Workplace Safety and Health: OSHA Could Improve Federal Agencies' Safety Programs with a More Strategic Approach to Its Oversight
Published: 2006-04-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Federal workers' compensation costs exceeded $1.5 billion in 2004, with approximately 148,000 new claims filed that year. Because of concerns for the safety of federal workers, as well as the costs associated with unsafe workplaces, GAO described the characteristics of federal agencies' safety programs and the implementation challenges they face, and assessed how well the Occupational Safety and Health Administration (OSHA) oversees and assists federal agencies' efforts to develop and administer their safety programs.
section_title: What GAO Found
paragraphs: Based on a survey of 57 agencies, GAO found that most agencies reported having at least one activity for each of the six components generally associated with a sound safety program--(1) management commitment, (2) employee involvement, (3) education and training, (4) identification of hazards, (5) correction of hazards, and (6) medical management (which includes having a return-to-work program for injured employees). However, agencies faced implementation challenges that cut across the components in the areas of data management, accountability, and safety resources. The survey results indicated that many agencies do not have automated systems for tracking elements of their safety programs, such as training. In addition, several of the agencies did not demonstrate that their managers are held accountable for maintaining effective safety programs. Finally, many agency officials stated that, due to limited resources, they often must depend on safety officers with limited professional safety experience. OSHA's oversight of federal agencies' safety programs is not as effective as it could be because the agency does not use its enforcement and compliance assistance resources in a strategic manner. Although inspections are one of OSHA's primary enforcement tools, it does not conduct many inspections of federal worksites or have a national strategy for targeting worksites with high injury and illness rates for inspection. Furthermore, although OSHA is responsible for tracking violations that agencies dispute and reporting any unresolved disputes to the President, OSHA does not track these disputed violations or their resolution. In addition, although OSHA is required to review agencies' safety programs annually and submit a report on them to the President each year, as of January 2006, the last report submitted was for fiscal year 2000. Finally, while OSHA has a range of compliance assistance programs designed to help agencies comply with its regulations and improve safety, these programs are not being fully utilized.

section_title: Letter
paragraphs: In the early to mid 1990s, five Yellowstone National Park employees were  killed in on-the-job accidents ranging from a snowmobiling accident to a  drowning. By the time the last death occurred, the Occupational Safety  and Health Administration (OSHA)—the Department of Labor agency  responsible for overseeing federal agencies’ safety programs—decided to  conduct a comprehensive inspection and identified over 500 violations at  the park. OSHA also worked with park officials to improve safety. As a  result, Yellowstone transformed its safety program and according to  Yellowstone officials, OSHA has deemed it a success. However, this  worksite represents only one of thousands of locations where federal  employees work. During the past decade, the number of executive branch  workers killed or injured in work-related accidents at federal worksites  has fluctuated, although the number has decreased overall. Over this  period, over 800 workers died from work-related accidents, with 47 deaths  occurring in 2004. Non-fatal work-related injuries declined over the first  half of this period and increased over the subsequent 5-year period, with  approximately 148,000 claims for injuries being filed in 2004. While the  number of injuries fluctuated, the costs of the claims for these injuries—  adjusting for inflation—remained constant for most of the decade and rose  slightly in 2004 to $1.5 billion. In view of these injuries and their affiliated  costs, you asked us to answer the following questions: (1) What are the  components of federal agencies’ safety programs and what  implementation challenges do they face? (2) How well does OSHA oversee  and assist federal agencies’ efforts to develop and administer their safety  programs?
To respond to your request, we focused on the executive branch because  OSHA has more oversight responsibilities with respect to these agencies  than it does for judicial and legislative branch agencies. We obtained  information using a data collection instrument from 57 safety managers for  agencies in the eight largest executive branch departments, which  represent about 80 percent of the federal workforce. The instrument  requested information and documentation on six components of sound  safety programs we identified from previous GAO work: (1) management  commitment, (2) employee involvement, (3) education and training, (4)  identification of hazards, (5) following up and correcting hazards, and (6)  medical management. We reviewed the information in the data collection  instrument and documentation that the agencies provided, assessing  whether the documentation supported the agency’s responses and  identifying the types of activities the agency conducted for each program  component. In addition, we conducted more detailed follow-up interviews  with safety officials from 12 of the 57 agencies surveyed. We also  interviewed employee representatives from 8 agencies and visited 5  federal worksites, most of which were identified by OSHA as having strong  safety programs. In addition, we obtained information on workers’  compensation claims from the Department of Labor’s Office of Workers’  Compensation Programs (OWCP). We also interviewed all 10 of OSHA’s  regional administrators and federal agency program officers and officials  in 10 area offices including the area director, a compliance safety and  health officer, and, in many cases, a compliance assistance specialist. In  addition, we examined OSHA’s inspection data from fiscal year 1995 to  2004 and reviewed, when available, the annual reports that the eight  largest federal departments provided to OSHA from 2000 to 2004. Finally,  we reviewed the reports on federal safety programs that OSHA provided to  the President during this time frame. For a more detailed explanation of  our methodology, see appendix I. We conducted our work between  November 2004 and February 2006 in accordance with generally accepted  government auditing standards.
subsections: section_title: Background
paragraphs: Congress passed the Occupational Safety and Health (OSH) Act in 1970 to  ensure safe and healthful working conditions for working men and  women, including federal employees. While OSHA was created to  administer the OSH Act, the act also gave federal agencies primary  responsibility for providing federal employees with working conditions  and workplaces that are free from safety and health hazards. The act  authorizes OSHA to set mandatory occupational safety and health  standards, rules, and regulations and to enforce their compliance. In turn,  each federal agency is required to establish and maintain a comprehensive  and effective occupational safety and health program that is consistent  with OSHA’s standards.
subsections: section_title: OSHA’s Role
paragraphs: OSHA’s Office of Federal Agency Programs within its Directorate of  Enforcement Programs has primary responsibility for overseeing federal  agencies’ safety programs. OSHA’s regulations and an Executive Order  establish its responsibilities for monitoring federal agencies’ programs.
OSHA uses two strategies to provide oversight of federal agencies’ safety  programs—enforcement and compliance assistance. OSHA’s enforcement  strategy includes inspections and evaluations of federal worksites that  help ensure that federal agencies are not violating any OSHA standards  and are complying with the requirements for their safety programs. In  addition, agencies are required to submit annual reports to OSHA on their  safety programs, which OSHA uses to prepare an annual report to the  President on federal agencies’ safety programs. OSHA’s compliance  assistance strategy consists of a range of programs intended to help  agencies improve their safety programs.
subsections: section_title: Enforcement
paragraphs: OSHA is authorized to conduct inspections of federal agency worksites  but, as figure 1 illustrates, inspections of federal worksites represent a  very small percentage of OSHA’s overall inspections.
Between fiscal years 2000 and 2004, less than 1 percent of OSHA’s  inspections were of federal worksites in executive branch agencies; the  remaining 99.5 percent were primarily of private-sector worksites. Federal  executive branch workers represented about 1.4 percent of the overall  U.S. workforce between 2002 and 2004.
Inspections are conducted by OSHA’s 80 area offices in its 10 regions.  Figure 2 shows the location of OSHA’s 10 regions.
OSHA categorizes inspections as those that are “programmed” and those  that are “unprogrammed.” Programmed inspections are those that OSHA  plans to conduct because it has targeted certain worksites for inspection  due to their potential hazards. Unprogrammed inspections are not  planned; they are prompted by actions such as complaints, accidents, and  referrals. OSHA has established a system of inspection priorities that  relate to these categories, with unprogrammed inspections being a higher  priority than programmed inspections. Top priority goes to imminent  danger situations in which death or serious physical harm could occur.
The next priority for OSHA inspectors is catastrophes and fatal accidents,  followed by complaints and referrals. Programmed inspections are OSHA’s  fourth priority. OSHA’s last priority is to perform follow-up inspections,  which are conducted to ensure that hazards identified during previous  inspections have been corrected. From fiscal years 2000 through 2004,  only 40 percent of OSHA’s inspections of federal worksites were  programmed. During the same period, 54 percent of its inspections of non- federal worksites were programmed.
OSHA is required to conduct comprehensive annual evaluations of the  larger or more hazardous federal agencies. Results of these evaluations  are summarized by OSHA in reports that include information from the  review of an agency’s safety policies and reports, as well as inspections of  the agency’s facilities and interviews with agency personnel.
In addition, OSHA is required to submit to the President an annual report  on the status of federal employees’ occupational safety and health. OSHA  uses reports submitted annually by federal agencies to OSHA on their  safety programs—along with the results of any evaluations it has  conducted of federal agencies’ safety programs—to prepare its annual  report to the President. The report should also contain recommendations  for improving agencies’ performance.
section_title: Compliance Assistance
paragraphs: OSHA’s compliance assistance strategy consists of several programs  available to federal agencies, although some programs have only recently  been offered to federal employers. OSHA also provides technical support  to federal agencies, such as conducting studies of accidents and the causes  of injuries and illnesses, and providing training of agencies’ safety and  health personnel. Two of OSHA’s compliance assistance programs—Field  Federal Safety and Health Councils and Agency Technical Assistance  Requests—specifically target federal agencies, while others are generally  available to both private- and public-sector employers. Compliance  assistance programs for private and public sector employers include the  Voluntary Protection Programs (VPP), alliances, and strategic  partnerships. Approval as a VPP site is OSHA’s official recognition of  worksites that have implemented exemplary safety and health programs.  The VPP was started in 1982 for private-sector companies but was  expanded to include federal agencies in 1997. The alliance program was  started in 2002 and includes organizations that have agreements with  OSHA to focus on training, outreach, and promoting awareness of safety  and health issues. The strategic partnership program was started in 1998  and consists of agreements between OSHA and employers to address  specific safety and health problems.
OSHA also has been responsible for helping implement Presidential  initiatives, with the most recent initiative being issued in 2004: the Safety  and Health and Return to Employment (SHARE) initiative. This initiative  directs agencies to set and adhere to both safety and workers’  compensation goals. Specifically, the initiative directs federal agencies to  achieve four goals: (1) reduce the overall case rate for these claims, (2)  reduce the lost-time rate—the number of employees who could not return  to work per 100 employees in the workforce, (3) improve the processing  time of workers’ compensation claims, and (4) reduce the lost production  day rate—the lost days due to injury or illness per 100 employees. OSHA  works with agencies in addressing the first two goals and helps them  calculate the rates monitored.
section_title: Role of the Federal Agencies
paragraphs: OSHA’s regulations establish the basic elements of executive agencies’  safety and health programs. According to the regulations, agencies’  programs must include provisions for  top management support, participation, and accountability;    safety and health policies, procedures, and standards;     goals and objectives;    worker involvement;     safety and health training of managers and workers;    collection of occupational injury and illness data;    self-inspection of workplaces and self-evaluation of the programs;    abatement of unsafe and unhealthful working conditions; and    adequate budgets, staff, and equipment and materials.
In conducting self-inspections, agencies must meet certain requirements.  Inspectors are required to be qualified to recognize and evaluate hazards  and suggest corrections, and they must conduct inspections of every  worksite at least once a year. According to the regulations, agencies  should conduct “sufficient” unannounced inspections and unannounced  follow-up inspections to ensure the identification and correction of  hazardous conditions.
Agencies must also report annually to OSHA on their programs. In  November 2004, OSHA issued a final rule amending the injury  recordkeeping and reporting requirements applicable to federal agencies.  Prior to this time, federal agencies were required to collect only injury  information related to workers’ compensation claims. OSHA revised the  recordkeeping requirements in order to improve the quality of the federal  recordkeeping system and to increase the utility of the data. Beginning in  January 2005, federal agencies were required to record injuries in the same  manner as private-sector employers and to apply new criteria to determine  whether an injury must be recorded. Specifically, a work-related injury  must be reported if, for example, it results in death, 1 or more days away  from work, restricted work, loss of consciousness, or a significant injury  or illness diagnosed by a physician. The regulations do not require that  this data be reported to OSHA. However, the regulations state that agency  heads must submit an annual report to OSHA, containing such information  as OSHA requests. At a minimum, these reports are to describe the  agency’s safety program and include, among other things, the agency’s  required self-evaluation findings. OSHA uses these reports, along with any  evaluations it has conducted to prepare its annual report to the President.
section_title: Six Components of a Sound Safety Program
paragraphs: Safety experts and federal safety agencies agree that, to build an effective  safety program, organizations must take a strategic approach to managing  workplace safety and health. This objective is generally accomplished by  establishing programs built upon a set of commonly recognized  components of sound safety programs, which, together, help an  organization lay out what it is trying to achieve, assess progress, and  ensure that safety policies and procedures are appropriate and effective.  Drawing from our prior work, a review of the literature, and OSHA’s  requirements, we identified six components often found in sound safety  programs: (1) management commitment, (2) employee involvement, (3)  education and training, (4) identification of hazards, (5) following up and  correcting hazards, and (6) medical management. Table 1 lists these  components, along with a description of their supporting activities.
section_title: Federal Workplace Trends
paragraphs: Over the last 10 years, the federal executive branch workforce has  changed in a number of ways, including its size, demographic  characteristics, experience levels, and types of occupations. During this  time, there was a 6 percent decrease in the federal workforce—from 2  million employees in fiscal year 1995 to 1.9 million in fiscal year 2004. In  addition, the average age of federal workers increased from 44 to 47 years  old and the average length of time in service increased slightly, from 16 to  17 years. Likewise, the average pay grade level of federal workers  increased from approximately GS-9 to about GS-10. Moreover, the  percentage of workers in professional and administrative positions  increased from 85 to 89 percent.
Federal employees encompass a wide range of professions, ranging from  low-risk occupations such as office workers to highly hazardous  occupations such as law enforcement positions. For example, at the U.S.
Marshals Service, duties of criminal investigators include seizing assets  and apprehending fugitives. In addition, U.S. Forest Service employees are  involved in a variety of potentially hazardous activities such as developing  laboratory products, managing recreational lands, and fighting wildland  fires, while inspectors with the Food Safety Inspection Service face daily  hazards such as exposure to the chemicals used to kill pathogens in meat.  Finally, employees at manufacturing operations such as at the U.S. Mint  and the Bureau of Engraving and Printing use industrial production  equipment such as forklifts and presses.
section_title: Injury and Illness Trends in the Federal Government
paragraphs: The impact of demographic changes in the makeup of the federal  workforce on the number of injuries they sustain is unclear. The number  of active workers’ compensation claims for work-related injuries declined  from approximately 154,000 claims in fiscal year 1995 to about 137,000  claims in fiscal year 1999.  However, these claims increased from  approximately 138,000 claims in fiscal year 2000 to about 148,000 claims in  2004, as shown in figure 3.
Although the severity of the injuries changed during this period, the types  of injuries that federal workers incurred remained the same. Despite the  fact that the number of traumatic injury claims decreased slightly—from  76,633 claims in fiscal year 1995 to 74,322 claims in fiscal year 2004, as a  proportion of total claims, traumatic injury claims increased slightly over  this same period. However, non-traumatic injury claims decreased by over  30 percent during this period—from 8,508 claims in fiscal year 1995 to  5,903 claims in 2004. In addition, the top five types of traumatic injuries  incurred by federal workers during this period ranged from sprains and  strains of ligaments, muscles, or tendons to lacerations. Over this same  period, the five most common types of non-traumatic injuries ranged from  hearing loss to back sprain or strain. See table 2 for a list of the five most  common types of traumatic and non-traumatic injuries federal workers  incurred from fiscal year 1995 to 2004.
While the size of the workforce declined, workers’ compensation costs for  federal employees remained fairly constant during the most recent 10-year  period, from about $1.54 billion in fiscal year 1995 to about $1.52 billion in  2004. In addition, the compensation per claim filed during this period  increased. For example, while there were about 1,800 fewer new claims in  fiscal year 2004 than there were in fiscal year 1995, the average  compensation per claim increased by 3 percent from fiscal year 1995 to  2004, with the average payment per claim rising from $9,958 in 1995 to  $10,242 in 2004. As shown in figure 4, the largest amount of workers’  compensation costs for federal workers paid from fiscal years 1995 to 2004  was for claims that were over 5 years old.
Finally, the proportion of payments for lost wages, death benefits, medical  costs, and rehabilitation have remained constant, with wage loss  compensation being the largest proportion (approximately 70 percent) of  workers’ compensation payments made from fiscal years 1995 to 2004.  (See fig. 5.)
section_title: Most Agencies Reported Having Many Safety Program Components, but Faced Common Implementation Challenges
paragraphs: Information reported by the 57 federal agencies illustrated various ways in  which agencies carry out activities within the six safety program  components—management commitment, employee involvement, training,  identification of hazards, correction of hazards, and medical management.  However, agency officials we surveyed and interviewed reported they face  a number of implementation challenges that cut across the components,  particularly in using automated systems, holding managers accountable  for maintaining an effective safety program, and making the best use of  their limited resources. Officials at these agencies also described measures  they have taken to overcome each of these challenges.
subsections: section_title: Most Agencies Reported Having at Least One Activity for Each Safety Program Component
paragraphs: All of the 57 agencies surveyed reported that their safety programs  incorporate activities for the management commitment component.  Activities supporting management commitment include setting goals for  the program and communicating from upper management to frontline staff  about the importance of the safety program. Fifty-five of the agencies  surveyed (96 percent) reported that they had established goals for their  safety and health programs, and all 57 agencies reported conducting  activities to communicate the importance of their safety programs to  employees, such as through newsletters and Web sites.
Almost all of the agencies we surveyed reported that they conduct  activities for two other components—employee involvement and training.  Most agencies reported having policies governing employees’ participation  in safety committees and reporting injuries and hazards. While 56 (98  percent) of the agencies provided procedures for employees to report  hazards, half of these procedures did not specify the right of employees to  report hazards anonymously, as required by an executive order.  Consistent with OSHA regulations, 56 of the 57 agencies reported that they  offer some type of safety training for their employees.
While many agencies identified a number of methods for identifying  hazards, fewer had comprehensive procedures for tracking whether  hazards are corrected—two additional components of safety programs.  Fifty-five (96 percent) of the agencies reported that they conduct OSHA- required inspections, which must be performed at least once a year, in  order to identify worksite hazards. However, although an executive order  requires employee representatives to participate in these inspections,  seven agencies (12 percent) reported not having any procedures for  informing employees of their role during safety inspections. Furthermore,  while most agencies reported having some procedures for following up on  inspections and ensuring that hazards are corrected, we found that the  procedures are not always adequate because a third of these agencies did  not specify a reasonable timeframe for correction, as required by OSHA.
Agencies reported having the fewest activities for the medical  management component. Eight agencies (14 percent) reported that they  do not have any procedures designed to ensure that an injured employee is  seen promptly by a physician. In addition, 12 agencies (21 percent)  reported they do not have programs for offering injured employees light or  restricted duty to help them return to work more quickly. Another 11  agencies reported having such programs but did not provide sufficient  documentation of them. For example, two agencies reported having  return-to-work programs, but the documentation they provided showed  that the programs had not yet been implemented. Although federal  agencies are not legally required to include these activities in their safety  programs, the failure to include them may limit the effectiveness of the  programs.
section_title: Common Implementation Challenges Include Data Management, Accountability, and Safety Resources
paragraphs: We found that agencies face some common challenges in implementing  their safety programs, particularly in using automated systems to manage  their programs, holding managers accountable for workplace safety, and  operating with limited resources.
subsections: section_title: Data Management
paragraphs: The use of automated systems presented challenges for many agencies.  Some agencies did not use such systems, while others cited difficulties in  identifying systems that would allow them to collect data relevant to their  safety programs. For example, 23 agencies (40 percent) reported that they  do not have automated systems to collect information on hazards that  have been identified and track whether they have been corrected in a  timely manner. In addition, 14 of the agencies reporting that they have  such a system (41 percent) either indicated that their hazard tracking  systems were not currently operational, or they did not provide sufficient  documentation to support the existence of such systems. Approximately a  quarter of the agencies surveyed reported that they did not have  automated systems for tracking safety training completed by their  employees. Furthermore, 34 agencies (60 percent) reported they did not  have an automated system for tracking the status of employees in light or  restricted duty return-to-work programs, and another 16 agencies did not  provide sufficient documentation of their systems. While federal agencies  are not required to use automated data systems, without such a system,  safety officials would have difficulty tracking broader trends such as  participation rates in light or restricted duty programs and the effect of  program participation on worker’s compensation costs.
Ten of the 12 agencies we reviewed in more detail reported challenges  with their automated systems, such as ensuring that these systems  collected appropriate data needed to evaluate the effectiveness of their  safety programs. For example, an official from the Tobyhanna Army Depot  told us that their computer technicians were in the process of designing a  hazard tracking program because no agencywide programs were available,  and off-the-shelf programs required too much adaptation to be practical.  She also developed a stand-alone spreadsheet to track all work-related  injuries because the systems available did not capture injuries that were  not recordable on the OSHA log (such as injuries requiring only first aid)  or injuries for which workers’ compensation claims are not filed.  Furthermore, a National Park Service official stated that entering safety  meetings and other non-traditional training methods into the agency’s  automated system is difficult because the system does not have data fields  for recording these activities. As a result, the agency has difficulty  determining the extent to which employees have been trained on many  safety issues.
Despite these challenges, several agencies told us they have started or are  in the process of implementing automated safety systems that will allow  them to collect and analyze data in order to better manage these safety  programs, including assessing the effectiveness of their programs. For  example, according to a Transportation Security Administration official,  the agency is developing a new injury tracking system that will link injury  and illness data with inspection data, allowing them to identify trends,  such as where injuries commonly occur and demographic characteristics  of injured employees. Similarly, officials with the Bureau of Engraving and  Printing said they are testing a medical management system that will  aggregate data from a number of different sources including the health  unit, safety investigation reports, and their workers’ compensation system.  Collecting these data will allow them to streamline the reporting process  and better track injury trends.
section_title: Accountability
paragraphs: Another challenge agencies face is holding managers accountable for  implementing effective safety programs. While 51 agencies (89 percent)  reported having policies that establish responsibility for workers’ safety  and health for all employees, 6 reported that they do not have such  policies, despite an OSHA regulation requiring them to establish these  policies for all management officials. Of the 51 agencies reporting having  such policies, 11 agencies did not provide sufficient documentation of the  policies. For example, one agency provided an Employee Performance  Plan, but there were no performance expectations related to safety  anywhere in the plan. Furthermore, although we asked the agencies to  provide copies of their performance appraisal review forms citing safety as  a rating element, only 16 agencies (28 percent) were able to do so.
Agency officials and employee representatives at 7 of the 12 agencies  selected for follow-up interviews cited further difficulties in maintaining  accountability throughout all levels of their organizations. For example, a  Veterans Health Administration employee representative reported that,  while there is a high level of commitment to safety at the headquarters  level, the message is diluted as it reaches lower levels of the agency. In  another example, the Defense Commissary Agency implemented a  program that requires regional safety managers to evaluate stores’ safety  programs. Agency officials stated that regional officials are expected to  follow up to ensure that stores make timely corrections, but are not  required to document when hazards are corrected. As a result, the agency  has little assurance that the safety of store employees is adequately  protected. In addition, according to an employee representative from the  Commissary, it is not always clear who is responsible for ensuring that  hazards are corrected.
Several agencies reported that they had developed ways to help ensure  that employees and managers are held accountable for agency safety  programs. For example, in order to address accountability issues within  the agency, the Veterans Health Administration initiated a program that  ties agency safety goals to performance ratings. Moreover, instead of  simply including safety as a general element of performance review, the  agency selects two to three specific safety program goals that change  every few years according to agency needs. Past goals have included  submitting workers’ compensation claims on time and reducing the  occurrence of needle stick injuries. According to agency officials, bonuses  for executive staff members are provided based on their progress in  meeting these goals. When significant improvement has been made in  these areas, safety officials set new goals—enabling continuous  improvement.
section_title: Safety Resources
paragraphs: Both agency and OSHA officials cited challenges in funding their safety  programs, although OSHA regulations require agencies to provide  adequate resources to implement and maintain these programs. One  agency official we interviewed reported difficulty identifying funding for  the agency’s safety program because safety funding is not specifically  designated as a line item in its budget. This lack of information on  available resources makes it particularly difficult to plan for long-term  safety issues, such as developing and providing training. For example,  officials with the National Park Service, which employs a large cadre of  seasonal workers, reported that the lack of itemized safety funds within its  budget makes it hard to develop their training plans. OSHA officials cited  the federal budget process itself as problematic because it requires federal  agencies to budget months in advance for safety-related equipment  purchases or other safety devices, long before they may have identified the  need for this equipment. This was corroborated by a U.S. Mint official who  reported that it is difficult to correct hazards that require a lot of capital  investment and planning.
In addition, a potential consequence of operating with limited resources is  the use of collateral duty safety officers—employees whose primary  responsibilities do not involve safety. Nearly all of the agency officials we  interviewed reported relying on these positions, which are typically filled  by employees who volunteer or are assigned by the agency. While some  agency officials reported their collateral duty officers were appropriately  trained, as required by OSHA, others reported that these officers have  limited knowledge or experience in safety. Some agency officials we  interviewed said that this lack of experience, as well as the limited amount  of time collateral duty officers are allotted for safety duties, has made it  difficult for these officers to learn all of the safety program requirements.  For example, according to a National Park Service official, collateral duty  officers at this agency typically spend about 10 percent of their time on  their safety responsibilities, and this may inhibit their ability to respond  effectively when safety concerns arise. Moreover, one Forest Service  official told us that collateral duty officers questioned the feasibility of  building safety programs with collateral duty officers, and was concerned  that the safety duties might detract from their primary job responsibilities.
Finally, 11 of the 12 agencies selected for follow-up interviews reported  that competing priorities make it difficult to manage their safety programs.  For example, a Food Safety Inspection Service official noted that  completing safety forms and fulfilling data requests can be a burden to the  agency’s overall mission of meat and poultry inspections. Similarly, an  employee representative at the Forest Service told us that, because safety  achievements are not typically recognized or rewarded—even though such  recognition is encouraged by OSHA regulations—supervisors focus on  meeting production targets rather than working safely.
Agencies identified a number of techniques for addressing the difficulties  associated with managing resources. For example, an official with a  National Park Service regional office said that they host monthly  conference calls with the collateral duty safety officers at several national  parks, which gives these individuals a chance to ask technical questions of  the regional safety officer and share effective practices among the parks.  These monthly calls also enable their collateral duty officers, who have  limited backgrounds in safety, to gain knowledge and experience over  time. Other agencies maximized their resources by collaborating with each  other. For example, one official with the Forest Service said that they have  an informal partnership with the Bureau of Land Management that allows  them to pool their resources by pursuing joint activities and sharing  offices and staff. One activity involved jointly developing and teaching an  accident investigation course and an off-highway vehicle course.
section_title: OSHA Provides Inadequate Oversight of Federal Agencies Because It Does Not Use Its Enforcement and Compliance Assistance Resources Strategically
paragraphs: OSHA’s oversight of federal agencies’ safety programs is not as effective as  it could be because it does not use its enforcement and compliance  assistance resources in a strategic manner. First, OSHA does not routinely  conduct inspections that target federal worksites with high injury and  illness rates. In addition, OSHA lacks procedures for tracking and  resolving violations disputed by federal agencies. Third, OSHA has not  conducted required evaluations of the larger or more hazardous agencies  in the last 6 years. Fourth, OSHA has not submitted its own annual reports  to the President in a timely manner, and they have not included an  assessment of each agency’s safety program, as required. Finally, while  OSHA has a range of promising programs for assisting agencies in  complying with its regulations and improving worker safety, not all of  these programs are being fully utilized.
subsections: section_title: OSHA’s Enforcement Strategy Does Not Include a Program for Targeting Worksites with High Injury Rates for Inspection
paragraphs: Unlike its enforcement strategy for private-sector employers, OSHA’s  oversight of federal worksites does not include a national program that  targets federal worksites with high injury and illness rates for inspection.  According to its internal guidance, OSHA is supposed to develop a list that  targets federal worksites for inspection. However, OSHA’s Office of  Federal Agency Programs has not developed such a list in over 5 years. In  the past, OSHA used workers’ compensation claims data collected by  OWCP to identify federal worksites with high numbers of injuries and  illnesses. Because of limitations in the data, however, it was difficult to  identify where each injury occurred and, therefore, use this information to  target federal worksites for inspection. OSHA officials at the national  office reported that they are working to start a new targeting effort but are  still facing the same difficulties in using workers’ compensation data to  select federal worksites for inspection.
As shown in figure 6, OSHA primarily conducts inspections of federal  worksites as a result of complaints.
Unprogrmmed inpection initited y complintOther nprogrmmed inpection (ccident, referr, etc.)
OSHA’s inspection data of federal worksites show that complaint  inspections generally result in few violations compared to targeted  inspections, which generally identify a greater number of serious  violations (see fig. 7). For example, over the last 10 years, unprogrammed  inspections, which are generally initiated by complaints, uncovered an  average of one serious violation per inspection, in contrast to an average  of four serious violations for programmed (targeted) inspections. The  small average number of violations for unprogrammed inspections is  driven by the fact that over half of these inspections result in no violations  being identified.
The new recordkeeping rule, which was implemented in January 2005,  requires federal agencies to begin collecting the same injury and illness  data as private-sector employers and could help OSHA develop its  targeting program, according to OSHA officials. Since the new rule  requires federal worksites to keep logs that include information that can  be used to calculate injury and illness rates, OSHA officials said these data  would be more useful in creating an effective targeting program than the  workers’ compensation data. While the new rule does not require federal  agencies to report injury and illness data to OSHA, OSHA officials said  they could target federal worksites for inspection in the same way they  target private-sector employers in industries with high injury and illness  rates for inspection. For its targeting program of private worksites, OSHA  surveys a sample of worksites in industries with the highest injury and  illness rates. The survey form requires employers to report on (1) the  average number of employees who worked for them during the previous  calendar year, (2) the total hours the employees worked during the  previous year, and (3) summary injury and illness data from their OSHA  logs. OSHA then uses this information to compute the worksites’ injury  and illness rates and sends those with relatively high rates a letter  informing them that they may be inspected. Finally OSHA develops a list  of worksites with high injury and illness rates to be targeted for  inspection. As an alternative to conducting a survey of federal worksites,  OSHA has the option of requiring federal agencies to report this  information in their annual reports to OSHA.
One of OSHA’s regional offices—which includes four area offices—and an  area office in another region developed their own targeted programs of  federal agency worksites using the workers’ compensation data. While  officials reported using the data has been difficult, they said that these  efforts have resulted in improved safety at federal worksites. In addition,  they reported that the agencies that were inspected have become more  aware of OSHA’s role and, in turn, have sought OSHA’s assistance in  improving their safety programs. Furthermore, agency officials whose  worksites have been selected for inspection have focused more attention  on safety and shared information, resulting in further improvements. For  example, at one worksite in Montana, Forest Service officials reported  that, after colleagues in Idaho told them OSHA had targeted federal  worksites in the state for inspection, they were reviewing their safety  programs and OSHA’s requirements in preparation for possible OSHA  visits.
Officials with OSHA’s national office said that they have encouraged  regions to develop their own programs targeting federal agencies for  inspection, but we identified some challenges that need to be addressed  before more regions can successfully develop these programs. For  example, one regional OSHA official reported requesting workers’  compensation data from the national office to start a targeting program,  but was told the national OSHA office did not have enough time to provide  the data requested. In addition, regional and area office OSHA officials  said that the ability to develop and maintain targeting programs depends  on the resources available. Besides the time and effort required to identify  worksites, they said the availability of inspectors is also a factor.  According to OSHA’s policies, OSHA inspectors’ top priority is responding  to imminent danger situations, followed by accidents, followed by  responding to complaints; conducting targeted inspections is a lower  priority.
section_title: OSHA Lacks a System for Tracking Disputed Violations
paragraphs: OSHA’s procedures for tracking violations disputed by federal agencies  differ from those for the private sector. Whereas private-sector employers  can dispute OSHA violations cited during inspections by requesting that  the violations be reviewed by an independent administrative law judge,  federal agencies must seek resolution with OSHA officials. In these  situations, federal agencies may first request an informal conference with  OSHA area office officials to discuss the violation in question. If the  dispute is not resolved, it is referred to the relevant OSHA region for  review and, if necessary, to OSHA’s national office.
While OSHA’s internal instructions require that area office and regional  officials be consulted in decisions made by national office officials and an  Executive Order requires OSHA to submit unresolved violation disputes to  the President, neither of these things appears to be occurring. Although  national office officials reported that there have not been any unresolved  disputed violations, and they have not had to report any unresolved  violations to the President in over 3 years, area office and regional staff  told us some unresolved disputed violations from federal agencies have  lingered for years. For example, a regional OSHA official reported that, in  another region, a federal agency was cited for violating a safety standard  that did not apply to that particular agency. The agency challenged the  violation, and the dispute reached the national office, where no decision  was made—leaving the violation unresolved for 7 years. Another OSHA  official reported a case in which the Bureau of Prisons refused to have  guards wear special gloves as required while conducting cell searches  because the guards thought the gloves would not provide them with  enough sensitivity to feel for objects hidden by prisoners. According to  this official, it was important for the guards to wear gloves during these  searches because of the danger of receiving needle sticks or cuts from  sharp objects. The case reached OSHA’s national office, but it chose not to  act on the case—leaving the guards at risk and the violation unresolved.
OSHA could not provide us with a list of all violations disputed by federal  agencies or the status of their resolution because it does not have a system  for tracking these disputed violations. OSHA officials at the national office  indicated that part of the reason the agency has not developed such a  system is because few federal agencies dispute violations. In addition,  according to these officials, disputed violations are resolved in a timely  manner. These officials reported that they seek to review cases in a similar  manner to the manner in which administrative law judges review private- sector employers’ cases and have considered using either a permanent or  ad hoc panel to ensure consistency in their review of violations disputed  by federal agencies. However, without a system for tracking violations  disputed by federal agencies, OSHA cannot ensure that all disputes have  been resolved or that they are resolved in a consistent manner.
section_title: OSHA Has Not Conducted Evaluations in More Than 6 Years
paragraphs: Although OSHA is required to conduct annual evaluations of the larger or  more hazardous federal agencies, and less frequent evaluations for smaller  and less hazardous federal agencies, it has not conducted any evaluations  since 1999. OSHA officials reported that because evaluations are so  resource intensive, they did not have enough staff to support doing them.  Evaluations are another element of OSHA’s enforcement strategy and  include both a national-level review of an agency’s safety program and  site-specific assessments. In the past, OSHA’s national office identified  federal worksites for evaluations and the area offices inspected them.  OSHA’s policies require agencies to correct any violations identified  during inspections conducted as part of its evaluations. In addition,  OSHA’s internal guidance encourages its officials to coordinate  evaluations with targeted inspections in order to use its resources more  efficiently.
The last evaluation that OSHA conducted, at the Veterans Health  Administration, resulted in a report that agency officials said they still use  to improve their safety program. While some OSHA officials told us that  evaluations are resource intensive and ineffective because agencies have  not always corrected the problems identified, other OSHA and agency  officials said OSHA’s evaluation of the Veterans Health Administration  helped bring management and union officials together for discussions  during the evaluation process. According to these officials, this improved  relationship continued after the evaluation was completed.
section_title: OSHA Has Not Submitted Timely Annual Reports on Agencies’ Safety Program as Required
paragraphs: As of February 2006, OSHA had not submitted its annual report to the  President that summarized and assessed the status of federal agencies’  safety programs since 2000 nor provided recommendations of ways for  federal agencies to improve their safety programs, as required. OSHA is  working to reduce the backlog for these reports, according to the officials  we interviewed. In addition, OSHA officials told us that they could not  assess the effectiveness of these programs or make recommendations  because they do not collect original data on agencies’ safety programs but,  instead, rely on the reports agencies provide to them on an annual basis.  According to these officials, they cannot assess or evaluate agencies’  programs without collecting independent information on their programs.  However, we believe that OSHA could use the information provided by the  agencies in their annual reports to assess agencies’ safety programs,  including whether they are meeting OSHA’s requirements. For example,  OSHA could use the agencies’ reports to determine what types of safety  and health training they are providing to their managers and workers, the  number and types of self-inspections they are conducting of their  workplaces, and the measures used to correct unsafe and unhealthful  working conditions identified during these inspections. In addition, OSHA  could use these reports to make recommendations for improvement.
OSHA requires agencies to summarize their injury and illness rates and  provide information on new initiatives they have started and their  accomplishments in their annual reports. However, OSHA officials told us  that they do not systematically review these reports over time to ensure  that agencies are making progress. Our analysis of the agencies’ reports  for fiscal years 2000 through 2004 showed that agencies generally  described the accomplishments of their safety programs but sometimes  repeated their safety goals across years. For example, one agency reported  in 2 consecutive years that it had “launched a new e-training program” that  included safety modules. In addition, agencies generally did not provide  any follow up information on their prior years’ goals or challenges. For  example, one agency reported having a goal to develop a database for  tracking injury and illness trends but made no mention of the system in the  following year’s report. One OSHA regional official suggested that the  national office could use regional staff more effectively by requiring each  region to review selected federal agencies’ annual reports. In this way,  regional staff could become more familiar with specific agencies’  programs, which would allow them to more readily identify discrepancies  and deficiencies in their annual reports.
section_title: OSHA Has Used a Variety of Compliance Assistance Programs for Federal Agencies, but None Is Widespread
paragraphs: Federal agencies can receive compliance assistance from OSHA through  programs developed especially for federal agencies as well as programs  initially developed for private-sector employers. The two compliance  assistance programs developed specifically for federal worksites—Field  Federal Safety and Health Councils and Agency Technical Assistance  Requests—have generally been helpful, according to OSHA officials, but  they are not consistently available to all federal agencies. Some of the  programs that OSHA initially developed for private-sector employers and  later expanded to federal agencies—the VPP, strategic partnerships, and  alliances—have not all been widely used by federal agencies. As of  January 2006, only 14 federal worksites had joined the VPP and OSHA had  established few strategic partnerships and alliances with federal agencies.  However, although only a limited number of federal worksites have used  these programs, OSHA officials told us many of these efforts have been  successful and they are encouraging more agencies to participate.
subsections: section_title: OSHA’s Regional Offices Have Struggled to Set Up and Maintain Field Federal Safety and Health Councils
paragraphs: Regions have anywhere from 2 to 13 active Field Federal Safety and Health  Councils, depending on the effort regional OSHA officials have made to  develop and maintain them. These councils, established by OSHA to  facilitate the exchange of ideas and information about occupational safety  throughout the federal government, consist of management and employee  representatives from local federal agencies. OSHA officials reported that  the councils are intended to provide a networking and training forum for  safety officials from different agencies in a given area, but all agreed that  maintaining the councils has been a struggle.
Both OSHA and agency officials cited challenges in maintaining the  councils. Some OSHA officials reported that federal agencies do not  always give their representatives time to attend the meetings. Other OSHA  officials raised concerns that federal agencies have failed to properly train  their collateral duty safety officials, which has inhibited their  contributions to the councils. In addition, some officials reported that  distance makes it difficult for council members to attend meetings. One  OSHA area director used the state’s library videoconferencing system to  bring together council members from different areas and suggested that  OSHA consider similar methods to encourage collaboration. On the other  hand, a couple of agency safety managers and OSHA officials told us the  councils are not necessarily an effective tool for agencies because the  safety concerns are so different among the agencies. For example, a  Department of Veterans Affairs’ safety manager might be focused on  preventing needle sticks and identifying violent patients, while National  Park Service safety staff might be concerned about snake bites and heat  exhaustion.
The councils also have limited financial resources. Funding is provided  solely by OSHA’s regional offices and is not a line item in their budgets.  While regions attempt to provide training to the councils, any budget  constraint can quickly eliminate their ability to do so. Until last year,  OSHA’s national office sponsored an annual conference and the regions  provided the travel funds for the council presidents to attend the  conference. However, the conference was canceled in fiscal year 2005,  partly because the national office did not have the funds to set up the  meeting and partly because the regions reported not having the travel  funds required.
section_title: OSHA’s Responses to Agency Technical Assistance Requests Are Sometimes Delayed
paragraphs: OSHA officials said they sometimes are reluctant to respond to Agency  Technical Assistance Requests, which can delay this assistance, because  they consume their limited enforcement resources. An agency can request  OSHA to provide advice on hazard abatement, training, or program  assistance. OSHA cannot cite agencies for violations during this process  but, in making the request, agencies understand they are expected to  correct any violations OSHA observes. While these requests for technical  assistance are considered part of OSHA’s compliance assistance strategy,  rather than enforcement, OSHA area offices and regions must use their  enforcement budgets and staff to conduct them. Because these offices  have limited enforcement resources, a regional OSHA official told us that,  although OSHA responds to all of these requests, this assistance may be  delayed.
section_title: Agencies Have Begun Joining OSHA’s VPP
paragraphs: As of January 2006, there were 14 federal worksites among the more than  900 private-sector worksites in OSHA’s VPP, which promotes effective  worksite safety and health. In general, OSHA and agency officials told us  the program is beneficial for federal agencies and they expect more  worksites to join. An agency official also said that having one federal  worksite join often is an impetus for others to consider applying to join the  program. For example, since the U.S. Mint in Philadelphia became a VPP  site in 2005, other agencies within the Department of Treasury have  considered joining. In addition, some OSHA field staff reported that they  are in the process of assisting agencies with their VPP applications. While  a few agency officials told us that the VPP was not feasible for agencies  because of the resources required, many told us they had worksites  seeking to join the program.
Some OSHA officials reported that federal agencies face unique challenges  in joining the VPP. For example, in order to participate, agencies must  have an injury and illness rate below the average within their given  industry. However, some agencies do not fit within a particular industry  code or definition. This was the case for Yellowstone National Park when  the worksite first applied to join the VPP. The park was required to classify  itself in an industry category that included amusement parks and  miniature golf courses, worksites with much lower injury and illness rates  than the park. The industry codes were recently changed and now include  a code for national parks, but Yellowstone is still challenged because its  injury and illness rates are higher than those of other parks such as  national monuments with many fewer hazards and injuries.
section_title: OSHA Has Developed Few Strategic Partnerships and Alliances with Federal Agencies
paragraphs: OSHA has developed relatively few strategic partnerships and alliances  with federal agencies, although OSHA officials said those that have been  formed have generally been beneficial to the agencies in improving their  safety programs. Strategic partnerships are agreements that employers  make with OSHA to address specific safety and health problems, while  alliances are agreements organizations make with OSHA to focus on  training, outreach, and promoting awareness of safety and health issues.  OSHA has created a limited number of strategic partnerships with federal  agencies at the national and regional level. At the national level, OSHA has  one partnership—an agreement with the Army created in October 2004  aimed at increasing awareness of safety, reducing ergonomic injuries, and  sharing best practices. At the regional level, OSHA has 7 current and 10  completed partnerships with federal agencies. (See table 3.)
In general, OSHA officials said that these partnerships have helped  agencies reduce their injury and illness rates by helping them to develop  stronger safety programs. However, in two instances OSHA terminated its  strategic partnerships with federal agencies prior to their completion,  either because the agency could not agree on the terms of the partnership  or because the agency lacked the commitment to make the changes  needed to improve their safety programs.
Federal agencies have joined two national alliances and formed a total of  10 regional or local alliances. While most of the alliances have focused on  general safety issues, more recently Region 10 signed an alliance with the  Fort Lewis Army Garrison that focuses on improving the training and  communication for emergency response efforts. According to one OSHA  official, this alliance has leveraged both agencies’ resources well. OSHA  has gained training from Fort Lewis on emergency response techniques,  and Fort Lewis has utilized OSHA’s expertise in properly fitting staff  members for personal protective equipment to be worn during an  emergency response.
section_title: Impact of the SHARE Presidential Initiative Is Unclear
paragraphs: OSHA assists federal agencies with SHARE, the Presidential initiative  begun in 2004 and intended to encourage federal agencies to improve their  safety programs and reduce federal workers’ compensation costs, but the  impact of the initiative on agencies’ safety programs is not clear.  Specifically, OSHA officials reported coordinating with OWCP to provide  training to the agencies about SHARE, but they had different views on the  effectiveness of the SHARE initiative. According to some OSHA officials,  the initiative has encouraged agencies’ national offices to pay more  attention to safety issues than they otherwise would have. Other officials  said that they thought SHARE was a paper exercise rather than a tool for  agencies to improve their safety programs, or that this type of program  might encourage underreporting of injuries. OSHA’s national office uses  workers’ compensation data to calculate agencies’ injury and illness rates  to determine whether they have met their SHARE goals related to workers’  safety, but it has not conducted any agency reviews to determine whether  underreporting has increased, according to OSHA officials.
OSHA officials at the national office said that they would like to use the  SHARE data to develop a list of agencies to target for inspection. By  focusing on agencies that are not meeting their SHARE goals, these  officials said they thought they could assist agencies in reducing their  injury and illness rates. OSHA officials said the agency will continue to use  workers’ compensation data to calculate agencies’ injury and illness rates  through 2006, but would consider using injury and illness data collected  under the new recordkeeping requirements after this time. Using this new  information would allow OSHA to identify trends for each federal agency  worksite and set more specific goals for improving agencies’ safety  programs.
section_title: Conclusions
paragraphs: OSHA faces a number of challenges in monitoring federal agencies’ safety  programs and, over time, has adapted its methods to try to make the most  of its resources. However, OSHA’s oversight could be further strengthened  if it took a more strategic approach. Because targeted inspections  generally uncover more workplace hazards than its other inspections, by  not targeting its inspection efforts to the most hazardous federal  worksites, OSHA is not using its limited enforcement staff and resources  in the best way possible. Now that federal agencies are collecting injury  data that would make targeting more feasible, OSHA is missing a critical  opportunity to identify and correct hazards. OSHA could require, as part of  the federal agencies’ annual reports, that each agency submit certain  portions or summaries of the data that agencies are required to collect  under the new recordkeeping requirements. This information could be  used to target federal worksites for inspection in the same way it targets  private-sector employers in industries with high injury and illness rates for  inspection. Alternatively, as OSHA does with private employers, OSHA  could develop its targeting program using the newly-required data that  federal agencies are collecting by surveying selected agencies and  worksites.
In addition, OSHA is not tracking violations disputed by federal agencies  or how they are resolved. As a result, hazardous worksite conditions may  remain uncorrected for years and OSHA may be limiting its ability to  address challenges agencies are facing in complying with OSHA’s  standards and to provide additional assistance to the agencies.
While inspections are specific to individual federal agency’s worksites,  evaluations allow OSHA to make thorough, agencywide assessments of  their safety programs. These evaluations require a lot of time and staff,  but, in the past, OSHA has been able to maximize its resources by  strategically combining evaluations of entire agencies with inspections of  federal worksites. By not conducting evaluations of the larger or more  hazardous federal agencies, OSHA is missing a critical opportunity to  provide agencies valuable feedback and assistance to agencies for  improving their safety programs in a more systematic way.
OSHA could also more effectively assess federal agencies’ safety programs  if it ensured that the agencies complied with the requirements for filing  annual reports and used the reports, as well as OSHA’s evaluations and  inspection data, to assess their safety programs and develop  recommendations for improvement. Because OSHA does not provide an  assessment of agencies’ safety programs in its annual report to the  President or recommendations for improvement as required, its ability to  ensure the effectiveness of these programs is limited.
section_title: Recommendations for Executive Action
paragraphs: The Secretary of Labor should direct OSHA to    develop a targeted inspection program for federal worksites based on  the new worker injury and illness data federal agencies are required to  collect by requiring that relevant portions or summaries of that data be  included in agencies’ annual reports to OSHA or by obtaining the data  from agencies or worksites through periodic, selected surveys;  track violations disputed by federal agencies to their resolution and  ensure that unresolved disputes are reported to the President;    conduct evaluations of the largest and most hazardous federal agencies    use evaluations, inspection data, and annual reports submitted by  federal agencies to assess the effectiveness of their safety programs,  and include, in OSHA’s annual report to the President, an assessment  of each agency’s worker safety program and recommendations for  improvement.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Secretaries of the Departments of  Labor, Agriculture, Defense, Homeland Security, Interior, Justice,  Treasury, and Veterans Affairs and the Commissioner of the Social  Security Administration. Officials from Agriculture, Treasury, and the  Social Security Administration informed us that their agencies did not  have any comments on our draft report. We received written comments  from the Departments of Labor, Homeland Security, and Interior. These  comments are reproduced in appendixes II, III, and IV. The Departments  of Defense, Justice, and Veterans Affairs provided technical clarifications,  which we incorporated as appropriate.
Labor generally agreed with all of our recommendations. In responding to  our first recommendation, OSHA explained that, for the immediate future,  it would use OWCP data to identify federal worksites for inspection. It did  not support the use of the annual reports to collect data on injury and  illness recorded by the agencies to use in targeting federal worksites for  inspection, but thought the use of surveys to collect these data was  noteworthy.
In regard to our second recommendation, OSHA reported that it will  create a database to track the status of OSHA citations disputed by federal  agencies. In responding to our final two recommendations, OSHA reported  that it would begin evaluations and a more rigorous review of agencies’  annual reports once staffing had increased.
The Departments of Homeland Security and Interior noted that Labor  could provide more assistance to agencies in addressing the challenges we  identified. While we believe agencies should seek assistance from OSHA  on ways to overcome these challenges, we also believe that these  challenges will require agencies to work internally to build support for  worker safety programs.
In addition, the Department of Homeland Security suggested that our  recommendations to Labor to increase OSHA’s enforcement activities may  not appreciably lower the incidence of injuries and illnesses and may  indeed reduce agencies’ requests for OSHA’s assistance. We continue to  believe that increased enforcement activities would provide OSHA with a  balanced strategy for ensuring workplace safety. In addition, inspections  will allow OSHA to review federal agencies’ injury and illness logs to  ensure that underreporting is not occurring—another concern that  Homeland Security raised in its comments. Finally, Homeland Security  suggested that OSHA should take the lead on developing a government- wide safety information system. We agree that it is important to have a  governmentwide safety information system and note that Labor has made  some effort in that direction.
We will make copies of this report available upon request. In addition, the  report  is available at no charge on GAO’s Web site at http://www.gao.gov.
If you have any questions about this report, please contact me at (202) 512- 9889 or at robertsonr@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix VII.
section_title: Appendix I: Scope and Methodology
paragraphs: We sent a data collection instrument to 57 agencies within the 8 largest  departments. The instrument requested information and documentation  on six components of sound safety programs we identified from previous  GAO reports: (1) management commitment, (2) employee involvement, (3)  education and training, (4) identification of hazards, (5) following up and  correcting hazards, and (6) medical management. We chose the eight  departments because they represented 80 percent of the federal executive  branch workforce—excluding the U.S. Postal Service, which under the  OSH Act is considered a private sector employer. We contacted officials  with each of the 8 departments to obtain the names of their operational  agencies and they provided us with the names of 57 agencies.  We  reviewed the documentation supplied by the agencies to support their  answers to selected questions on the data collection instrument. In  reviewing the documentation, we made two assessments: (1) whether the  documentation supported the agency’s responses and (2) what types of  activities the agency conducted for each program component. We  examined each document provided by the agencies in support of their  responses and assessed each as either “supporting” or “not supporting” the  agencies’ responses. Each document was reviewed by two people to  ensure that our assessment of the sufficiency of the documents provided  by the agencies was consistent. Of the 57 agencies that completed the data  collection instrument, two did not provide any supporting documentation.
The practical difficulties of conducting any survey may introduce errors,  commonly referred to as nonsampling errors.  For example, differences in  how a particular question is interpreted, the sources of information  available to respondents or in how the data are entered into a database or  were analyzed can introduce unwanted variability into the survey results.   We took steps in the development of the survey instrument, the data  collection, and the data analysis stages for the purpose of minimizing such  nonsampling errors.  For example, a survey specialist designed the survey  instrument in collaboration with GAO staff with subject matter expertise.   We pre-tested this survey at two agencies and, based on the results and  comments received during pre-testing, made appropriate revisions.  We  also independently verified the entry of all survey responses entered into  an analysis database as well as data analyses procedures.
We conducted follow-up interviews with safety managers and when  possible, employee representatives from the largest agency within each  department, and with the agencies with the highest lost-time or injury and  illness rates. In some cases, the largest agency had both the highest lost- time and injury and illness rates. In total, we conducted follow-up  interviews with safety managers in 12 agencies, as well as employee  representatives in 8 agencies. The interview questions were based on how  each agency originally responded to the data collection instrument and  their supporting documentation.
We also visited five federal agencies’ worksites: the Tobyhanna Army  Depot in Tobyhanna, Pennsylvania; Yellowstone National Park in  Wyoming; the U.S. Mint in Philadelphia, Pennsylvania; the U.S. Forest  Service’s Gardiner District Office (Gallatin National Forest) in Gardiner,  Montana; and the Veterans Health Administration’s Rocky Mountain  Network Office (a Veteran Integrated Service Network site) in Glendale,  Colorado, and Eastern Colorado Health Care Center in Denver, Colorado.  The first three worksites are OSHA recognized VPP sites. The Forest  Service site bordered Yellowstone National Park, and the Veterans Health  Administration site was recognized by OSHA as having a good safety  program. At each of these locations, we interviewed safety officials and  discussed the challenges and solutions they faced in developing their  safety programs.
We obtained information on claims filed by federal workers for injuries  they incurred from fiscal years 1995 through 2004 from OWCP. We used  data from two of OWCP’s data systems to tabulate basic descriptive  statistics provided in this report. One system provides injury and case  status information on all individuals who have filed claims with OWCP  while the other is used to bill agencies for the actual amount of workers’  compensation payments made on the agencies’ behalf. These systems  were used to develop our tables including the number of new cases filed;  the types of injuries incurred; and the actual amounts paid, by the age of  the case and types of payment. To assess the reliability of these data, we  interviewed OWCP and OSHA officials, reviewed published reports based  on these data (including reports from Labor’s Office of the Inspector  General), and performed our own tests for consistency and completeness.  We found that certain data elements had high levels of missing information  and thus could not be used in this report. For the elements we used,  although small data discrepancies were found, we determined that the  data were sufficiently reliable for providing the basic descriptive statistics  reported.
In reviewing OSHA’s role, we analyzed inspection data of federal agencies  for fiscal years 1995 through 2004 from OSHA’s Integrated Management  Information System. We interviewed OSHA officials at the national office  and all of its 10 regional administrators and federal agency program  officers. For each region, we interviewed the director of the area office  that had the largest number of inspections of federal worksites in the last 5  years. We also interviewed a compliance safety and health official in each  of these offices identified by the area director and, where possible, the  compliance assistance specialist, although not every area office had a  compliance assistance specialist. In addition, we interviewed two OSHA  officials about the local emphasis program for federal worksites that one  region had implemented.
Finally, when available, we examined agencies’ annual reports to OSHA  from 2000 to 2004 and asked to review OSHA’s annual reports to the  President for the same time period. However, as noted in the report, OSHA  had not completed its annual reports to the President for fiscal years 2001  through 2004 as required. We reviewed the report to the President that  OSHA had completed for fiscal year 2000.
section_title: Appendix II: Comments from the Department of Labor
subsections: section_title: GAO Comments
paragraphs: The following are GAO comments on Labor’s letter dated March 17, 2006.  1.  We reordered the SHARE goals as OSHA requested and identified  those goals for which OSHA is responsible.  2.  OSHA suggests that our finding—that violations disputed by federal  agencies were not being tracked—was confusing because the agency  has an inspection database that it uses to track the status of all  violations. However, as noted in its comments, when OSHA generated  a report to identify unresolved violations at federal agencies, staff  could not determine the status of 11 violations. In addition, OSHA  acknowledged that the Office of Federal Agency Programs (OFAP)  does not have a formal tracking system for cases it receives for  resolution. We reviewed the report language and believe that it  accurately explains the process in place.
section_title: Appendix III: Comments from the Department of Homeland Security
section_title: Appendix IV: Comments from the Department of Interior
section_title: Appendix V: Data Collection Instrument Sent to the Federal Agencies
section_title: Appendix VI: Agencies’ Responses to the Data Collection Instrument
paragraphs: The following table summarizes agencies’ responses to the data collection  instrument. In addition, the last column summarizes whether the  documentation agencies provided to support their responses for selected  questions was sufficient.
section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: Revae E. Moran (Assistant Director) and Margaret A. Holmes (Analyst in  Charge) managed all aspects of the assignment. Jessica A. Lemke, Sheila  R. McCoy, and Kris Trueblood made significant contributions to this  report. Other key contributors to this report included Kyle Browning,  Richard Burkard, Nina E. Horowitz, Tovah Rom, Beverly Ross, Jeremy D.  Sebest, John G. Smale Jr., Rachael C. Valliere, and Eric A. Wenner.