From 1997 to 2002 OSHA vowed to cut silica exposure by 15 percent - instead it increased by 300 percent, according to OSHA data. Agency officials believe better targeting may explain these results.
While the previous article in this series - "OSHA's Strategic Plan Lessons Learned" - indicated that OSHA met the vast majority of the performance goals it set for itself in its last SP, it did not meet them all. A comparison of the old SP and the new one, which will guide the agency through 2008, reveals how OSHA is attempting to grapple with some of its more serious challenges.
One of the lessons OSHA learned with respect to some problem areas: shift away from specific numeric goals in the SP and focus instead on immeasurable broader national goals.
For example, Gary Visscher, deputy assistant secretary of labor for OSHA, believes data problems may explain the silica issue. "If you set an exposure level target, and if you do a better job getting to high hazard places, then it looks like overall exposure is going up, even though we might just be doing a better job of targeting," he explained.
The agency's new SP has no specific target for reducing silica exposure.
Bill Kajola, an industrial hygienist with the AFL-CIO faults OSHA's new SP for taking this approach. "Hundreds of people are dying annually due to silicosis," he asserted. "When OSHA found silica exposures were higher than their goals on the old SP, they ought to use this to say, 'we have identified a much more serious problem than we expected' and then take aggressive steps to address it, such as a final rule to deal with the hazard."
What OSHA is doing instead, according to Kajola, is admitting it set a numerical goal it cannot achieve. "So now the agency is setting the SP in broad terms knowing well in advance it can meet them," he contended.
In its most recent regulatory agenda OSHA states that over 2 million workers are exposed to silica dust in general industry, construction and maritime industries and that "between 1990 and 1996, 200 to 300 deaths per year are known to have occurred where silicosis was identified on death certificates as an underlying or contributing cause of death." According to the National Institute for Occupational Safety and Health, from 1997 to 1999 silicosis deaths fell somewhat, to an average of just under 200 deaths per year. Kajola believes the real number could be twice as high, because many physicians do not include silicosis on death certificates.
Silica has remained on OSHA's regulatory agenda for years, but Kajola praised OSHA for some recent progress on a proposed comprehensive silica standard, "although the pace is much slower than we would like."
OSHA has no estimate on how long it might take to complete a final silica rule. The agency says it has attempted to address this problem through a variety of non-regulatory approaches, including initiation of a special emphasis program in 1997, but Visscher said OSHA is not currently doing anything different to reduce silica hazards.
Other examples of previous SP goals where OSHA fell short include:
- A Gallup survey of OSHA's stakeholders found that 22 percent of employers who had been inspected by the agency were "very satisfied" with the OSHA staff's understanding of the respondent's industry; 46 percent were "satisfied." OSHA's current drive to have more inspectors professionally certified could be related to improving on this result.
- Only 65 percent of OSHA "whistleblower" investigations were completed within 90 days, short of the 80 percent goal. In OSHA's view, this goal has been "substantially met." There have been no additions to OSHA's 80 full-time whistleblower investigators, but a spokesperson said their training has been improved thanks to a more detailed and consistent instruction course.
As with silica and professional certification, the new SP contains no specific measurable goals for the whistleblower program. Improved targeting did not prevent OSHA from meeting its other specific hazard reduction goals, however, and the agency has retained numerical reduction targets, most notably reductions in injuries, illnesses and fatalities.
"In our new strategic plan we're emphasizing broad, national goals on reductions of injuries, illnesses and fatalities," said Visscher. "We're trying to improve the overall safety and health culture in the workplace - this was one of the most important lessons learned from the old strategic plan."