Report to Congressional Committees

United States General Accounting Office

GAO

October 2001 WORKPLACE

SAFETY AND

HEALTH

OSHA Should

Strengthen the

Management of Its

Consultation Program

GAO-02-60
Page i GAO-02-60 Review of OSHA's Consultation Program

Letter 1

Results in Brief 3

Background 4

Worker Safety and Pending Enforcement Are Key Factors

Influencing Participation 9

OSHA Unable to Assess Consultation Program’s Performance 12

Funding Allocation Process Does Little to Encourage Goal

Achievement 16

Conclusions 22

Recommendations for Executive Action 23

Agency Comments 24

Appendix I Comments From the Occupational Safety and Health

Administration 27

GAO Comments 29

Appendix II GAO Contacts and Staff Acknowledgments 30

GAO Contacts 30

Staff Acknowledgments 30

Tables

Table 1: OSHA Performance Goals Applicable to the Consultation

Program 6

Table 2: Changes in Funding for States With Decreased Activity

Levels 17

Table 3: Possible Reasons for Declines in State Consultation

Program Activity Levels 18

Table 4: State Programs Unable to Spend Their Funds Each Year

During FY1996-99 18

Figures

Figure 1: Yearly Changes in OSHA Consultation Program Funding

and Total Visits 5

Contents
Page ii GAO-02-60 Review of OSHA's Consultation Program

Abbreviations

BLS Bureau of Labor Statistics

CAM Consultation Activity Measures Report

GPRA Government Performance and Results Act of 1993

IMIS Integrated Management Information System

MARC Mandated Activities Report for Consultation

OMB Office of Management and Budget

OPTMS OSHA Performance and Tracking Measurement System

OSHA Occupational Safety and Health Administration
Page 1 GAO-02-60 Review of OSHA's Consultation Program

October 12, 2001

Congressional Committees

The Department of Labor’s Occupational Safety and Health Administration

(OSHA) is the federal agency with primary responsibility for promoting

workplace safety and health. OSHA is known for conducting workplace

inspections that can result in fines if employers are not in compliance with

applicable safety and health regulations. The agency also operates a less

publicized effort, the Consultation Program, which is targeted to small

employers in hazardous industries who voluntarily request a consultation

to identify and eliminate workplace hazards that could cause injuries and

illnesses to workers.1

 The consultation is provided free of charge, and

information obtained from a consultation is treated as confidential. In

return, the employer agrees to remedy, within a reasonable time frame,

any serious hazards identified by the consultant. If these hazards are not

remedied within a reasonable time frame, consultants will refer the

employer to OSHA for an inspection. In fiscal year 2000, the program

accounted for about 26,000 consultation visits.

To carry out the program, OSHA provides funds to 502

 state consultation

programs3

 that are responsible for conducting the consultation visits.

Between fiscal years 1996 and 2001, program funding increased over 50

percent—from $32.4 million to $48.8 million. By fiscal year 2001, the

Consultation Program’s funding accounted for over 11 percent of OSHA’s

total budget. However, from fiscal years 1996 to 2000 (the last year for

which complete activity data is available), employer requests for

consultation visits increased only about 4 percent. This discrepancy

between funding and employer interest has led to questions about the

 1

The Consultation Program defines a small employer as one with no more than 250 workers

at the workplace where the consultation is conducted and no more than 500 workers

companywide.

2

This includes 48 states (excluding Kentucky and Washington), the District of Columbia,

and Guam. These programs are authorized under section 21(d) of the Occupational Safety

and Health Act of 1970 (29 U.S.C. 670(d)). Kentucky, Washington, Puerto Rico, and the

Virgin Islands operate consultation programs that are authorized under section 23(g) of the

act (29 U.S.C. 672(g)). For programmatic purposes, these latter programs are distinct from

the nationwide Consultation Program.

3

For purposes of this report, we refer to all consultation programs, including those located

in the District of Columbia and Guam, as “state consultation programs.”

United States General Accounting Office

Washington, DC 20548
Page 2 GAO-02-60 Review of OSHA's Consultation Program

program’s operation and OSHA’s management of it. To help address these

concerns, we initiated this work to (1) identify the factors affecting

employers’ decisions to participate in the program, (2) assess OSHA’ s

ability to measure the Consultation Program’s progress toward achieving

the agency’s goals for reducing workplace injuries and illnesses, and (3)

determine how well OSHA’s funding allocation and monitoring processes

encourage states to support achievement of agency goals. This report is

being addressed to committees that have jurisdiction over federal efforts

to promote workplace safety and health.

To identify factors affecting employer participation in the Consultation

Program, we conducted structured interviews with associations

representing employers and employees in industries that had high rates of

injuries or illnesses among their workers or that were targeted by OSHA

for inspection or participation in the program.4

 We also interviewed 17

employers who had participated in the California, Maine, or New York

consultation programs.5

 To assess OSHA’s ability to measure the

program’s progress toward meeting the agency’s goals and to ensure that

the funding allocation process supports the achievement of those goals,

we identified OSHA’s program and financial oversight policies and

procedures and reviewed activity and budget data.6

 We also obtained data

on program expenditures from all programs experiencing declining levels

of activity as defined by total visits.7

 We interviewed OSHA headquarters

officials in Washington, D.C., and at 6 of the agency’s 10 regional offices to

assess how these policies and procedures were implemented in the field.

To obtain information on how programs operate at the local level and

pursue our objectives with state officials, we visited seven state

consultation programs that accounted for nearly 30 percent of fiscal year

 4

These sectors were construction, food and kindred products, lumber and wood products,

metal products manufacturing, motor freight transportation, and health services.

5

We chose these states for our employer interviews because, during fiscal years 1996-2000,

California and New York had the two largest consultation programs, and the Maine

consultation program was among the fastest growing programs in terms of initial

consultation visits.

6

Because Arizona, Indiana, Nevada, and New Mexico joined the Consultation Program in

fiscal year 1999, we were unable to include them in our analyses of program activity or

funding levels.

7

We obtained data on program expenditures from 16 state consultation programs. These

are the programs in Arkansas, California, Connecticut, Delaware, District of Columbia,

Florida, Iowa, Maryland, Michigan, New Hampshire, New York, North Dakota, South

Dakota, Tennessee, Utah, and Wisconsin.
Page 3 GAO-02-60 Review of OSHA's Consultation Program

2000 federal funds allocated to all 50 programs and represented a crosssection of approaches to program implementation.8

 At each location, we

interviewed program officials and analyzed program and financial data.

We conducted our work in accordance with generally accepted

government auditing standards between January 2001 and August 2001.

Several factors affect employers’ decisions to participate in the

Consultation Program. According to industry associations, employee

representatives, and participating employers we interviewed, the two

principal incentives for program participation are to (1) make the

employer’s workplace safer and reduce worker injury and illness by

promoting workplace safety and health and (2) prepare the employer’s

workplace for an OSHA inspection. In contrast, the potentially high cost of

correcting hazards and the possibility that program consultants would lack

the competence to adequately identify and remedy hazards are the two

principal disincentives.

OSHA is generally unable to measure the Consultation Program’s progress

toward the achievement of OSHA’s key goals related to reducing

workplace injuries and illnesses. This is primarily because the

measurement system OSHA uses lacks the data necessary to separate the

outcomes of the Consultation Program from the outcomes of OSHA’s

other efforts to reduce workplace injuries and illnesses. Lacking necessary

data, OSHA cannot determine whether injuries and illnesses actually

decline at an employer’s work site after a consultation visit takes place.

Moreover, OSHA and state consultation program officials agree that the

agency’s data collection system for measuring program activity is

burdensome and inefficient. For example, officials of one state program

told us that the program could increase the number of consultations they

conduct by as much as 20 percent if federal OSHA reporting requirements

were reduced. State program officials also said that there are so many data

elements measured that it is difficult to know which program activities

should receive priority.

OSHA’s process for allocating funds to the state consultation programs

plays no role in encouraging participating states to achieve agency goals.

The criteria OSHA uses to allocate funds to state consultation programs do

not consider performance; that is, achievement of agency goals, how many

 8

The state consultation programs we visited were California, District of Columbia, Maine,

Maryland, New Jersey, New York, and Pennsylvania.

Results in Brief
Page 4 GAO-02-60 Review of OSHA's Consultation Program

consultation-related activities a state consultation program has done in the

past year, or a program’s ability to use the funds allocated for these

activities. For example, during fiscal years 1996-2000, all state consultation

programs received increases in program funds, even though 16 programs

decreased their level of activity during this period. In addition, OSHA’s

regional offices lack detailed data on how state consultation programs

spend federal funds because they have inconsistent policies for auditing

the financial performance of these programs; some regions conduct audits

every year, while others had not audited state programs under their

jurisdiction for 5 years. They also lack ready access to detailed

information on how state consultation programs spend the federal funds.

As a result, OSHA does not know the extent to which state consultation

programs are making effective use of allocated funds.

We are making recommendations to OSHA to strengthen its management

of the Consultation Program by improving its processes for measuring the

program’s contribution toward achieving OSHA goals and ensuring that

the allocation of funds to the state programs supports attainment of these

goals.

In commenting on a draft of this report, OSHA generally agreed with our

recommendations and said the report would help improve the

Consultation Program. However, OSHA noted that, in its view, current

federal law for program evaluation does not require the agency to measure

the contribution of individual programs toward achieving its agencywide

goals. Nonetheless, OSHA agrees that it needs measurement criteria for

the program and will look for opportunities to examine its effectiveness.

OSHA established the Consultation Program in 1975 as a mechanism,

separate from its enforcement program, to reduce workplace injuries and

illnesses, especially for small employers who often cannot afford in-house

or private sources of assistance. The program operated in the shadow of

OSHA’s much larger and more visible enforcement program until the mid1990s, when OSHA began to give greater emphasis to consultation.

Consistent with that emphasis, funding for the Consultation Program

increased over 50 percent between fiscal years 1996 and 2001.9

 Many

knowledgeable officials see this trend toward cooperation as enhancing

OSHA’s overall efforts to protect workplace safety and health.

 9

This includes cost-of-living allowances.

Background
Page 5 GAO-02-60 Review of OSHA's Consultation Program

However, program activity for the same period did not increase

substantially with the increase in funding. For example, the number of

total consultation visits increased about 2 percent nationwide between

fiscal years 1996 and 2000 (the last year for which complete program data

are available)—from 25,986 to 26,418. Further, the number of total hazards

identified through the program decreased about 8 percent—from 188,577

to 171,167. Figure 1 shows the yearly change in funding compared with the

change in the number of total visits from fiscal years 1996 to 2000.

Figure 1: Yearly Changes in OSHA Consultation Program Funding and Total Visits

Notes: Total visits include initial visits to employers plus training and other follow-up visits. This figure

does not include funding or activity data for Arizona, Indiana, Nevada, and New Mexico because they

joined the Consultation Program in fiscal year 1999.

Source: OSHA data.

-5

0

5

10

15

20

25

30

1996 1997 1998 1999 2000

-0.5

8.1

-2.6

10.9

2.0

24.2

1.7

28.0

Total Visits = 25,986

Funding = $30,331,900

Percentage Change in Total Visits

Percentage Change in Funding

Percentage Change Compared to Fiscal Year 1996

Fiscal Year
Page 6 GAO-02-60 Review of OSHA's Consultation Program

With one exception, each state has designated a single agency (i.e., labor,

commerce, health, or environmental protection) or a state university to

deliver the consultation services.10 The state entities running this program

have significant flexibility for delivering the consultations. However, there

are procedures and requirements codified in regulation that each state

consultation program must follow.11 State consultation programs are

required, for example, to give service priority to small, high-hazard

employers and ensure that worker representatives are involved in initial

and closeout meetings with the employer.

With the passage of the Government Performance and Results Act of 1993

(GPRA), OSHA established three agencywide strategic goals related to

improving workplace safety and health. The first goal, in particular, is to

“improve workplace safety and health for all workers as evidenced by

fewer hazards, reduced exposures, and fewer illnesses, injuries, and

fatalities.” Under this strategic goal, OSHA established several

performance goals, most recently for fiscal years 1997-2002, that contained

specific objectives for reducing workplace injuries, illnesses, and fatalities.

As shown in table 1, OSHA has identified four of these performance goals

as being applicable to the Consultation Program.

Table 1: OSHA Performance Goals Applicable to the Consultation Program

Type of goal Projected outcome

Reduce by 15% workplace illnesses and injuries in the shipyard,

food processing, nursing home, logging, and construction

industries.

Reduce by 15% illnesses and injuries resulting from amputations

and from exposure to lead and silica.

Targeted

Reduce by 15% the four leading causes of fatalities in the

construction industry.

Nationwide Reduce injuries and illnesses by 20% in at least 100,000

workplaces where OSHA initiates an intervention.

Note: In addition to these strategic outcome goals, OSHA identified strategic activity and customer

satisfaction goals that applied to the Consultation Program, which are not discussed in this report.

Source: U.S. Department of Labor, OSHA, Revised Strategic Plan (FY 1997–FY 2002), Sept. 18,

1998.

 10Wisconsin has divided its consultation program between its commerce and health

agencies.

11See 29 C.F.R. part 1908.
Page 7 GAO-02-60 Review of OSHA's Consultation Program

OSHA established these strategic and performance goals for the 31

consultation programs in states (29 states, the District of Columbia, and

Guam) for which OSHA has primary enforcement authority. These states

are under federal OSHA jurisdiction for workplace safety and health. The

remaining 19 state consultation programs operate in states that have their

own safety and health programs.12 Each of these “state-plan” states has

adopted OSHA’s first strategic goal but has developed its own related

performance goals.13

OSHA developed a database system—the OSHA Performance and

Tracking Measurement System (OPTMS)—to obtain information on

activities related to OSHA’s GPRA goals. According to OSHA officials, this

Web-based system requires no additional reporting because it includes 276

data elements that already exist in other OSHA data systems. One hundred

of the elements are relevant to the Consultation Program. For example,

OPTMS tracks the number of consultations that are performed in targeted

industries, as well as the number of employers participating in the

Consultation Program that develop a safety and health program. Only the

consultation programs in the 31 federal OSHA states provide data into

OPTMS for evaluation.14

OSHA also uses its Integrated Management Information System (IMIS) to

collect agencywide data, including data on the activities of the

Consultation Program. Consultation Program managers at OSHA use IMIS

to compile two reports providing data specific to the Consultation

Program. The first of these, the Consultation Activity Measures Report

(CAM), tracks 18 quantitative indicators of the Consultation Program’s

activities, such as the number of days from request to visit and the number

of hazards identified per visit. The second, the Mandated Activities Report

for Consultation (MARC), tracks five indicators of the Consultation

Program’s activities that reflect regulatory requirements, including the

 12Under the Occupational Safety and Health Act, states are allowed to establish and enforce

their own safety and health standards as long as they are at least as effective as the federal

OSHA program.

13As mentioned earlier, the analysis in this report does not include the consultation

programs in Kentucky, Washington, Puerto Rico, and the Virgin Islands. The consultation

programs in these “state-plan” states are authorized in a separate provision of the

Occupational Safety and Health Act.

14OSHA said that it will assess the performance of states that have their own safety and

health programs in accordance with their respective statewide goals as well as through

traditional activity and other outcome measures.
Page 8 GAO-02-60 Review of OSHA's Consultation Program

proportion of visits that were made to high-hazard establishments and the

number of visits to smaller employers.

In addition, to help measure the Consultation Program’s progress toward

achieving performance goals, OSHA introduced, for the first time in fiscal

year 2000, a process for use by its regional offices to provide guidance to

the state consultation programs. Under this process, the regional offices

are supposed to assist each state consultation program in developing an

annual project plan that contains goals. Each state consultation program is

supposed to develop an end-of-year performance report that the regional

offices review. The regional offices also prepare reports on the state

consultation programs under their jurisdiction. The first of both these

year-end reports was under way during our audit work, so they were too

new to evaluate.

To fund the Consultation Program, OSHA provides grants to the state

entities delivering the services. OSHA provides 90 percent of the funds

needed to carry out the program, and the state consultation programs

provide the remaining 10 percent.15 OSHA gives each state consultation

program a base amount equal to the funding it received during the prior

year plus any cost-of-living adjustment. If there are any funds remaining,

OSHA uses a formula it instituted in fiscal year 1999 to distribute them to

state consultation programs. As part of this formula, OSHA first divides

the remaining funds in half. It distributes the first half based on the share

of the overall funding that each state consultation program has. It then

takes the second half and distributes it according to yearly data for three

factors that approximate a program’s workload—level of gross state

product, total state nonfarm employment, and number of small highhazard establishments in the state.16 For each year during fiscal years 1996-

2000, each state consultation program received a funding increase. The

states must obligate the federal funds before the end of the fiscal year for

which they were appropriated, or else they expire and are no longer

available to the Consultation Program.

 15OSHA finances 100 percent of the consultation program in Guam.

16Before fiscal year 1999, the amount of funding provided to state consultation programs

was simply based on amounts the programs received the prior year and their ability to

match the funding provided. OSHA officials stated that the formula, which the agency

created in conjunction with state consultation program representatives, was designed to

bring state programs to some level of funding parity. Funding parity is attained when the

funding that is provided to each state program is proportional to the overall demographic

factors affecting demand for the service in each state.
Page 9 GAO-02-60 Review of OSHA's Consultation Program

Industry associations as well as participating employers identified the

opportunity to improve workplace safety and health and to prepare for or

preempt an OSHA inspection as two incentives for participation in the

Consultation Program. Industry association officials, worker

representatives, and participating employers we interviewed also

identified concerns about costs to address identified hazards and the

qualifications of program consultants as two disincentives.

Industry associations as well as participating employers identified the

opportunity to minimize worker injuries and illnesses and otherwise

improve workplace safety and health as one incentive for participating in

the Consultation Program. They saw activities to promote workplace

safety and health as an opportunity to reduce the number of employee

workdays lost because of injuries and illnesses; retain experienced

workers and minimize turnover; promote strong labor-management

relations, particularly in union workplaces; and possibly reduce workers’

compensation costs. Even employers that had in-house expertise on

workplace safety and health said that the Consultation Program could help

them identify hazards that they might otherwise have overlooked and

resolve problems that previously they had not addressed directly.

Some industry associations, as well as participating employers, identified

the Consultation Program’s potential for reducing the number of citations

(and fines) that might result from a subsequent OSHA inspection as a

second incentive. Although they saw safety as the factor driving employers

to request consultations, several industry associations said that an

imminent inspection would serve as a strong incentive for their members

to participate in a consultation. Many industry associations believed that

an employer who had a consultation would likely fare better if an

inspection did occur. Several of the employers we interviewed who had

participated in consultations said that their primary incentive for doing so

had been to prepare for or preempt an inspection and the possibility of

substantial fines. These employers generally had been notified of a

possible inspection, either directly by the state or federal OSHA, or more

indirectly through industry associations, business newsletters, or

presentations that OSHA was targeting their industry.

OSHA officials as well as most of the state consultation program officials

we interviewed echoed the view that there is a strong positive correlation

between anticipated inspections and an employer’s request for a

consultation. They provided examples, which follow, of the effect of an

increased emphasis on inspections.

Worker Safety and

Pending Enforcement

Are Key Factors

Influencing

Participation

Worker Safety and

Enforcement Identified as

Incentives
Page 10 GAO-02-60 Review of OSHA's Consultation Program

• In 1993, Maine OSHA implemented the “Maine 200” program, through

which it contacted the 200 Maine employers with the highest number of

serious workplace injuries and illnesses. OSHA offered these employers a

choice of working cooperatively with OSHA to address workplace hazards

or remaining on a list of work sites that would likely be inspected. About

98 percent of these employers chose the former. According to a Maine

consultation program official, many of these employers turned to the

Maine consultation program for assistance in identifying and correcting

hazards. Maine consultants added that subsequent enforcement programs,

focused on local employers, have also been very successful in encouraging

employers to use the Consultation Program.

• In 1994, California initiated a state-funded consultation program, called the

Targeted High Hazard Consultation Program, through which California

sends letters to employers with high workers’ compensation rates to notify

them that they will be inspected unless they seek help from available

consultation programs or their insurance carrier. According to California

program officials, this effort increased the number of consultations

requested from the state-funded consultation program. This program was

recently merged with the state OSHA-funded consultation program.

Industry association officials and employers we interviewed identified

concerns about the costs of correcting hazards and the qualifications of

program consultants as disincentives. First, officials from both groups

stated that employers are concerned that the cost of correcting the

hazards identified by a consultation might be prohibitive. They feared that

if they could not afford to correct all the hazards in an acceptable time

frame, the consultant might report them to OSHA for an inspection.

Consultants and state program managers we interviewed said that, in their

experience, the costs associated with addressing hazards are generally

manageable, but fears about costs still persist among employers. Second,

industry associations and employee representatives expressed concern

that some state consultation programs employ individuals who lack the

appropriate credentials or experience to serve as workplace safety and

health consultants. Some states do not require that consultants have

advanced or specialized degrees. Other industry associations and

employee representatives said that even those consultants with credentials

in workplace safety or health-related fields might not have the industry

expertise necessary to identify and suggest remedies for hazards. One area

identified with regard to this concern was the health industry.

General distrust of OSHA was another factor identified as a disincentive

for participation in consultations. Employers feared that consultants

Concerns About Costs and

Consultant Qualifications

Identified as Disincentives
Page 11 GAO-02-60 Review of OSHA's Consultation Program

would inappropriately provide information about the consultation to

OSHA, prompting an inspection. However, none of the industry

association representatives or employers we spoke with knew of any

instances where this had actually happened.17 Related to this concern was

the perception that state consultation programs were oriented more

favorably toward workers than employers. Industry associations and

employers identified recently developed regulatory requirements that they

believed reinforced this perception. These included the requirement that

employers permit an employee representative to participate in all phases

of the consultation visit and the requirement to post a list of the hazards

identified by the consultation and the date by which the hazards are to be

corrected.

Although employers have both incentives and disincentives for

participating in the consultation program, they may be unaware, in

general, of the program and what it offers. Industry association officials

said that they do not often see the Consultation Program promoted at key

employer events. In addition, they did not think that the Consultation

Program was adequately promoted as part of other federal efforts that

help small employers establish and maintain safe workplaces. Employee

representatives echoed this sentiment, saying that they did not believe that

most employees knew about the program. Others said that even if the

employers were aware of it, they might not know who can participate or

how to initiate a consultation.

During the course of our work, we found several state consultation

programs that were attempting to address some of these disincentives. For

example:

 17Industry and labor representatives we interviewed said there had been cases where a

consultation was ongoing or just concluded and an OSHA inspector arrived, but they

believed this indicated a lack of coordination between the two entities rather than an

inappropriate exchange of information.
Page 12 GAO-02-60 Review of OSHA's Consultation Program

• Maine’s promotion program. The Maine consultation program has

developed a campaign that, among other things, addresses the disincentive

posed by employers’ concerns about costs. This program has used state

funds to develop a promotion campaign, called Safety Works, which

emphasizes that, in the long run, employers will very likely save money by

eliminating serious workplace hazards. This campaign also emphasizes

that consultants are willing to work with employers to identify remedies

that do not financially overburden the employer. Maine also provides lowcost loans to the employer, if necessary, to address the identified hazards.

• Pennsylvania’s university-based program. The Pennsylvania consultation

program operates out of the Indiana University of Pennsylvania and is one

of eight state programs located at a state university. Between fiscal years

1996 and 2000, the program experienced an 88-percent increase in requests

for consultation visits, while nationwide requests for consultation visits

increased only marginally. Operating out of a university has allowed the

Pennsylvania program a number of benefits. First, potential clients are less

likely to perceive university-based programs as an extension of OSHA.

Second, the university can attract higher qualified consultants than the

state government because it can offer higher salaries than the state

government as well as competitive benefits. For example, it offers

consultants the opportunity to take sabbaticals from consultation to teach

at the university.

In measuring its progress toward reaching its GPRA performance goals for

reducing injuries and illnesses, OSHA does not seek to isolate the

contributions of each of its program activities (e.g., consultation or

compliance inspections). For this and other reasons, the agency cannot

measure the impact of the Consultation Program. Specifically, the agency

cannot measure the extent to which the program contributes to

accomplishing OSHA’s goals for reducing the number of workplace

injuries and illnesses associated with targeted industries or hazards.

Similarly, the agency cannot measure the extent to which the program

contributes to the agency’s reaching its nationwide goal. Finally, state

consultation programs have concerns about OSHA’s system for collecting

activity information, which they characterized as burdensome and

inefficient.

OSHA cannot assess the extent to which its Consultation Program is

helping to achieve OSHA’s goals. OSHA employs a three-step process to

measure its success at reducing injuries and illnesses in targeted areas that

uses data from OPTMS and nationwide data from the Bureau of Labor

Statistics (BLS). Using OPTMS, OSHA first identifies all agency activities

OSHA Unable to

Assess Consultation

Program’s

Performance

OSHA Lacks the Data to

Measure Progress
Page 13 GAO-02-60 Review of OSHA's Consultation Program

in a given period that were directed toward OSHA goals. OSHA then uses

BLS data to measure changes in the level of workplace injuries or illnesses

in targeted industries or caused by targeted hazards. If the level of

measured injuries and illnesses declines, OSHA infers that the activities it

conducted contributed to that decline.

There are three reasons why OSHA’s efforts do little to allow it to identify

the impact of the Consultation Program. First, in conducting its analysis,

OSHA collects data only from the 31 state consultation programs located

in federal OSHA states, meaning that the activities of the 19 “state plan”

state consultation programs are not reflected. Second, in assessing

progress toward its goals, OSHA does not isolate the activities of the

Consultation Program from those of its other programs (such as

enforcement), which means that OSHA does not know the relative impact

of the Consultation Program on the achievement of its goals. Third, even if

OSHA were able to identify the separate activities of the Consultation

Program, its analysis would not demonstrate a direct causal link between

the services offered by the Consultation Program and nationwide changes

in workplace safety and health, which may also result from other

influences.

Establishing a better connection between the Consultation Program and

reductions in the number of injuries and illnesses among workers would

require having data from all state programs and all employers receiving

consultations, both before and after the consultation. Other factors, such

as new management, might affect the level of injuries and illnesses at a

workplace. Nonetheless, this information could give OSHA a better

understanding of the outcomes of the Consultation Program than it has

now. The Consultation Program currently collects data on workers’

injuries and illnesses in preparation for each consultation visit, but

according to OSHA officials, the program has been hesitant to collect the

same data for the period following the consultation.

OSHA has been reluctant to collect these data because agency officials

believe that such data may not be available and because their collection

may burden employers, be outside the agency’s authority, or raise issues

regarding the confidentiality of employer information. While these issues

need to be considered, they do not appear to be insurmountable. There

does not appear to be any prohibition against OSHA’s obtaining this

information from all 50 state programs, and several state programs collect

this information already. Also, consultants told us that they believe there

are ways for OSHA to obtain this information while maintaining its pledge

of confidentiality. For example, state program consultants could collect
Page 14 GAO-02-60 Review of OSHA's Consultation Program

and enter aggregate information into OSHA’s data system (i.e., compiled

into industry or statewide information) without divulging establishment

names.

OSHA also experiences difficulty in assessing the Consultation Program’s

contribution to the agency’s nationwide performance goal—reducing by 20

percent the number of worker injuries and illnesses at 100,000 workplaces

where it initiates an intervention. To measure its progress toward this

goal, OSHA conducted a study18 in which it used two databases—one

maintained by BLS and the other in-house—to identify the number of

workplaces where injuries and illnesses had been reduced by 20 percent

from October 1995 to March 1997. This report concluded that OSHA was

making progress toward achieving this goal. However, it also noted that

the study was not designed to isolate the effects of different types of

interventions. Thus, it could not be used to evaluate the impact of the

Consultation Program.

State consultation program managers, as well as OSHA officials, expressed

concern about the burden placed on state programs by OSHA’s data

reporting requirements. This was especially true in those cases where

these programs also had state-imposed reporting requirements. State

program officials said that they believed much of the time spent on data

reporting was wasted because the reporting requirements focus more on

the number of hazards identified than on how effectively the hazards were

remedied. Consultants with the Maine consultation program stated that

they devote half their time to fulfilling reporting requirements, while New

York program officials said that, for each day spent with employers,

consultants spend 21⁄2 days in the office complying with data reporting

requirements, including the consultation report for the employer. In

California, consultation officials estimated that the state program could

increase the number of consultations they did by as much as 20 percent if

federal OSHA reporting requirements were reduced.

In addition, the number of activity indicators that OSHA tracks—over 100

indicators that are relevant to the state consultation programs in the

MARC, CAM, and OPTMS systems—dilutes OSHA’s ability to

communicate the program’s key goals and priorities to states. State

 18See OSHA, An Estimate of OSHA’s Progress from FY 1995 to FY 1999 in Attaining Its

Performance Goal of Reducing Injuries and Illnesses in 100,000 Workplaces (Mar. 23,

2000).

OSHA Relies on

Burdensome Reporting

System for Measuring

Program Performance
Page 15 GAO-02-60 Review of OSHA's Consultation Program

consultation program officials said that the large number of activity

indicators tracked by OSHA makes it difficult to determine which

activities—and associated goals—should have priority. For example,

OSHA tracks the number of consultation visits state consultation

programs make. This may signal states to give priority to conducting as

many visits as possible to many different employers. However, OSHA also

tracks the number of consultations that result in employers developing

safety and health programs. This may signal states to give priority to

conducting numerous visits to a single employer. While focusing more

intensely on individual employers may increase the likelihood that

employers develop health and safety programs, at the same time, it may

potentially reduce the number of consultations overall. State consultation

program managers also said that the sheer number of activities OSHA

tracks means that state programs cannot pursue all of the indicators. As a

result, program managers tend to select the three to five that they believe

are most important. For example, one state program manager we visited

focused almost entirely on initial visits, hazards corrected, and timeliness

of the report; another placed greatest emphasis on total visits, combined

safety and health visits, and certain targeted goals.

Finally, state consultation program officials told us that indicators used,

some of which were developed in the 1980s, do not reflect how some state

consultation programs currently operate. For example, the New York and

California programs focus on providing employers with long-term

assistance that includes, among other things, extensive follow-up,

technical assistance regarding the best ways to correct hazards, training

for management and workers, and guidance on the proper installation of

new equipment and the introduction of new processes. However, these

activities are not represented in current indicators. The California, Maine,

and New Jersey programs have placed increased emphasis on promoting

the Consultation Program within the local business community by making

presentations, participating in conferences, and utilizing electronic and

print media. Although OSHA currently collects information on activities

intended to promote the program, it does not analyze this information.

OSHA officials, as well as every Consultation Program manager we

interviewed, acknowledged that OSHA needs to replace the current

performance measurement system with a less burdensome and more

relevant system. For the past 8 years, OSHA Consultation Program

officials have recognized the need for a separate system for obtaining

activity data that would operate outside IMIS; however, resource

constraints and higher priorities within the agency have prevented this.

OSHA has been attempting to improve the electronic transfer of data from
Page 16 GAO-02-60 Review of OSHA's Consultation Program

the states into IMIS, and Consultation Program staff at OSHA have been

told that they cannot make any significant changes to the IMIS-based data

systems until this project to update IMIS is completed. In the meantime,

OSHA officials said that they have told the state programs that many of the

indicators, such as those in the CAM, should no longer drive program

activity. However, OSHA continues to require state programs to provide

data on all of these indicators and includes some of the indicators in newly

developed yearly program monitoring reports that each state program

must complete.

OSHA’s process for allocating federal funds to state consultation programs

does not encourage these programs to make effective use of these funds.

Because OSHA does not collect data to assess the Consultation Program’s

performance, it cannot consider such data in its allocation process. Also,

even though OSHA collects data on state program activity, it does not use

this information to allocate funds to state consultation programs. It also

does not consider state programs’ ability to use allocated funds. As a

result, state consultation programs receive additional funds each year

regardless of prior performance. At the same time, OSHA’s 10 regional

offices do not pursue consistent policies for conducting fiscal audits of

consultation programs within their jurisdictions and lack ready access to

spending information needed to oversee the operations of consultation

programs.

In allocating funds to state consultation programs, OSHA does not factor

in the programs’ activity levels. As a result, programs can routinely

decrease the number of consultations they conduct and the number of

hazards they identify and still receive funding that is the same or greater

than they received in the previous fiscal year. All state consultation

programs received increases in funding between fiscal years 1996 and

2000, even though 16 consultation programs experienced often significant

decreases in activity levels, as shown in table 2.

Funding Allocation

Process Does Little to

Encourage Goal

Achievement

Activity Is Not Considered

in Allocation Process
Page 17 GAO-02-60 Review of OSHA's Consultation Program

Table 2: Changes in Funding for States With Decreased Activity Levels

Percentage change from FY1996 to FY2000

State Funding level Total visits made Hazards identified

Arkansas 15 -25 5

California 25 -53 -47

Connecticut 22 -10 -49

Delaware 47 -15 -31

District of Columbia 46 -23 -55

Florida 25 -50 -63

Iowa 20 -34 -26

Maryland 32 -25 -14

Michigan 27 -5 17

New Hampshire 75 -1 12

New York 19 -17 -23

North Dakota 28 -2 43

South Dakota 42 -24 -23

Tennessee 19 -32 -56

Utah 18 -18 -4

Wisconsin 19 -3 -4

Note: This table does not include funding or activity data for Arizona, Indiana, Nevada, and New

Mexico because they only joined the Consultation Program in fiscal year 1999.

Source: OSHA data.

Although neither OSHA nor state program officials we interviewed have

analyzed why one-third of the state consultation programs appeared to be

doing less with additional funds, they did identify several factors that

might affect activity levels. As shown in table 3, these included, among

others, data collection mechanisms that do not reflect all the activities that

programs pursue, data collection requirements that potentially decrease

time available for consultation, and hiring freezes that result in unfilled

consultant positions. However, OSHA officials agreed that, at some point,

decreases in basic program activities, such as the number of consultation

visits or hazards identified, raise questions about resource utilization.
Page 18 GAO-02-60 Review of OSHA's Consultation Program

Table 3: Possible Reasons for Declines in State Consultation Program Activity

Levels

Possible reason Effect on activity levels

Developing long-term relationships

with employers

These efforts require greater levels of resources

than quick one-time consultations.

Data collection mechanisms do not

reflect all the activities that

programs pursue

It may appear that activity is decreasing, but

resources have just been shifted to other activities.

GPRA-imposed targeted industries

or hazards

Changes in areas of program focus may require

different strategies to find new clients.

Data collection requirements Administrative requirements take consultants’ time

away from consultations.

State-imposed hiring or salary

freezes

Hurts programs’ ability to fill consultant positions,

so fewer consultants available to do visits.

Source: State consultation program management and staff.

We also found that OSHA provided increased funding to states even if they

had a history of being unable to use their funding allocations for prior

years. In total, 31 of the programs were unable to use all their funds at

least once between fiscal years 1996 and 1999. (How many state programs

will have this experience in fiscal year 2000 is unknown because they are

still reporting their expenditures to OSHA.) Table 4 identifies the 7 state

programs that were unable to use all of their funds every year during that

period. In addition, 8 other programs were unable to use all their funds for

3 of those 4 years, 10 programs had this experience for 2 of those years,

and 6 programs had this experience for 1 year.

Table 4: State Programs Unable to Spend Their Funds Each Year During FY1996-99

Percentage of total funds unused

State 1996 1997 1998 1999

Louisiana 6 11 35 13

Michigana 8 11 22 11

New Hampshire 10 3 5 12

New York 1 7 5 8

North Carolina 9 6 3 13

North Dakota 19 18 23 43

Tennessee 11 5 13 1

a

Michigan provided this information separately for its safety program and health program, which at the

time were managed by different agencies. We combined this information for purposes of this analysis.

Source: OSHA data.

Unused funds complicate OSHA’s ability to ensure that funds are used to

support the achievement of its strategic goals. State consultation programs
Page 19 GAO-02-60 Review of OSHA's Consultation Program

sometimes notify OSHA of their inability to use the funds, in which case

OSHA can reallocate those funds to other programs. However, because

these funds arrive late in the year and will not be made available in

subsequent years, OSHA instructs the state consultation programs not to

use them for salaries or fringe benefits, other than one-time bonuses. As a

result, state consultation programs generally use these funds to buy

equipment or other supplies. In other cases, state consultation programs

that cannot use the funds do not alert OSHA to that fact, in which case all

unobligated funds expire at the end of the fiscal year and are no longer

available for use.

OSHA, in partnership with the states, changed its allocation process

starting in fiscal year 1999, but did not use this opportunity to factor in

activity levels or use of funds. By not doing so, OSHA lost the opportunity

to use the funding allocation process to influence state program

performance. As noted earlier, under OSHA’s current allocation process,

state programs are ensured a level of funding equal to what they received

in the previous year, as long as the program budget has not decreased. In

addition, state programs are awarded additional funds based on their size

rather than their activity levels or a demonstrated ability to use the funds

allocated to them.

As a result of its limited monitoring, OSHA lacks the information

necessary to identify which state programs need additional guidance to

achieve agency goals. OSHA’s 10 regional offices, which are responsible

for monitoring state consultation program expenditures, have inconsistent

policies concerning when, and under what circumstances, they conduct

audits of the state consultation programs. We found that some regional

offices conducted annual financial audits of state consultation programs in

their jurisdiction, while others had not audited state programs under their

jurisdiction for as long as 5 years. As of August 2001, seven OSHA regional

offices had not audited 17 state consultation programs under their

jurisdiction for over a year. For example, Region 3 (Philadelphia) had not

audited the Maryland consultation program ($682,000 budget in fiscal year

2000) for 5 years. OSHA Region 9 (San Francisco) had not audited the

largest program, California ($4.45 million budget in fiscal year 2000), in 2

years. Region 9 also had not audited the Guam and Hawaii programs in 2

years, despite knowing about the significant management and fiscal

difficulties these programs have. Because the relative amounts provided to

OSHA’s Oversight of

Financial Expenditures Is

Limited and Inconsistent
Page 20 GAO-02-60 Review of OSHA's Consultation Program

each state for the consultation program are small in comparison with

other federal programs, the expenditure of these funds is also not likely to

be audited by any other entity.19 OSHA officials said they have not

provided guidance to regions on the appropriate interval between routine

financial audits or the conditions that might warrant an out-of-cycle audit.

OSHA officials also said that they would like the regions to conduct more

audits but the decline in staff resources in the field has adversely affected

the regions’ ability to do so.

OSHA’s regional offices also do not have access to financial data

demonstrating how state consultation programs spend federal funds by

object class (i.e., salaries, fringe benefits, travel, equipment, supplies,

contracts, and other expenses) unless they conduct an audit or obtain

special authority from the Office of Management and Budget (OMB) to

routinely collect this information.20 At the beginning of each fiscal year,

state consultation programs report how they plan to spend the funds by

object class; however, there is no requirement to provide a detailed report

showing how the funds were actually spent. Instead, they are required to

report quarterly and yearly a single figure showing only total expenditures.

OSHA officials said they would like to collect detailed information on

expenditures to improve monitoring. We found that most of the state

consultation programs we contacted had this information readily available

and did not believe it would be an onerous requirement to provide it

routinely to OSHA. To date, OSHA has not petitioned OMB to collect this

information.

Because OSHA’s regional offices do not have ready access to detailed

information on expenditures, they cannot readily monitor the actual use of

funds or state reprogramming of funds from one object class to another.

This could lead state programs to deviate from agreed-upon spending

patterns without informing OSHA or, potentially, to use funds for

inappropriate purposes. For example, of the 12 programs that experienced

 19For example, under the Single Audit Act (31 U.S.C. 7501 et seq.), any state spending

$300,000 or more in federal awards is responsible for arranging a financial audit of its total

federal accounts. Although the states must provide to auditors a total listing of all federal

grants, auditors have some flexibility in determining which programs to evaluate in detail.

Since 1997, only four state consultation programs have been included in detailed audit

analyses performed under the Single Audit Act.

20OMB Circular A-102 requires grantees to file summary financial status reports with their

funding agencies. However, detailed reporting by object class is prohibited unless OMB

grants a waiver.
Page 21 GAO-02-60 Review of OSHA's Consultation Program

declines in their level of activity from fiscal years 1996 to 2000 and

provided us with information on actual expenditures, half reported that

they reprogrammed at least 20 percent of the funds they originally

projected to spend on salaries and benefits to other spending categories in

at least 1 fiscal year. There is insufficient information to know whether

these activities violated program requirements or resulted in inappropriate

expenditures.

However, in some cases, it appears that staffing or other long-standing

limitations at the state level could raise questions about the basis for the

state consultation program’s original funding request. For example, in

some cases, state-imposed hiring or salary freezes had been in place for

years, which made it unlikely that vacancies could have been filled.

However, state program officials continued to request funds to fill these

vacancies. When the vacancies were not filled, they reprogrammed these

funds into other areas. While state consultation programs must comply

with federal review procedures to reprogram federal funds, regional office

officials stated that these were not entirely effective tools for keeping up

with such actions by state programs. As a result, OSHA lacks information

on the extent to which state programs are using the funds or potentially

reprogramming them into other areas, and it does not know whether state

programs are using the funds in the best way to achieve agency goals.

Two large consultation programs illustrate the potential problems caused

by this lack of oversight. Both programs experienced decreases in

program activity between fiscal years 1996 and 2000 and appeared to

reprogram large amounts of funding, not necessarily with the knowledge

of OSHA regional officials.

• For each of fiscal years 1996-2000, the first of these state consultation

programs submitted to OSHA budget projections that included over

$300,000 for indirect administrative charges, for a total of approximately

$1.76 million. However, end-of-year information on actual expenditures

showed that, for the 5-year period, this program spent approximately

$87,000 (or less than 5 percent) of the $1.76 million on indirect

administrative costs.

• Since fiscal year 1996, the second state consultation program had been

developing its planned expenditures on the assumption that the program

would be fully staffed. It did so with full knowledge that this was unlikely

to occur, given that the program was experiencing high and increasing

vacancy rates for consultants (37 percent in fiscal year 2000). As a result,

the program reprogrammed much of the federal funds slated for paying
Page 22 GAO-02-60 Review of OSHA's Consultation Program

salaries and benefits to consultants into supplies and equipment or

contracts to obtain promotional services. It also used some of the excess

personnel funding to make up for the shortfall in salaries and benefits paid

to existing staff who received higher than the minimum pay in their grade.

(According to officials with this consultation program, state agencies are

required to budget salaries and benefits as if all staff received the lowest

pay in their grades.)

Many believe that OSHA’s increased effort to emphasize cooperation

rather than confrontation—as signaled by the increase in funds to the

Consultation Program—is a move in the right direction. Yet OSHA has

made this commitment without establishing the performance

measurement system needed to determine how well the Consultation

Program contributes to OSHA’s central mission and resulting goals—

reducing workplace injuries and illnesses. OSHA does not know to what

degree it can rely on consultation activities to achieve these goals or the

extent to which it should use consultations in combination with its

enforcement activities. Having adequate goals and measurement systems

for the Consultation Program would allow OSHA to establish a link

between voluntary, cooperative efforts at employers’ workplaces and any

subsequent reductions in worker injuries and illnesses at those

workplaces and potentially increase the value of the program for

employers and workers.

Although OSHA is in the process of updating IMIS, these efforts, in

themselves, will not improve the agency’s ability to assess the

Consultation Program’s performance, reduce the reporting burden faced

by program managers, or address the confusion that results from

programs having too many indicators to track. Without assessing the kind

of information it needs to measure the Consultation Program’s progress

toward attainment of basic agency goals and including state program

managers in this process, OSHA will be unable to identify those indicators

that provide the best measure of program performance and eliminate

those that pose an unnecessary burden on consultants. Moreover, it will be

unable to focus state consultation programs on those activities that best

match the agency’s priorities.

OSHA has not used its funding allocation process to influence the

activities of state programs. In the absence of a link between a state

consultation program’s performance and its funding, state programs have

continued to receive funds equal to what they have received in previous

years even if they reduced the number of consultations they conduct and

the number of hazards they identify. Large programs will continue to be

Conclusions
Page 23 GAO-02-60 Review of OSHA's Consultation Program

rewarded the lion’s share of funding simply because they are large, rather

than because they are successful. Factoring a program’s performance into

the allocation process is no easy task, nor can it necessarily be

accomplished within a short time frame. However, it is very much in line

with the GPRA goal of encouraging agencies to be results oriented and to

ensure that the Consultation Program, as part of OSHA, is doing what it is

supposed to do. Without a link between funding and performance, there

can be no assurance that federal funds are working toward the

achievement of agency goals.

With regard to financial oversight, OSHA has insufficient knowledge about

how program funds are being spent. In the absence of clear guidance from

OSHA regarding what factors warrant financial audits, the frequency with

which regional offices audit state consultation programs will continue to

vary. Moreover, programs that are known to have significant fiscal and

management problems, significant declines in program activity, or who

request funds each year for one purpose and then reprogram them for

another, will be able to continue these practices unchecked. OSHA may

have the opportunity to collect the necessary expenditure information

without auditing state programs, but such action may need approval from

OMB. Correcting these problems is challenging because doing so requires

determining how much of the agency’s limited oversight resources should

be devoted to ensuring that funds are spent properly, even when the

amount of these funds might be relatively small. However, without such

information, OSHA is unable to show itself or others how well state

consultation programs are utilizing federal funds.

To strengthen OSHA’s ability to assess the Consultation Program’s

progress toward key agency goals, we recommend that the Secretary of

Labor direct the Assistant Secretary for Occupational Safety and Health to

• require state consultation programs to collect and forward to OSHA data

on injuries and illnesses from employers participating in the Consultation

Program at some period after the consultation is completed for use in

analyzing whether there is a relationship between participation in the

program and reductions in workplace injuries and illnesses and

• review reporting requirements with an eye toward eliminating indicators

that no longer reflect the program while adding new ones that do.

Decisions about which indicators to eliminate or develop should be driven

by the kind of information needed to measure progress toward goals and

send a clear message to state programs on agency priorities. Any decisions

should be accomplished in cooperation with state program managers and

Recommendations for

Executive Action
Page 24 GAO-02-60 Review of OSHA's Consultation Program

should ultimately contribute to reducing the reporting burden on state

consultation programs. This process should be a key component of any

upgrade the agency performs on IMIS.

To help OSHA ensure that the funding allocation process encourages state

consultation programs to work toward agency goals, we recommend that

the Secretary of Labor direct the Assistant Secretary for Occupational

Safety and Health, in cooperation with state partners, to develop a plan

and timetable for factoring incentives into the allocation process. In so

doing, OSHA may want to (1) develop performance goals for inclusion in

the allocation formula or (2) set aside up to 20 percent of consultation

funds for distribution by the Secretary in accordance with separate criteria

that reward good performance or address specific state program needs.

To help ensure better oversight of state expenditures of consultation

funds, we recommend that the Secretary of Labor direct the Assistant

Secretary for Occupational Safety and Health to

• provide specific guidance to the regional offices regarding the monitoring

of state-level expenditures of Consultation Program funds that includes

criteria or situations under which regional offices should review program

spending or conduct audits of expenditures and

• seek to routinely obtain program expenditure data by object class from

state consultation programs, either through conducting more frequent

financial audits or by obtaining the necessary authority from OMB.

OSHA generally agreed with our recommendations and said the report

would help improve the Consultation Program (see app. I). OSHA’s most

significant concern with the draft report related to the extent to which it

should be held accountable for measuring the Consultation Program’s

contribution toward achieving GPRA performance goals. Among other

things, OSHA stated that it did not believe that GPRA requires annual

measurement of individual programs’ contributions toward meeting these

goals. As such, OSHA noted that it had chosen to evaluate the effect of its

entire complement of programs (consultation, enforcement, and others)

on achieving performance goals related to reducing workplace injuries and

illnesses.

We did not examine whether OSHA was technically in compliance with

GPRA requirements. However, regardless of the answer to this question,

we believe that it is important for OSHA to know the extent to which the

Consultation Program is contributing to the agency’s primary mission. This

type of information is central to managing the agency’s resources. As such,

Agency Comments
Page 25 GAO-02-60 Review of OSHA's Consultation Program

we were pleased to note that OSHA acknowledged the need to find

opportunities to evaluate the effectiveness of its individual programs.

OSHA suggested a number of technical changes to improve the accuracy

of our report, which we incorporated as appropriate.

We are sending copies of this report to appropriate congressional

committees, the Secretary of Labor, the Assistant Secretary of Labor for

Occupational Safety and Health, and the Director of OMB. We will also

make copies available to others upon request.

Please contact me or Lori Rectanus on (202) 512-7215 if you or your staff

have any questions about this report. Other contacts and staff

acknowledgments are listed in appendix II.

Robert E. Robertson

Director, Education, Workforce,

 and Income Security Issues
Page 26 GAO-02-60 Review of OSHA's Consultation Program

List of Recipients

The Honorable Edward M. Kennedy

Chairman

The Honorable Judd Gregg

Ranking Member

Committee on Health, Education,

 Labor, and Pensions

U.S. Senate

The Honorable Paul Wellstone

Chairman

The Honorable Michael Enzi

Ranking Member

Subcommittee on Employment,

 Safety and Training

Committee on Health, Education,

 Labor, and Pensions

U.S. Senate

The Honorable John A. Boehner

Chairman

The Honorable George Miller

Ranking Minority Member

Committee on Education and the

 Workforce

House of Representatives

The Honorable Charlie Norwood

Chairman

The Honorable Major Owens

Ranking Minority Member

Subcommittee on Workforce Protections

Committee on Education and the

 Workforce

House of Representatives
Appendix I: Comments From the Occupational Safety and Health Administration

Page 27 GAO-02-60 Review of OSHA's Consultation Program

Appendix I: Comments From the

Occupational Safety and Health

Administration

Note: GAO comments

supplementing those in

the report text appear at

the end of this appendix.

See comment 1.
Appendix I: Comments From the Occupational Safety and Health Administration

Page 28 GAO-02-60 Review of OSHA's Consultation Program

See comment 2.
Appendix I: Comments From the Occupational

Safety and Health Administration

Page 29 GAO-02-60 Review of OSHA's Consultation Program

The following are GAO’s comments on the OSHA letter dated September

26, 2001.

1. We clarified report language concerning the purpose of this study.

2. We modified our recommendation to recognize the importance of state

participation in deliberations leading to changes in the funding

allocation process.

GAO Comments
Appendix II: GAO Contacts and Staff

Acknowledgments

Page 30 GAO-02-60 Review of OSHA's Consultation Program

Lori Rectanus (202) 512-7215

Joseph J. Natalicchio (202) 512-7215

In addition to those mentioned above, Patrick J. diBattista, Dennis M.

Gehley, Julian P. Klazkin, Leslie E. Pastrano, John G. Smale, Jr., and

Wayne J. Turowski made key contributions to this report.

Appendix II: GAO Contacts and Staff

Acknowledgments

GAO Contacts

Staff

Acknowledgments

(130015)
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