Benefits of the OSHA 

On-Site Consultation 

Program 

An Economic Analysis

Working Paper

August 1, 2018
1

Introduction

The Occupational Safety and Health Administration (OSHA) On-Site Consultation 

(OSC) Program has existed in several formats since 1975, yet OSHA has only recently 

begun efforts to quantify the impact of the program. To supplement the case studies and 

employer testimonials showing the positive impact that OSC has had on employers across 

the country, OSHA has developed preliminary quantitative estimates of the societal 

benefits from the OSC Program. The following paper represents research in progress and 

may be updated as additional benefits arise.

What Is the On-Site Consultation Program?

The OSHA OSC Program provides no-cost and confidential occupational safety and

health services to small- and medium-sized businesses1 in all 50 states, the District of 

Columbia, and several U.S. territories. The consultation program helps employers reduce 

the likelihood of workplace injuries and illnesses by working with them to identify and 

correct workplace hazards, provide advice for compliance with OSHA standards, and 

assist in establishing and improving safety and health programs. Priority is given to highhazard worksites.

2 This program operates separately from OSHA enforcement efforts. 

However, employers must agree to correct any serious and imminent danger hazards 

identified in a timely manner.

Although largely funded by OSHA, the OSC Program is administered by local agencies

or universities. Because the OSC Program is voluntary, requests for an on-site 

consultation are always initiated by the employer. After an employer makes a request, 

and the consultation visit is scheduled, the consultant travels to the worksite to evaluate 

potential hazards, work practices, and the employer’s safety and health program. At the 

end of the visit, the consultant discusses findings with the employer and recommends

improvements. All serious and imminent danger hazards that are identified must be 

 1 Small establishments are defined by OSC as those with 250 or fewer employees on-site, and fewer than 

500 employees corporate-wide. Medium-sized establishments are also defined as those with 250 or fewer 

employees on-site, but with 500 or more employees corporate-wide. Establishments with more than 250 

employees on-site or more than 500 employees corporate-wide can also receive visits under the OSC 

Program. These size definitions are used internally by OSC and do not necessarily correspond to other 

Department of Labor establishment size categories. 

2 A “high-hazard worksite” is one that meets one of the following criteria: 

• Has a days away from work, days of restricted work activity, or job transfer (i.e, DART) rate that 

is above the national average for that industry; 

• Is in a NAICS industry that is on the OSHA-generated listing of high-hazard industries (i.e., 

Annual OSHA High Rate Industries Listing);

• Has one or more hazardous work processes or work areas (secondary NAICS code that appears on 

the High Rate Industries Listing) but is in an industry that is not on the high-hazard list;

• Meets an alternate definition developed by the state and approved by OSHA; or 

• Has a large number of hazardous operations required to complete a work process and that cannot 

be described by a secondary NAICS code. (See OSHA, 2015 for more information.) 
2

corrected within a specific time period agreed upon by the consultant and the employer, 

but no fines or penalties are assessed as a result of the visit. 

During a consultation visit, the consultant completes a workplace audit to identify 

hazards and assess the employer’s safety and health program using OSHA Form 33, 

Safety and Health Program Assessment Worksheet, which identifies 58 attributes 

distributed into seven safety and health program elements, including:

• Management Leadership

• Worker Participation

• Hazard Anticipation and Detection

• Hazard Prevention and Control

• Planning and Evaluation

• Administration and Supervision

• Safety and Health Training

The consultant evaluates the employer’s safety and health program, identifies program 

deficiencies, and suggests corrective measures and areas for improvement.

Based on OSC Program data, between FY 2012 and FY 20163

, 28,514 establishments in 

the private sector received services through the OSC Program each year, on average, and

these establishments employed a total of approximately 1.26 million employees. Table 1 

shows the number of establishments that received services by size. 

Table 1. Establishments That Received On-Site Consultation Services

by Establishment Size, FY 2012 – FY 2016*

Establishment Size Category 

by Number of Employees** Establishments Employees

1 to 25 15,718 97,550

26 to 100 9,022 270,798

Over 101 3,774 892,584

Total 28,514 1,260,932

*Excludes FY 2014, see fn 3

** See fn1 for explanation

Source: OSC Program Performance Summary (FY 2017)

Estimating the Value of the On-Site Consultation Program

OSHA set out to determine the annual economic value to society, in general, and to 

workers and employers, specifically, from injuries and illnesses prevented by the 

interventions provided through the OSC Program. Economic benefits to workers are 

 3 This analysis averages four years of data from the OSC Program between FY 2012 and FY 2016 and 

excludes data from FY 2014 because a lengthy government shutdown at the beginning of that fiscal year 

affected the OSC Program’s ability to conduct consultation visits.
3

realized through prevented injuries and illnesses and include factors such as reduced pain 

and suffering, a decrease in lost income (above and beyond that compensated by workers’ 

compensation), and avoidance of the dislocating effects of permanent partial disabilities. 

Worker benefits were calculated via the willingness to pay (WTP) to avoid risk method, 

which is preferred by economists for this purpose. Fewer injuries also mean less money 

paid out by the workers' compensation system, so these reduced payments are considered 

a benefit as well. These reduced payments are not savings directly realized by employers,

but reduced workplace injuries and reduced payments from the workers' compensation 

system will eventually lead to reduced premiums for employers. In this study, savings to 

the workers' compensation system are accounted for separate from savings to employers. 

Economic benefits to employers include the avoidance of various indirect costs 

associated with workplace injuries, illnesses, and deaths. Such indirect costs include loss 

of productivity, the cost of hiring and training replacement workers, property damage, 

and time spent on administrative tasks such as accident investigations or filing claims.

To date, no empirical studies examining the effects of OSC Program visits on injuries and 

illnesses have been conducted. To estimate the societal benefits of the OSC Program, 

OSHA examined programs similar to OSC that have been evaluated for effectiveness.

Evaluations have found that safety and health programs, as well as OSHA enforcement 

inspections, reduce injuries (see for example, Smitha et al. 2001), and the magnitude of 

these reductions forms the basis for estimating the benefits of the OSC Program from

reducing injuries. 4 OSHA has identified three approaches to estimating the number of 

injuries prevented by the OSC Program – to treat OSC visits as a(n): 

1. One-time, one-year safety and health program

2. Hazard-reduction exercise; or

3. OSHA enforcement inspection.

Based on these three approaches, OSHA derived a range of estimates of the number of 

injuries prevented by OSC Program visits. These estimates are based entirely on 

avoidance of OSHA recordable injuries and illnesses and do not measure the value of 

fatalities avoided or chronic illnesses avoided. The existing empirical studies are simply 

not of large enough scale to detect statistically significant differences in numbers of 

fatalities, nor to detect differences in the incidence and fatalities from chronic illnesses. 

As a result, the benefits estimated in this paper are likely underestimated, because they 

exclude important sources of benefits.

Consistent with the Office of Management and Budget Circular A-4, OSHA assessed the 

value of avoided injuries using a WTP method, where the value is derived from the 

willingness of affected individuals to pay to avoid a marginal increase in the risk of a 

non-fatal injury. Workers place an implicit value on occupational injuries avoided, which 

 4 OSHA is examining injuries, rather than fatalities and occupationally acquired chronic illnesses, because 

data are more readily available, and the short-term nature of the OSC Program (and similar interventions) 

makes it difficult to link avoided chronic illnesses back to the program activities. 
4

reflects their willingness to pay to avoid monetary costs (for medical expenses and lost 

wages) and quality-of-life losses as a result of an occupational injury. OSHA estimated 

the value of avoided injury at $77,000 per case (in 2015 dollars, which reflects the low 

end of estimates developed by Viscusi and Gentry, 2015).

Employer benefits are described in terms of workers’ compensation savings. Typical 

workers’ compensation injuries cost insurers about $30,526 each, on average, based on 

the total program costs for workers’ compensation and the total number of reportable 

injuries in the private sector (Baldwin and McClaren, 2016; Bureau of Labor Statistics 

(BLS), 2013).

5 These will not be direct savings to the employer but to the workers’ 

compensation system; however, the savings will eventually be realized to some extent by 

employers as insurance premium savings. 

OSHA also estimated the benefits to employers of avoided indirect costs from

occupational injuries, which include costs of hiring and training replacement workers, 

administrative costs, and lost productivity. The estimate used is from a Business 

Roundtable publication, Improving Construction Safety Performance, and is based on a 

study conducted by the Stanford University Department of Civil Engineering (OSHA, 

2017). While the magnitude of indirect costs is inversely related to the seriousness of the 

injury, for the purposes of this analysis, OSHA used the lowest estimated ratio from the 

Business Roundtable publication and estimates that the indirect costs are equal to 110 

percent of direct costs considered to be the cost of a workers’ compensation injury.

6

For this analysis, OSHA used a rate of 3.0 injury cases per 100 equivalent full-time 

workers in private industry, as estimated by the BLS for 2015 (BLS, 2016). Based on this 

rate, and the number of workers who are covered by consultation services on average, 

OSHA estimated that there are potentially 37,828 injuries annually among the workers 

whose workplaces received consultation services. Given that the OSC Program targets 

high-hazard industries, using the average injury and illness rate for all firms likely 

underestimates the potential benefits of the program.

Applying these values of avoided injuries to an estimate of the number of avoided 

injuries that result from OSC Program visits, OSHA estimated the value of the OSC 

Program, using the three approaches listed above and described in detail below. 

The Safety and Health Programs Approach

Safety and health programs have been proven to substantially reduce the number and 

severity of workplace injuries and illnesses and the associated financial burdens on U.S. 

workplaces. Employers can use safety and health programs to establish and maintain 

 5 This value is derived by taking the total cost of the workers compensation system in 2013 of $91.8 billion 

(NASI, 2016) divided by the number of recordable injuries - 3,007,300 (BLS, 2013) - which yields a 

workers’ compensation cost per injury of $30,526.

6 The estimated indirect cost ratio ranges from a high of 4.5 for injuries with direct costs of less than $3,000 

(i.e., the indirect costs are 450 percent of direct costs) to 1.1 for injuries with direct costs greater than 

$10,000. See OSHA, 2017 for more information. 
5

processes to identify and control hazards in the workplace, with the goal of reducing risk 

and preventing occupational fatalities, injuries, and illnesses. 

Safety and health programs are built on a set of common sense pillars, including:

• Management commitment to safety and to finding and fixing hazards.

• Worker participation in all aspects of the program and are encouraged to report 

any hazards or concerns.

• Hazards that are identified are addressed expeditiously, with an emphasis on 

eliminating the hazard entirely. 

• Goals for the program are set every year, and progress towards these goals is 

monitored and reported. 

OSHA previously published a white paper outlining the key features of safety and health 

programs and examining the evidence of their effectiveness (OSHA, 2012). More 

recently, OSHA published the Recommended Practices for Safety and Health Programs, 

a guide to help employers and workers implement their own program (OSHA, 2016). 

Numerous studies found strong evidence of the effectiveness of safety and health 

programs. The 1991 Texas Extra-Hazardous Employer Program encouraged firms with 

injury rates substantially higher than the industry average to adopt safety and health 

programs. An analysis of that program found firms that completed the program reduced 

their injury rate by between 49 and 77 percent (LaTourrette and Mendeloff, 2008). In a 

2012 review, OSHA found that safety and health programs in eight states that either 

required or provided incentives for employers to adopt a program lowered the injury and 

illness incident rate by between 9 and 60 percent (OSHA, 2012). Based on this analysis, 

OSHA estimated that safety and health programs can help reduce injuries 15 percent to 

35 percent for employers who newly implement a safety and health program (OSHA, 

2012). 

For the purposes of this paper, OSHA selected the midpoint of that range and estimated 

that a fully implemented safety and health program can lower injury rates by 25 percent

in the first year the program is implemented. If a consultation visit produces results 

similar to those seen when employers implement a safety and health program, the OSC 

Program could prevent 9,457 injuries each year (see Table 2). Using $77,000 as the value 

of an avoided injury, the benefits to workers from the injuries avoided as a result of the 

OSC Program, using the safety and health program approach, could total about $728 

million per year.

In addition, the cost savings to the workers’ compensation system would be about $289 

million per year, and the value of the indirect costs avoided (using the estimated value 

discussed above, where indirect costs are equal to 110 percent of the direct costs) would 

be about $318 million per year. Using this approach, the total benefits of the OSC 

Program are estimated to be $1.3 billion annually.
6

Table 2. Annual Benefits of the OSC Program: 

Safety and Health Program Approach

Covered Workers 1,260,932

Estimated Injuries per Year 37,828

Injuries Prevented by OSC Program Visits 9,457

Value of Avoided Injury per Injury $77,000

Benefits to Workers from Avoided Injuries $728,188,374

Workers’ Compensation Cost per Injury $30,526

Benefits to the Workers’ Compensation System 

from Reduced Claims $288,684,134

Benefits to Employers from Avoided Indirect 

Costs $317,552,547

Total $1,334,425,056

Limitations of the Safety and Health Program Approach

There are some limitations to the data on the effect of safety and health programs on the 

rate of workplace injuries; for one, the data usually measure results only from facilities 

that fully implement a safety and health program. This means that only facilities where 

management recognizes an opportunity to improve performance and supports safety and 

health programs are captured in the data on the effectiveness of the programs. While the 

exclusion of reluctant employers may affect the veracity of estimates of the benefits of 

safety and health programs when evaluating the potential effectiveness of statutorily 

imposed mandatory requirements for safety and health programs, the voluntary, 

employer-initiated nature of the OSC Program means that employers who receive OSC 

Program services are those that are committed to improving the safety of their 

workplaces. Therefore, the rates of reduction in injuries seen in the literature are likely 

representative of the rates of reduction in injuries from OSC visits. 

The data on safety and health program effectiveness also suggest a possible “regression 

to the mean;” in other words, after a few years, performance slides back to preintervention levels and the effects seen in the initial years disappear. Because this 

analysis is only considering the effects of one year of OSC Program activity and is not 

drawing any conclusions about the longer-term program effectiveness, the data on the 

initial effects of safety and health programs are adequate for the purposes of this study. 

Note that the estimated results presented in this paper are annual average numbers, and 

OSC Programs interact with employers and workers on a continual basis. Even if the 

effectiveness of the OSC Program at a given facility decreased once multiple years had 

passed since the employer’s interactions with the program, there are still sizeable benefits 

being realized annually as new workplaces engage with the OSC Program. 
7

Finally, to the extent that consultation visits result in long-term adoption of safety and 

health programs, this approach could underestimate the effects of consultation visits.

Hazards Removed Approach

An important aspect of each consultation visit is how the consultant helps the employer 

identify and control or eliminate hazards. OSHA Information System data revealed that 

from FY 2012 to FY 2016, the OSC Program identified an average of 109,582 serious 

and imminent danger hazards at the facilities they visited each year. Proactively abating 

workplace hazards has been shown to reduce injuries (see Mendeloff, 1996, for example); 

however, the quantitative relationship between hazards removed and the associated 

decreases in injuries is not well known. 

The best data on the relationship between hazard identification and decreases in injuries

comes from Mendeloff’s (1996) evaluation for OSHA of the Maine Top 200 

Experimental Targeting Program, which provided intensive, targeted workplace safety 

and health interventions to the 200 employers in Maine that had the most workplace 

injuries, based on workers’ compensation claims filed in 1991. The Maine Top 200 

program required employers to, among other things, conduct a baseline comprehensive 

survey of their facilities to identify hazards and submit a plan to abate those hazards. 

These activities were evaluated and monitored by OSHA. 

The 184 firms that participated in this program identified 98,500 hazards in their baseline 

surveys and reportedly had corrected more than half of those hazards by September 1994. 

By July 1995, the number of hazards identified had exceeded 174,000, with more than 

118,000 reportedly abated. Subsequently, firms in the Maine Top 200 program saw a 

significant decline in the number of lost workday injuries or illnesses (Mendeloff, 1996).

Based on the number of hazards identified and abated, and the decrease in reported 

injuries and illnesses in the Maine Top 200 study, OSHA estimated that for each 10 

hazards eliminated, one injury was avoided. Data published by Gormley and Balla in 

2007 show that, between 1991 and 1994, the number of injuries with at least one lost 

workday in Maine fell by 9,100, while the Maine Top 200 report measured at least 

50,000 hazards abated by mid-1994 and 118,000 hazards abated by 1995. OSHA 

assumed that about 90,000 hazards were abated by the end of 1994. Dividing 90,000 

hazards by 9,100 injuries gives a ratio of about 10 hazards remediated to one injury 

prevented. Since hazard identification and abatement are integral parts of the OSC 

process, it is reasonable to apply these reductions to facilities that receive services from 

the OSC Program. Based on OSC data for FY 2012 to FY 2016 that show that an average 

of 109,582 hazards were identified annually, this means that an average of 10,958 injuries 

may have been prevented by the OSC Program each year (see Table 3). 

Using these reductions and $77,000 per injury avoided, cost of a workers’ compensation 

injury, and ratio of indirect costs to direct costs discussed previously, OSHA estimated 

the following economic value of the benefits of the OSC Program: 

• Benefits to workers from avoided injuries: about $843 million.
8

• Benefits to workers’ compensation: about $335 million.

• Benefits to employers from indirect costs avoided: about $368 million. 

In total, this approach results in estimated benefits from the OSC Program of about $1.55 

billion annually.

Table 3. Annual Benefits of the OSC Program:

Hazards Removed Approach

Hazards Identified 109,582

Injuries Avoided 10,958 

Benefits to Workers from Avoided Injuries $843,777,550

Benefits to the Workers’ Compensation 

System from Reduced Claims $334,508,487

Benefits to Employers from Indirect Costs 

Avoided $367,959,336

Total $1,546,245,372

Limitations of the Hazards Removed Approach

Due to the uncertain relationship between hazards identified and removed and reductions 

in work-related injuries, this model is a somewhat less robust method for evaluating the 

benefits of OSC Programs. The data from the Maine Top 200 study clearly show a 

decrease in the number of reported lost-time injuries and illnesses over the five years 

evaluated. However, the decline may be related to reforms of Maine’s workers’ 

compensation system, economic factors such as increases in unemployment or changes in 

worker demographics, and potential under-reporting. There is also some evidence that 

more workers who were injured or became ill were being placed on light/restricted duty 

sooner and more frequently during the evaluation period of the Maine Top 200 program, 

which could have significantly decreased the number of injuries being reported to 

workers’ compensation, because they did not need to be reported (Maine Workers’ 

Compensation Board, 1997). 

Another concern with developing a causal relationship between hazards identified and 

reduced injuries was that the Maine Top 200 Program did not have a standard definition 

for what to include as a “hazard” on the employer’s self-reported hazard list. Some 

inspectors reported hazards on a very detailed level (e.g., every electrical outlet that did 

not work was counted as a separate hazard), while others reported hazards in a more 

general manner (e.g., electrical system deficiencies were listed as one hazard). Some 

inspectors identified many minor hazards that were unlikely to result in injuries (and 

therefore would be unlikely to reduce injuries when the hazards were abated), while 

others identified fewer, but more serious, hazards (which may have been putting workers 

at higher risk of injury; and thus abatement of such hazards may have been more likely to 

result in avoided injuries). This adds additional uncertainty to the effect that identifying 

hazards has on reducing injuries.
9

Finally, when looking at the ratio of hazards eliminated to injuries prevented, the data on 

this relationship are limited. If the hazard-injury relationship differs, then the economic 

value of OSC Programs would vary as well. For example, the analysis above assumed 

that one injury is prevented for every ten hazards abated. If, in fact, the actual abatement 

factor differs, then the effectiveness of the OSC Program would change proportionately. 

So while the available data suggest the 10-to-1 ratio is appropriate (ten hazards abated 

lead to one injury avoided), given the uncertainty in the data, this approach is less reliable 

than the safety and health program approach. 

The OSHA Enforcement Inspection Approach

OSHA enforcement program evaluations have found that employers’ injury rates fall in 

years following an OSHA enforcement inspection. Since the process of an OSHA 

inspection and a consultation visit share similar features—both aim to identify and abate 

workplace hazards—one could expect that consultation visits will reduce injury rates in 

subsequent years just as OSHA inspection visits do. Scholz, et al. (1990) found that a 10 

percent increase in enforcement activities reduces injuries by about one percent for large, 

frequently inspected firms. Haviland et al. (2008) estimated that firms with 20 to 250 

employees experience a 10 percent reduction in injury rates when they have an inspection 

with a penalty. Similar results have been found by Mendeloff and Gray (2005) and from 

analysis of the results of the Maine Top 200 program (Gormley and Balla, 2007). Based 

on these findings, OSHA hypothesized that OSC Program visits could have a similar 

effect on injury rates, i.e., a reduction of about 10 percent. 

From FY 2012 to FY 2016, OSC consultants visited private sector establishments with an 

annual average total of 1.26 million employees. Assuming a 3.0 percent injury rate (BLS 

2016), about 38,000 injuries could be expected to occur among those 1.26 million 

workers. If the OSC Program visits yield similar reductions in injuries in the year 

following the visit as OSHA inspections do, then the injury rates in the subsequent year 

would be 10 percent lower, meaning there would be about 3,800 fewer injuries and the 

OSC Program benefits would be as follows:

• Benefits to workers from avoided injuries: about $291 million.

• Benefits to the workers’ compensation system from reduced payments: about 

$115 million.

• Savings to employers from avoided indirect costs: about $127 million. 

Using this approach, the estimated total annual benefits of the OSC Program are about 

$534 million per year. 
10

Table 4. Annual Benefits of the OSC Program:

OSHA Enforcement Inspections Approach

Number of Employees Covered 1,260,932

Expected Annual Injuries 37,828

Injuries Prevented (10 percent) 3,783

Benefit to Workers from Avoided 

Injuries $291,275,350

Benefit to Workers’ Compensation 

System from Reduced Claims $115,473,654 

Benefits to Employers from Indirect 

Costs Avoided $127,021,019

Total $533,770,022

Limitations of this OSHA Enforcement Inspection Approach

Comparing consultation visits to OSHA enforcement inspections may not be a fair 

comparison. Inspections are, in general, very limited compared to the comprehensive 

scope of a consultation visit. Data from the OSC Program and OSHA enforcement 

inspection records show that OSC workplace evaluations find twice as many hazards as 

OSHA enforcement inspections do. OSC consultants have a lower threshold for 

classifying hazards as serious, in part because they do not issue citations or fines, which 

require compliance officers to collect additional evidence to support the citation. Since 

the program is voluntary and initiated by the employer, consultants usually have 

workplace records readily available and receive employer assistance in abating all known 

hazards. 

Employers who are subject to OSHA enforcement inspections may not be forthcoming 

with information that could open them up to additional citations and fines. OSC 

consultants conduct wall-to-wall inspections of facilities in order to identify and abate as 

many hazards as possible; OSHA inspection visits are narrower in scope and generally 

cannot address an entire facility when looking for violations. Finally, one of the aims of 

the consultation visits is to help employers improve their safety and health programs. 

This means that, even after the consultation has ended, worker safety will likely remain a 

priority, as employers continue to identify and abate new hazards. 

During OSHA enforcement inspections, the focus is not on program improvement, so the 

impacts of an inspection on injury rates and hazard identification and abatement are 

likely to be lower than the impacts of a consultation visit. Consultation visits likely yield 

a greater reduction in injury rates over the subsequent year than OSHA enforcement 

inspections do, which means that the benefits estimated by this method are well below 

the true benefits of the OSC Program. 
11

Conclusion

The three different approaches described above have varying degrees of comparability 

when it comes to estimating the effect and value of OSC Program visits. For all methods 

used, OSHA did not estimate the benefits of avoided fatalities, occupationally acquired 

chronic illnesses, and premature deaths due to occupationally acquired chronic illnesses. 

However, it is likely that the OSC Program has an impact on these incidents, as well as 

reducing injuries from traumatic accidents. These simple models also do not attempt to 

measure the ongoing effect that a consultation visit may have on injury rates. 

With those caveats in mind, OSHA estimates that the total value of the OSC Program is 

between $534 million (using the OSHA enforcement inspections method) to $1.5 billion 

(using the hazards removed method). While the estimated value of these benefits varies 

depending on which method is used, each method shows that there are significant 

benefits being derived from the program. Even at the low end of the estimated range, 

there are still thousands of workers who have likely avoided injury as a result of the OSC 

Program. 

Table 5. Total Annual Benefits of the OSHA On-Site Consultation Program 

(millions of dollars)

Safety and Health 

Program Approach

Hazards Removed 

Approach

OSHA Enforcement 

Inspections Approach

Benefits to Workers from 

Avoided Injuries $728 $844 $291

Benefits to the Workers’ 

Compensation System 

from Reduced Claims $289 $335 $115

Benefit to Employers from 

Avoided Indirect Costs $318 $368 $127

Total Value[a] $1,334 $1,546 $533

[a] Totals may not sum due to rounding

Regardless of which approach is used, the OSC Program reduces injuries and illnesses 

and produces hundreds of millions of dollars in societal benefits each year. The OSHA 

enforcement inspections approach likely underestimates the true value of the OSC 

Program. The hazards removed approach, while theoretically plausible, utilizes less 

reliable data and relies heavily on assumptions about the relationship between hazards 

removed and injuries prevented. The approach based on efforts to help employers 

implement a comprehensive safety and health program most closely tracks the OSC visits 

in form and function. Research has also shown that implementing a safety and health 

program helps reduce injury rates. Therefore, OSHA has determined that the best method 

to estimate the benefits of the OSC Program is the safety and health program approach, 

which estimates that the OSC Program produces benefits to workers, employers, and 

society of about $1.3 billion per year. 
12

Sources

Baldwin, Marjorie L. and C.F. McLaren, 2016. Workers’ Compensation: Benefits, 

Coverage, and Costs (2014 data). Retrieved March 29, 2017, from the National 

Academy of Social Insurance website: 

https://www.nasi.org/research/2016/workers-compensation-benefits-coveragecosts

Bureau of Labor Statistics, 2014. Employer-Reported Workplace Injuries and Illnesses –

2013. Retrieved on May 2, 2017 from the BLS website: 

https://www.bls.gov/news.release/archives/osh_12042014.pdf

Bureau of Labor Statistics, 2016. Employer-Reported Workplace Injuries and Illnesses –

2015. Retrieved on April 15, 2017 from the BLS website: 

https://www.bls.gov/news.release/pdf/osh.pdf

Foley, Michael, Z.J. Fan, E. Rauser, and B. Silverstein, 2012. “The Impact of Regulatory 

Enforcement and Consultation Visits on Workers’ Compensation Claims 

Incidence Rates and Costs, 1999-2008,” 55 American Journal of Industrial 

Medicine, pp. 976-990.

Gormley, William T. and S.J. Balla, 2007. Bureaucracy and Democracy: Accountability 

and Performance, 2nd Edition. Washington, DC: CQ Press, 2007.

Haviland, Amelia M., R.M. Burns, W. Gray, T. Ruder, and J. Mendeloff, 2008. What 

Kinds of Injuries Do OSHA Inspections Prevent? Retrieved April 10, 2017, from 

the RAND Corporation website: 

www.rand.org/pubs/working_papers/WR593.html

Haviland, Amelia M., R.M. Burns, W.B. Gray, T. Ruder, and J. Mendeloff, 2012. “A 

New Estimate of the Impact of OSHA Inspections on Manufacturing Injury Rates, 

1998-2005,” 55 American Journal of Industrial Medicine, pp. 964-975. 

LaTourrette, Tom and J. Mendeloff, 2008. Mandatory Workplace Safety and Health 

Programs: Implementation, Effectiveness, and Benefit-Cost Trade-Offs. Retrieved 

April 10, 2017, from the RAND Corporation website: 

http://www.rand.org/pubs/technical_reports/TR604.html

Maine Workers’ Compensation Board, Maine Bureau of Labor Standards, and Maine 

Bureau of Insurance, 1997. "Annual Report on the Status of the Maine Workers' 

Compensation System, 1997." Workers’ Compensation Board Documents. Paper 

56. Retrieved on March 30, 2017 from the Digital Maine website: 

http://digitalmaine.com/wcb_docs/56
13

Mendeloff, John, 1996. “A Preliminary Evaluation of the Top 200 Program in Maine.” 

prepared for OSHA.

Mendeloff, John, and W.B. Gray, 2006. “Inside the Black Box: How do OSHA 

Inspections Lead to Reductions in Workplace Injuries.” 27 Law & Policy 2, pp. 

219-237.

Office of Management and Budget, Circular A-4 Regulatory Analysis. 2003. 

OSHA, 2012. Injury and Illness Protection Programs. Retrieved on April 10, 2017 from 

the OSHA website: https://www.osha.gov/dsg/topics/safetyhealth/OSHAwhitepaper-january2012sm.pdf

OSHA, 2015. Consultation Policies and Procedures Manual. Retrieved on April 29, 

2017 from the OSHA website: 

https://www.osha.gov/OshDoc/Directive_pdf/CSP_02-00-003.pdf

OSHA, 2016. Recommended Practices for Safety and Health Programs. Retrieved on 

June 6, 2018 form the OSHA website:

https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.

pdf

OSHA, 2017. OSHA $afety Pays Program: Background of the Cost Estimates. Retrieved 

on April 6, 2017, from the OSHA website: 

https://www.osha.gov/dcsp/smallbusiness/safetypays/background.html

Scholz, John T. and W.B. Gray, 1990. “OSHA Enforcement and Workplace Injuries: A 

Behavioral Approach to Risk Assessment.” 3 Journal of Risk and Uncertainty, pp. 

283-305.

Smitha, Matt W., K.A. Kirk, K.R. Oestenstad, K.C. Brown, S.D. Lee, 2002. “Effect of 

State Workplace Safety Laws on Occupational Injury Rates.” Journal of 

Occupational and Environmental Medicine, 43.

Viscusi, W. and E. Gentry, 2015. “The Value of a Statistical Life for Transportation: A 

Test of the Benefits Transfer Methodology.” Journal of Risk and Uncertainty, 51, 

pp. 53-77.