OSHA does with private employers, OSHA 

could develop its targeting program using the newly-required data that 

federal agencies are collecting by surveying selected agencies and 

worksites. 

In addition, OSHA is not tracking violations disputed by federal agencies 

or how they are resolved. As a result, hazardous worksite conditions may 

remain uncorrected for years and OSHA may be limiting its ability to 

address challenges agencies are facing in complying with OSHA’s 

standards and to provide additional assistance to the agencies. 

While inspections are specific to individual federal agency’s worksites, 

evaluations allow OSHA to make thorough, agencywide assessments of 

their safety programs. These evaluations require a lot of time and staff, 

but, in the past, OSHA has been able to maximize its resources by 

strategically combining evaluations of entire agencies with inspections of 

federal worksites. By not conducting evaluations of the larger or more 

hazardous federal agencies, OSHA is missing a critical opportunity to 

provide agencies valuable feedback and assistance to agencies for 

improving their safety programs in a more systematic way. 

OSHA could also more effectively assess federal agencies’ safety programs 

if it ensured that the agencies complied with the requirements for filing 

annual reports and used the reports, as well as OSHA’s evaluations and 

inspection data, to assess their safety programs and develop 

recommendations for improvement. Because OSHA does not provide an 

assessment of agencies’ safety programs in its annual report to the 

President or recommendations for improvement as required, its ability to 

ensure the effectiveness of these programs is limited. 

The Secretary of Labor should direct OSHA to 

• develop a targeted inspection program for federal worksites based on 

the new worker injury and illness data federal agencies are required to 

collect by requiring that relevant portions or summaries of that data be 

Recommendations for 

Executive Action 
Page 38 GAO-06-379 Worker Safety 

included in agencies’ annual reports to OSHA or by obtaining the data 

from agencies or worksites through periodic, selected surveys; 

• track violations disputed by federal agencies to their resolution and 

ensure that unresolved disputes are reported to the President; 

• conduct evaluations of the largest and most hazardous federal agencies 

as required; and 

• use evaluations, inspection data, and annual reports submitted by 

federal agencies to assess the effectiveness of their safety programs, 

and include, in OSHA’s annual report to the President, an assessment 

of each agency’s worker safety program and recommendations for 

improvement. 

We provided a draft of this report to the Secretaries of the Departments of 

Labor, Agriculture, Defense, Homeland Security, Interior, Justice, 

Treasury, and Veterans Affairs and the Commissioner of the Social 

Security Administration. Officials from Agriculture, Treasury, and the 

Social Security Administration informed us that their agencies did not 

have any comments on our draft report. We received written comments 

from the Departments of Labor, Homeland Security, and Interior. These 

comments are reproduced in appendixes II, III, and IV. The Departments 

of Defense, Justice, and Veterans Affairs provided technical clarifications, 

which we incorporated as appropriate. 

Labor generally agreed with all of our recommendations. In responding to 

our first recommendation, OSHA explained that, for the immediate future, 

it would use OWCP data to identify federal worksites for inspection. It did 

not support the use of the annual reports to collect data on injury and 

illness recorded by the agencies to use in targeting federal worksites for 

inspection, but thought the use of surveys to collect these data was 

noteworthy. 

In regard to our second recommendation, OSHA reported that it will 

create a database to track the status of OSHA citations disputed by federal 

agencies. In responding to our final two recommendations, OSHA reported 

that it would begin evaluations and a more rigorous review of agencies’ 

annual reports once staffing had increased. 

The Departments of Homeland Security and Interior noted that Labor 

could provide more assistance to agencies in addressing the challenges we 

identified. While we believe agencies should seek assistance from OSHA 

on ways to overcome these challenges, we also believe that these 

Agency Comments 

and Our Evaluation 
Page 39 GAO-06-379 Worker Safety 

challenges will require agencies to work internally to build support for 

worker safety programs. 

In addition, the Department of Homeland Security suggested that our 

recommendations to Labor to increase OSHA’s enforcement activities may 

not appreciably lower the incidence of injuries and illnesses and may 

indeed reduce agencies’ requests for OSHA’s assistance. We continue to 

believe that increased enforcement activities would provide OSHA with a 

balanced strategy for ensuring workplace safety. In addition, inspections 

will allow OSHA to review federal agencies’ injury and illness logs to 

ensure that underreporting is not occurring—another concern that 

Homeland Security raised in its comments. Finally, Homeland Security 

suggested that OSHA should take the lead on developing a governmentwide safety information system. We agree that it is important to have a 

governmentwide safety information system and note that Labor has made 

some effort in that direction. 

We will make copies of this report available upon request. In addition, the 

report is available at no charge on GAO’s Web site at http://www.gao.gov. 

If you have any questions about this report, please contact me at (202) 512-

9889 or at robertsonr@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are listed in appendix VII. 

Robert E. Robertson 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Scope and Methodology 

Page 40 GAO-06-379 Worker Safety 

We sent a data collection instrument to 57 agencies within the 8 largest 

departments. The instrument requested information and documentation 

on six components of sound safety programs we identified from previous 

GAO reports: (1) management commitment, (2) employee involvement, (3) 

education and training, (4) identification of hazards, (5) following up and 

correcting hazards, and (6) medical management. We chose the eight 

departments because they represented 80 percent of the federal executive 

branch workforce—excluding the U.S. Postal Service, which under the 

OSH Act is considered a private sector employer. We contacted officials 

with each of the 8 departments to obtain the names of their operational 

agencies and they provided us with the names of 57 agencies. We 

reviewed the documentation supplied by the agencies to support their 

answers to selected questions on the data collection instrument. In 

reviewing the documentation, we made two assessments: (1) whether the 

documentation supported the agency’s responses and (2) what types of 

activities the agency conducted for each program component. We 

examined each document provided by the agencies in support of their 

responses and assessed each as either “supporting” or “not supporting” the 

agencies’ responses. Each document was reviewed by two people to 

ensure that our assessment of the sufficiency of the documents provided 

by the agencies was consistent. Of the 57 agencies that completed the data 

collection instrument, two did not provide any supporting documentation. 

The practical difficulties of conducting any survey may introduce errors, 

commonly referred to as nonsampling errors. For example, differences in 

how a particular question is interpreted, the sources of information 

available to respondents or in how the data are entered into a database or 

were analyzed can introduce unwanted variability into the survey results. 

We took steps in the development of the survey instrument, the data 

collection, and the data analysis stages for the purpose of minimizing such 

nonsampling errors. For example, a survey specialist designed the survey 

instrument in collaboration with GAO staff with subject matter expertise. 

We pre-tested this survey at two agencies and, based on the results and 

comments received during pre-testing, made appropriate revisions. We 

also independently verified the entry of all survey responses entered into 

an analysis database as well as data analyses procedures. 

We conducted follow-up interviews with safety managers and when 

possible, employee representatives from the largest agency within each 

department, and with the agencies with the highest lost-time or injury and 

illness rates. In some cases, the largest agency had both the highest losttime and injury and illness rates. In total, we conducted follow-up 

interviews with safety managers in 12 agencies, as well as employee 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 41 GAO-06-379 Worker Safety 

representatives in 8 agencies. The interview questions were based on how 

each agency originally responded to the data collection instrument and 

their supporting documentation. 

We also visited five federal agencies’ worksites: the Tobyhanna Army 

Depot in Tobyhanna, Pennsylvania; Yellowstone National Park in 

Wyoming; the U.S. Mint in Philadelphia, Pennsylvania; the U.S. Forest 

Service’s Gardiner District Office (Gallatin National Forest) in Gardiner, 

Montana; and the Veterans Health Administration’s Rocky Mountain 

Network Office (a Veteran Integrated Service Network site) in Glendale, 

Colorado, and Eastern Colorado Health Care Center in Denver, Colorado. 

The first three worksites are OSHA recognized VPP sites. The Forest 

Service site bordered Yellowstone National Park, and the Veterans Health 

Administration site was recognized by OSHA as having a good safety 

program. At each of these locations, we interviewed safety officials and 

discussed the challenges and solutions they faced in developing their 

safety programs. 

We obtained information on claims filed by federal workers for injuries 

they incurred from fiscal years 1995 through 2004 from OWCP. We used 

data from two of OWCP’s data systems to tabulate basic descriptive 

statistics provided in this report. One system provides injury and case 

status information on all individuals who have filed claims with OWCP 

while the other is used to bill agencies for the actual amount of workers’ 

compensation payments made on the agencies’ behalf. These systems 

were used to develop our tables including the number of new cases filed; 

the types of injuries incurred; and the actual amounts paid, by the age of 

the case and types of payment. To assess the reliability of these data, we 

interviewed OWCP and OSHA officials, reviewed published reports based 

on these data (including reports from Labor’s Office of the Inspector 

General), and performed our own tests for consistency and completeness. 

We found that certain data elements had high levels of missing information 

and thus could not be used in this report. For the elements we used, 

although small data discrepancies were found, we determined that the 

data were sufficiently reliable for providing the basic descriptive statistics 

reported. 

In reviewing OSHA’s role, we analyzed inspection data of federal agencies 

for fiscal years 1995 through 2004 from OSHA’s Integrated Management 

Information System. We interviewed OSHA officials at the national office 

and all of its 10 regional administrators and federal agency program 

officers. For each region, we interviewed the director of the area office 

that had the largest number of inspections of federal worksites in the last 5 
Appendix I: Scope and Methodology 

Page 42 GAO-06-379 Worker Safety 

years. We also interviewed a compliance safety and health official in each 

of these offices identified by the area director and, where possible, the 

compliance assistance specialist, although not every area office had a 

compliance assistance specialist. In addition, we interviewed two OSHA 

officials about the local emphasis program for federal worksites that one 

region had implemented. 

Finally, when available, we examined agencies’ annual reports to OSHA 

from 2000 to 2004 and asked to review OSHA’s annual reports to the 

President for the same time period. However, as noted in the report, OSHA 

had not completed its annual reports to the President for fiscal years 2001 

through 2004 as required. We reviewed the report to the President that 

OSHA had completed for fiscal year 2000. 
Appendix II: Comments from the Department 

of Labor 

Page 43 GAO-06-379 Worker Safety 

Appendix II: Comments from the Department 

of Labor 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of the appendix. 

See comment 1. 
Appendix II: Comments from the Department 

of Labor 

Page 44 GAO-06-379 Worker Safety 

See comment 2. 
Appendix II: Comments from the Department 

of Labor 

Page 45 GAO-06-379 Worker Safety 
Appendix II: Comments from the Department 

of Labor 

Page 46 GAO-06-379 Worker Safety 
Appendix II: Comments from the Department 

of Labor 

Page 47 GAO-06-379 Worker Safety

The following are GAO comments on Labor’s letter dated March 17, 2006. 

1. We reordered the SHARE goals as OSHA requested and identified 

those goals for which OSHA is responsible. 

2. OSHA suggests that our finding—that violations disputed by federal 

agencies were not being tracked—was confusing because the agency 

has an inspection database that it uses to track the status of all 

violations. However, as noted in its comments, when OSHA generated 

a report to identify unresolved violations at federal agencies, staff 

could not determine the status of 11 violations. In addition, OSHA 

acknowledged that the Office of Federal Agency Programs (OFAP) 

does not have a formal tracking system for cases it receives for 

resolution. We reviewed the report language and believe that it 

accurately explains the process in place.

GAO Comments 
Appendix III: Comments from the Department 

of Homeland Security 

Page 48 GAO-06-379 Worker Safety 

Appendix III: Comments from the 

Department of Homeland Security 
Appendix III: Comments from the Department 

of Homeland Security 

Page 49 GAO-06-379 Worker Safety 
Appendix III: Comments from the Department 

of Homeland Security 

Page 50 GAO-06-379 Worker Safety 
Appendix IV: Comments from the Department 

of Interior 

Page 51 GAO-06-379 Worker Safety 

Appendix IV: Comments from the 

Department of Interior 
Appendix IV: Comments from the Department 

of Interior 

Page 52 GAO-06-379 Worker Safety 
Appendix V: Data Collection Instrument Sent 

to the Federal Agencies 

Page 53 GAO-06-379 Worker Safety 

Appendix V: Data Collection Instrument Sent 

to the Federal Agencies 
Appendix V: Data Collection Instrument Sent 

to the Federal Agencies 

Page 54 GAO-06-379 Worker Safety 
Appendix V: Data Collection Instrument Sent 

to the Federal Agencies 

Page 55 GAO-06-379 Worker Safety 
Appendix V: Data Collection Instrument Sent 

to the Federal Agencies 

Page 56 GAO-06-379 Worker Safety 
Appendix V: Data Collection Instrument Sent 

to the Federal Agencies 

Page 57 GAO-06-379 Worker Safety 
Appendix V: Data Collection Instrument Sent 

to the Federal Agencies 

Page 58 GAO-06-379 Worker Safety 
Appendix VI: Agencies’ Responses to the Data 

Collection Instrument 

Page 59 GAO-06-379 Worker Safety 

The following table summarizes agencies’ responses to the data collection 

instrument. In addition, the last column summarizes whether the 

documentation agencies provided to support their responses for selected 

questions was sufficient. 

Table 4: Agency Responses to the Data Collection Instrument by Safety Program Component 

Survey question 

Number of agencies 

responding “No”

Number of agencies 

responding “Yes” 

Percent of selected 

agencies responding 

“Yes” that provided 

sufficient supporting 

documentationa

MANAGEMENT COMMITMENT 

Q1 Department goals established for the 

occupational safety and health program. 2 55 91

Q2 Activities designed to communicate the 

importance of the OSH program to staff. 0 57 93

Q3 Management information system that allows for 

trend analysis, risk analysis, etc. 8 49 84

Q4 Policies that establish responsibility for 

workplace safety and health for all staff through 

performance reviews. 6 51 78

EMPLOYEE INVOLVEMENT 

Q5 Procedures for employees to report accidents. 0 57 89

Q6 Procedures for employees to report hazards. 1 56 91

Q7 Employee access to the system capturing 

information on accidents and/or hazards. 19 38 N/A

Q8 Employee involvement in safety 

committees/teams. 3 54 83

Q9 Employee input/involvement in the safetyrelated training curriculum. 8 49 N/A

Q10 Employee participation in walkthroughs of 

worksites to identify hazardous conditions. 7 50 N/A

Q11 Employee involvement on accident 

investigation teams. 14 43 N/A

IDENTIFICATION OF HAZARDS 

Q12 Procedures for conducting required OSHA 

inspections of worksites by safety personnel. 

2 55 93

Q13 Procedures for conducting informal 

walkthroughs of worksites to identify hazards. 

7 50 80

CORRECTION OF HAZARDS 

Q14 Procedures for developing controls for 

workplace hazards. 

4 53 N/A

Appendix VI: Agencies’ Responses to the 

Data Collection Instrument 
Appendix VI: Agencies’ Responses to the Data 

Collection Instrument 

Page 60 GAO-06-379 Worker Safety 

Survey question 

Number of agencies 

responding “No”

Number of agencies 

responding “Yes” 

Percent of selected 

agencies responding 

“Yes” that provided 

sufficient supporting 

documentationa

Q15 Procedures for following up on inspections to 

ensure hazards are corrected. 

4 53 87

Q16 Automated system to track workplace hazards. 23 34 59

TRAINING 

Q17 Departmental OSH training program. 1 56 N/A

Q18 National training initiatives targeted by 

headquarters staff. 12 45 N/A

Q19 Automated system to track employee training. 14 43 63

MEDICAL MANAGEMENT 

Q20 Procedures to ensure that an injured or ill 

employee is seen within a specified time frame by a 

medical provider. 8 49 N/A

Q21 Automated system tracking accident data. 9 48 N/A

Q22 Department restricted or light duty return-towork program. 12 45 76%

Q23 Automated system tracking return-to-work 

status of employees. 34 23 30%

Source: GAO analysis. 

a

Fourteen questions were selected for in-depth documentation review.
Appendix VII: GAO Contact and Staff 

Acknowledgments 

Page 61 GAO-06-379 Worker Safety 

Robert A. Robertson (202) 512-9889 

Revae E. Moran (Assistant Director) and Margaret A. Holmes (Analyst in 

Charge) managed all aspects of the assignment. Jessica A. Lemke, Sheila 

R. McCoy, and Kris Trueblood made significant contributions to this 

report. Other key contributors to this report included Kyle Browning, 

Richard Burkard, Nina E. Horowitz, Tovah Rom, Beverly Ross, Jeremy D. 

Sebest, John G. Smale Jr., Rachael C. Valliere, and Eric A. Wenner. 

Appendix VII: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Acknowledgments 

(130388) 
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