Workplace Safety and Health: OSHA Should Strengthen the 	 
Management of Its Consultation Program (12-OCT-01, GAO-02-60).	 
								 
Several factors affect employers' decisions to participate in the
Occupational Safety and Health Administration's (OSHA)		 
Consultation Program. GAO surveyed industry associations,	 
employee representatives, and participating employers and found  
that the two main incentives for program participation are to (1)
make the employer's workplace safer and reduce worker injury and 
illness by promoting workplace safety and health and, (2) prepare
the employer's workplace for an OSHA inspection. The measurement 
system OSHA uses lacks sufficient data to separate the outcomes  
of the Consultation Program from the outcomes of OSHA's other	 
efforts to reduce workplace injuries and illnesses. OSHA's	 
process for allocating funds to the state consultation programs  
plays no role in encouraging participating states to achieve	 
agency goals. The criteria OSHA uses to allocate funds to state  
consultation programs do not consider performance; that is	 
achievement of agency goals, how many consultation related	 
activities a state consultation program has carried out in the	 
past year, or a program's ability to use the funds allocated for 
these activities.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-60						        
    ACCNO:   A02233						        
  TITLE:     Workplace Safety and Health: OSHA Should Strengthen the  
Management of Its Consultation Program				 
     DATE:   10/12/2001 
  SUBJECT:   Program evaluation 				 
	     Health hazards					 
	     Occupational health and safety programs		 
	     OSHA Integrated Management Information		 
	     System						 
								 
	     OSHA Workplace Consultation Program		 
	     OSHA Maine 200 Program				 
	     Safety Works Program				 
	     Targeted High Hazard Consultation			 
	     Program						 
								 
	     OSHA Performance and Tracking			 
	     Measurement System 				 
								 

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GAO-02-60
     
Report to Congressional Committees

United States General Accounting Office

GAO

October 2001 WORKPLACE SAFETY AND HEALTH

OSHA Should Strengthen the Management of Its Consultation Program

GAO- 02- 60

Page i GAO- 02- 60 Review of OSHA's Consultation Program Letter 1

Results in Brief 3 Background 4 Worker Safety and Pending Enforcement Are
Key Factors

Influencing Participation 9 OSHA Unable to Assess Consultation Program?s
Performance 12 Funding Allocation Process Does Little to Encourage Goal

Achievement 16 Conclusions 22 Recommendations for Executive Action 23 Agency
Comments 24

Appendix I Comments From the Occupational Safety and Health Administration
27

GAO Comments 29

Appendix II GAO Contacts and Staff Acknowledgments 30 GAO Contacts 30 Staff
Acknowledgments 30

Tables

Table 1: OSHA Performance Goals Applicable to the Consultation Program 6
Table 2: Changes in Funding for States With Decreased Activity

Levels 17 Table 3: Possible Reasons for Declines in State Consultation

Program Activity Levels 18 Table 4: State Programs Unable to Spend Their
Funds Each Year

During FY1996- 99 18

Figures

Figure 1: Yearly Changes in OSHA Consultation Program Funding and Total
Visits 5 Contents

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

BLS Bureau of Labor Statistics CAM Consultation Activity Measures Report
GPRA Government Performance and Results Act of 1993 IMIS Integrated
Management Information System MARC Mandated Activities Report for
Consultation OMB Office of Management and Budget OPTMS OSHA Performance and
Tracking Measurement System OSHA Occupational Safety and Health
Administration

Page 1 GAO- 02- 60 Review of OSHA's Consultation Program

October 12, 2001 Congressional Committees The Department of Labor?s
Occupational Safety and Health Administration (OSHA) is the federal agency
with primary responsibility for promoting workplace safety and health. OSHA
is known for conducting workplace inspections that can result in fines if
employers are not in compliance with applicable safety and health
regulations. The agency also operates a less publicized effort, the
Consultation Program, which is targeted to small employers in hazardous
industries who voluntarily request a consultation to identify and eliminate
workplace hazards that could cause injuries and illnesses to workers. 1 The
consultation is provided free of charge, and information obtained from a
consultation is treated as confidential. In return, the employer agrees to
remedy, within a reasonable time frame, any serious hazards identified by
the consultant. If these hazards are not remedied within a reasonable time
frame, consultants will refer the employer to OSHA for an inspection. In
fiscal year 2000, the program accounted for about 26,000 consultation
visits.

To carry out the program, OSHA provides funds to 50 2 state consultation
programs 3 that are responsible for conducting the consultation visits.
Between fiscal years 1996 and 2001, program funding increased over 50
percent- from $32.4 million to $48.8 million. By fiscal year 2001, the
Consultation Program?s funding accounted for over 11 percent of OSHA?s total
budget. However, from fiscal years 1996 to 2000 (the last year for which
complete activity data is available), employer requests for consultation
visits increased only about 4 percent. This discrepancy between funding and
employer interest has led to questions about the

1 The Consultation Program defines a small employer as one with no more than
250 workers at the workplace where the consultation is conducted and no more
than 500 workers companywide.

2 This includes 48 states (excluding Kentucky and Washington), the District
of Columbia, and Guam. These programs are authorized under section 21( d) of
the Occupational Safety and Health Act of 1970 (29 U. S. C. 670( d)).
Kentucky, Washington, Puerto Rico, and the Virgin Islands operate
consultation programs that are authorized under section 23( g) of the act
(29 U. S. C. 672( g)). For programmatic purposes, these latter programs are
distinct from the nationwide Consultation Program.

3 For purposes of this report, we refer to all consultation programs,
including those located in the District of Columbia and Guam, as ?state
consultation programs.?

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 02- 60 Review of OSHA's Consultation Program

program?s operation and OSHA?s management of it. To help address these
concerns, we initiated this work to (1) identify the factors affecting
employers? decisions to participate in the program, (2) assess OSHA? s
ability to measure the Consultation Program?s progress toward achieving the
agency?s goals for reducing workplace injuries and illnesses, and (3)
determine how well OSHA?s funding allocation and monitoring processes
encourage states to support achievement of agency goals. This report is
being addressed to committees that have jurisdiction over federal efforts to
promote workplace safety and health.

To identify factors affecting employer participation in the Consultation
Program, we conducted structured interviews with associations representing
employers and employees in industries that had high rates of injuries or
illnesses among their workers or that were targeted by OSHA for inspection
or participation in the program. 4 We also interviewed 17 employers who had
participated in the California, Maine, or New York consultation programs. 5
To assess OSHA?s ability to measure the program?s progress toward meeting
the agency?s goals and to ensure that the funding allocation process
supports the achievement of those goals, we identified OSHA?s program and
financial oversight policies and procedures and reviewed activity and budget
data. 6 We also obtained data on program expenditures from all programs
experiencing declining levels of activity as defined by total visits. 7 We
interviewed OSHA headquarters officials in Washington, D. C., and at 6 of
the agency?s 10 regional offices to assess how these policies and procedures
were implemented in the field. To obtain information on how programs operate
at the local level and pursue our objectives with state officials, we
visited seven state consultation programs that accounted for nearly 30
percent of fiscal year

4 These sectors were construction, food and kindred products, lumber and
wood products, metal products manufacturing, motor freight transportation,
and health services. 5 We chose these states for our employer interviews
because, during fiscal years 1996- 2000, California and New York had the two
largest consultation programs, and the Maine consultation program was among
the fastest growing programs in terms of initial consultation visits.

6 Because Arizona, Indiana, Nevada, and New Mexico joined the Consultation
Program in fiscal year 1999, we were unable to include them in our analyses
of program activity or funding levels.

7 We obtained data on program expenditures from 16 state consultation
programs. These are the programs in Arkansas, California, Connecticut,
Delaware, District of Columbia, Florida, Iowa, Maryland, Michigan, New
Hampshire, New York, North Dakota, South Dakota, Tennessee, Utah, and
Wisconsin.

Page 3 GAO- 02- 60 Review of OSHA's Consultation Program

2000 federal funds allocated to all 50 programs and represented a
crosssection of approaches to program implementation. 8 At each location, we
interviewed program officials and analyzed program and financial data. We
conducted our work in accordance with generally accepted government auditing
standards between January 2001 and August 2001.

Several factors affect employers? decisions to participate in the
Consultation Program. According to industry associations, employee
representatives, and participating employers we interviewed, the two
principal incentives for program participation are to (1) make the
employer?s workplace safer and reduce worker injury and illness by promoting
workplace safety and health and (2) prepare the employer?s workplace for an
OSHA inspection. In contrast, the potentially high cost of correcting
hazards and the possibility that program consultants would lack the
competence to adequately identify and remedy hazards are the two principal
disincentives.

OSHA is generally unable to measure the Consultation Program?s progress
toward the achievement of OSHA?s key goals related to reducing workplace
injuries and illnesses. This is primarily because the measurement system
OSHA uses lacks the data necessary to separate the outcomes of the
Consultation Program from the outcomes of OSHA?s other efforts to reduce
workplace injuries and illnesses. Lacking necessary data, OSHA cannot
determine whether injuries and illnesses actually decline at an employer?s
work site after a consultation visit takes place. Moreover, OSHA and state
consultation program officials agree that the agency?s data collection
system for measuring program activity is burdensome and inefficient. For
example, officials of one state program told us that the program could
increase the number of consultations they conduct by as much as 20 percent
if federal OSHA reporting requirements were reduced. State program officials
also said that there are so many data elements measured that it is difficult
to know which program activities should receive priority.

OSHA?s process for allocating funds to the state consultation programs plays
no role in encouraging participating states to achieve agency goals. The
criteria OSHA uses to allocate funds to state consultation programs do not
consider performance; that is, achievement of agency goals, how many

8 The state consultation programs we visited were California, District of
Columbia, Maine, Maryland, New Jersey, New York, and Pennsylvania. Results
in Brief

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

consultation- related activities a state consultation program has done in
the past year, or a program?s ability to use the funds allocated for these
activities. For example, during fiscal years 1996- 2000, all state
consultation programs received increases in program funds, even though 16
programs decreased their level of activity during this period. In addition,
OSHA?s regional offices lack detailed data on how state consultation
programs spend federal funds because they have inconsistent policies for
auditing the financial performance of these programs; some regions conduct
audits every year, while others had not audited state programs under their
jurisdiction for 5 years. They also lack ready access to detailed
information on how state consultation programs spend the federal funds. As a
result, OSHA does not know the extent to which state consultation programs
are making effective use of allocated funds.

We are making recommendations to OSHA to strengthen its management of the
Consultation Program by improving its processes for measuring the program?s
contribution toward achieving OSHA goals and ensuring that the allocation of
funds to the state programs supports attainment of these goals.

In commenting on a draft of this report, OSHA generally agreed with our
recommendations and said the report would help improve the Consultation
Program. However, OSHA noted that, in its view, current federal law for
program evaluation does not require the agency to measure the contribution
of individual programs toward achieving its agencywide goals. Nonetheless,
OSHA agrees that it needs measurement criteria for the program and will look
for opportunities to examine its effectiveness.

OSHA established the Consultation Program in 1975 as a mechanism, separate
from its enforcement program, to reduce workplace injuries and illnesses,
especially for small employers who often cannot afford in- house or private
sources of assistance. The program operated in the shadow of OSHA?s much
larger and more visible enforcement program until the mid1990s, when OSHA
began to give greater emphasis to consultation. Consistent with that
emphasis, funding for the Consultation Program increased over 50 percent
between fiscal years 1996 and 2001. 9 Many knowledgeable officials see this
trend toward cooperation as enhancing OSHA?s overall efforts to protect
workplace safety and health.

9 This includes cost- of- living allowances. Background

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

However, program activity for the same period did not increase substantially
with the increase in funding. For example, the number of total consultation
visits increased about 2 percent nationwide between fiscal years 1996 and
2000 (the last year for which complete program data are available)- from
25,986 to 26,418. Further, the number of total hazards identified through
the program decreased about 8 percent- from 188,577 to 171,167. Figure 1
shows the yearly change in funding compared with the change in the number of
total visits from fiscal years 1996 to 2000.

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

Notes: Total visits include initial visits to employers plus training and
other follow- up visits. This figure does not include funding or activity
data for Arizona, Indiana, Nevada, and New Mexico because they joined the
Consultation Program in fiscal year 1999.

Source: OSHA data. -5

0 5

10 15

20 25

30 2000 1999 1998 1997 1996

-0.5 8.1

-2.6 10.9

2.0 24.2

1.7 28.0

Total Visits = 25,986 Funding = $30,331,900

Percentage Change in Total Visits Percentage Change in Funding

Percentage Change Compared to Fiscal Year 1996 Fiscal Year

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

With one exception, each state has designated a single agency (i. e., labor,
commerce, health, or environmental protection) or a state university to
deliver the consultation services. 10 The state entities running this
program have significant flexibility for delivering the consultations.
However, there are procedures and requirements codified in regulation that
each state consultation program must follow. 11 State consultation programs
are required, for example, to give service priority to small, high- hazard
employers and ensure that worker representatives are involved in initial and
closeout meetings with the employer.

With the passage of the Government Performance and Results Act of 1993
(GPRA), OSHA established three agencywide strategic goals related to
improving workplace safety and health. The first goal, in particular, is to

?improve workplace safety and health for all workers as evidenced by fewer
hazards, reduced exposures, and fewer illnesses, injuries, and fatalities.?
Under this strategic goal, OSHA established several performance goals, most
recently for fiscal years 1997- 2002, that contained specific objectives for
reducing workplace injuries, illnesses, and fatalities. As shown in table 1,
OSHA has identified four of these performance goals as being applicable to
the Consultation Program.

Table 1: OSHA Performance Goals Applicable to the Consultation Program Type
of goal Projected outcome

Reduce by 15% workplace illnesses and injuries in the shipyard, food
processing, nursing home, logging, and construction industries. Reduce by
15% illnesses and injuries resulting from amputations and from exposure to
lead and silica. Targeted

Reduce by 15% the four leading causes of fatalities in the construction
industry. Nationwide Reduce injuries and illnesses by 20% in at least
100,000

workplaces where OSHA initiates an intervention. Note: In addition to these
strategic outcome goals, OSHA identified strategic activity and customer
satisfaction goals that applied to the Consultation Program, which are not
discussed in this report.

Source: U. S. Department of Labor, OSHA, Revised Strategic Plan (FY 1997- FY
2002), Sept. 18, 1998.

10 Wisconsin has divided its consultation program between its commerce and
health agencies. 11 See 29 C. F. R. part 1908.

Page 7 GAO- 02- 60 Review of OSHA's Consultation Program

OSHA established these strategic and performance goals for the 31
consultation programs in states (29 states, the District of Columbia, and
Guam) for which OSHA has primary enforcement authority. These states are
under federal OSHA jurisdiction for workplace safety and health. The
remaining 19 state consultation programs operate in states that have their
own safety and health programs. 12 Each of these ?state- plan? states has
adopted OSHA?s first strategic goal but has developed its own related
performance goals. 13

OSHA developed a database system- the OSHA Performance and Tracking
Measurement System (OPTMS)- to obtain information on activities related to
OSHA?s GPRA goals. According to OSHA officials, this Web- based system
requires no additional reporting because it includes 276 data elements that
already exist in other OSHA data systems. One hundred of the elements are
relevant to the Consultation Program. For example, OPTMS tracks the number
of consultations that are performed in targeted industries, as well as the
number of employers participating in the Consultation Program that develop a
safety and health program. Only the consultation programs in the 31 federal
OSHA states provide data into OPTMS for evaluation. 14

OSHA also uses its Integrated Management Information System (IMIS) to
collect agencywide data, including data on the activities of the
Consultation Program. Consultation Program managers at OSHA use IMIS to
compile two reports providing data specific to the Consultation Program. The
first of these, the Consultation Activity Measures Report (CAM), tracks 18
quantitative indicators of the Consultation Program?s activities, such as
the number of days from request to visit and the number of hazards
identified per visit. The second, the Mandated Activities Report for
Consultation (MARC), tracks five indicators of the Consultation Program?s
activities that reflect regulatory requirements, including the

12 Under the Occupational Safety and Health Act, states are allowed to
establish and enforce their own safety and health standards as long as they
are at least as effective as the federal OSHA program.

13 As mentioned earlier, the analysis in this report does not include the
consultation programs in Kentucky, Washington, Puerto Rico, and the Virgin
Islands. The consultation programs in these ?state- plan? states are
authorized in a separate provision of the Occupational Safety and Health
Act.

14 OSHA said that it will assess the performance of states that have their
own safety and health programs in accordance with their respective statewide
goals as well as through traditional activity and other outcome measures.

Page 8 GAO- 02- 60 Review of OSHA's Consultation Program

proportion of visits that were made to high- hazard establishments and the
number of visits to smaller employers.

In addition, to help measure the Consultation Program?s progress toward
achieving performance goals, OSHA introduced, for the first time in fiscal
year 2000, a process for use by its regional offices to provide guidance to
the state consultation programs. Under this process, the regional offices
are supposed to assist each state consultation program in developing an
annual project plan that contains goals. Each state consultation program is
supposed to develop an end- of- year performance report that the regional
offices review. The regional offices also prepare reports on the state
consultation programs under their jurisdiction. The first of both these
year- end reports was under way during our audit work, so they were too new
to evaluate.

To fund the Consultation Program, OSHA provides grants to the state entities
delivering the services. OSHA provides 90 percent of the funds needed to
carry out the program, and the state consultation programs provide the
remaining 10 percent. 15 OSHA gives each state consultation program a base
amount equal to the funding it received during the prior year plus any cost-
of- living adjustment. If there are any funds remaining, OSHA uses a formula
it instituted in fiscal year 1999 to distribute them to state consultation
programs. As part of this formula, OSHA first divides the remaining funds in
half. It distributes the first half based on the share of the overall
funding that each state consultation program has. It then takes the second
half and distributes it according to yearly data for three factors that
approximate a program?s workload- level of gross state product, total state
nonfarm employment, and number of small highhazard establishments in the
state. 16 For each year during fiscal years 1996- 2000, each state
consultation program received a funding increase. The states must obligate
the federal funds before the end of the fiscal year for which they were
appropriated, or else they expire and are no longer available to the
Consultation Program.

15 OSHA finances 100 percent of the consultation program in Guam. 16 Before
fiscal year 1999, the amount of funding provided to state consultation
programs was simply based on amounts the programs received the prior year
and their ability to match the funding provided. OSHA officials stated that
the formula, which the agency created in conjunction with state consultation
program representatives, was designed to bring state programs to some level
of funding parity. Funding parity is attained when the funding that is
provided to each state program is proportional to the overall demographic
factors affecting demand for the service in each state.

Page 9 GAO- 02- 60 Review of OSHA's Consultation Program

Industry associations as well as participating employers identified the
opportunity to improve workplace safety and health and to prepare for or
preempt an OSHA inspection as two incentives for participation in the
Consultation Program. Industry association officials, worker
representatives, and participating employers we interviewed also identified
concerns about costs to address identified hazards and the qualifications of
program consultants as two disincentives.

Industry associations as well as participating employers identified the
opportunity to minimize worker injuries and illnesses and otherwise improve
workplace safety and health as one incentive for participating in the
Consultation Program. They saw activities to promote workplace safety and
health as an opportunity to reduce the number of employee workdays lost
because of injuries and illnesses; retain experienced workers and minimize
turnover; promote strong labor- management relations, particularly in union
workplaces; and possibly reduce workers? compensation costs. Even employers
that had in- house expertise on workplace safety and health said that the
Consultation Program could help them identify hazards that they might
otherwise have overlooked and resolve problems that previously they had not
addressed directly.

Some industry associations, as well as participating employers, identified
the Consultation Program?s potential for reducing the number of citations
(and fines) that might result from a subsequent OSHA inspection as a second
incentive. Although they saw safety as the factor driving employers to
request consultations, several industry associations said that an imminent
inspection would serve as a strong incentive for their members to
participate in a consultation. Many industry associations believed that an
employer who had a consultation would likely fare better if an inspection
did occur. Several of the employers we interviewed who had participated in
consultations said that their primary incentive for doing so had been to
prepare for or preempt an inspection and the possibility of substantial
fines. These employers generally had been notified of a possible inspection,
either directly by the state or federal OSHA, or more indirectly through
industry associations, business newsletters, or presentations that OSHA was
targeting their industry.

OSHA officials as well as most of the state consultation program officials
we interviewed echoed the view that there is a strong positive correlation
between anticipated inspections and an employer?s request for a
consultation. They provided examples, which follow, of the effect of an
increased emphasis on inspections. Worker Safety and

Pending Enforcement Are Key Factors Influencing Participation

Worker Safety and Enforcement Identified as Incentives

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

 In 1993, Maine OSHA implemented the ?Maine 200? program, through which it
contacted the 200 Maine employers with the highest number of serious
workplace injuries and illnesses. OSHA offered these employers a choice of
working cooperatively with OSHA to address workplace hazards or remaining on
a list of work sites that would likely be inspected. About 98 percent of
these employers chose the former. According to a Maine consultation program
official, many of these employers turned to the Maine consultation program
for assistance in identifying and correcting hazards. Maine consultants
added that subsequent enforcement programs, focused on local employers, have
also been very successful in encouraging employers to use the Consultation
Program.

 In 1994, California initiated a state- funded consultation program, called
the Targeted High Hazard Consultation Program, through which California
sends letters to employers with high workers? compensation rates to notify
them that they will be inspected unless they seek help from available
consultation programs or their insurance carrier. According to California
program officials, this effort increased the number of consultations
requested from the state- funded consultation program. This program was
recently merged with the state OSHA- funded consultation program.

Industry association officials and employers we interviewed identified
concerns about the costs of correcting hazards and the qualifications of
program consultants as disincentives. First, officials from both groups
stated that employers are concerned that the cost of correcting the hazards
identified by a consultation might be prohibitive. They feared that if they
could not afford to correct all the hazards in an acceptable time frame, the
consultant might report them to OSHA for an inspection. Consultants and
state program managers we interviewed said that, in their experience, the
costs associated with addressing hazards are generally manageable, but fears
about costs still persist among employers. Second, industry associations and
employee representatives expressed concern that some state consultation
programs employ individuals who lack the appropriate credentials or
experience to serve as workplace safety and health consultants. Some states
do not require that consultants have advanced or specialized degrees. Other
industry associations and employee representatives said that even those
consultants with credentials in workplace safety or health- related fields
might not have the industry expertise necessary to identify and suggest
remedies for hazards. One area identified with regard to this concern was
the health industry.

General distrust of OSHA was another factor identified as a disincentive for
participation in consultations. Employers feared that consultants Concerns
About Costs and

Consultant Qualifications Identified as Disincentives

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

would inappropriately provide information about the consultation to OSHA,
prompting an inspection. However, none of the industry association
representatives or employers we spoke with knew of any instances where this
had actually happened. 17 Related to this concern was the perception that
state consultation programs were oriented more favorably toward workers than
employers. Industry associations and employers identified recently developed
regulatory requirements that they believed reinforced this perception. These
included the requirement that employers permit an employee representative to
participate in all phases of the consultation visit and the requirement to
post a list of the hazards identified by the consultation and the date by
which the hazards are to be corrected.

Although employers have both incentives and disincentives for participating
in the consultation program, they may be unaware, in general, of the program
and what it offers. Industry association officials said that they do not
often see the Consultation Program promoted at key employer events. In
addition, they did not think that the Consultation Program was adequately
promoted as part of other federal efforts that help small employers
establish and maintain safe workplaces. Employee representatives echoed this
sentiment, saying that they did not believe that most employees knew about
the program. Others said that even if the employers were aware of it, they
might not know who can participate or how to initiate a consultation.

During the course of our work, we found several state consultation programs
that were attempting to address some of these disincentives. For example:

17 Industry and labor representatives we interviewed said there had been
cases where a consultation was ongoing or just concluded and an OSHA
inspector arrived, but they believed this indicated a lack of coordination
between the two entities rather than an inappropriate exchange of
information.

Page 12 GAO- 02- 60 Review of OSHA's Consultation Program

 Maine?s promotion program. The Maine consultation program has developed a
campaign that, among other things, addresses the disincentive posed by
employers? concerns about costs. This program has used state funds to
develop a promotion campaign, called Safety Works, which emphasizes that, in
the long run, employers will very likely save money by eliminating serious
workplace hazards. This campaign also emphasizes that consultants are
willing to work with employers to identify remedies that do not financially
overburden the employer. Maine also provides lowcost loans to the employer,
if necessary, to address the identified hazards.

 Pennsylvania?s university- based program. The Pennsylvania consultation
program operates out of the Indiana University of Pennsylvania and is one of
eight state programs located at a state university. Between fiscal years
1996 and 2000, the program experienced an 88- percent increase in requests
for consultation visits, while nationwide requests for consultation visits
increased only marginally. Operating out of a university has allowed the
Pennsylvania program a number of benefits. First, potential clients are less
likely to perceive university- based programs as an extension of OSHA.
Second, the university can attract higher qualified consultants than the
state government because it can offer higher salaries than the state
government as well as competitive benefits. For example, it offers
consultants the opportunity to take sabbaticals from consultation to teach
at the university.

In measuring its progress toward reaching its GPRA performance goals for
reducing injuries and illnesses, OSHA does not seek to isolate the
contributions of each of its program activities (e. g., consultation or
compliance inspections). For this and other reasons, the agency cannot
measure the impact of the Consultation Program. Specifically, the agency
cannot measure the extent to which the program contributes to accomplishing
OSHA?s goals for reducing the number of workplace injuries and illnesses
associated with targeted industries or hazards. Similarly, the agency cannot
measure the extent to which the program contributes to the agency?s reaching
its nationwide goal. Finally, state consultation programs have concerns
about OSHA?s system for collecting activity information, which they
characterized as burdensome and inefficient.

OSHA cannot assess the extent to which its Consultation Program is helping
to achieve OSHA?s goals. OSHA employs a three- step process to measure its
success at reducing injuries and illnesses in targeted areas that uses data
from OPTMS and nationwide data from the Bureau of Labor Statistics (BLS).
Using OPTMS, OSHA first identifies all agency activities OSHA Unable to

Assess Consultation Program?s Performance

OSHA Lacks the Data to Measure Progress

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

in a given period that were directed toward OSHA goals. OSHA then uses BLS
data to measure changes in the level of workplace injuries or illnesses in
targeted industries or caused by targeted hazards. If the level of measured
injuries and illnesses declines, OSHA infers that the activities it
conducted contributed to that decline.

There are three reasons why OSHA?s efforts do little to allow it to identify
the impact of the Consultation Program. First, in conducting its analysis,
OSHA collects data only from the 31 state consultation programs located in
federal OSHA states, meaning that the activities of the 19 ?state plan?
state consultation programs are not reflected. Second, in assessing progress
toward its goals, OSHA does not isolate the activities of the Consultation
Program from those of its other programs (such as enforcement), which means
that OSHA does not know the relative impact of the Consultation Program on
the achievement of its goals. Third, even if OSHA were able to identify the
separate activities of the Consultation Program, its analysis would not
demonstrate a direct causal link between the services offered by the
Consultation Program and nationwide changes in workplace safety and health,
which may also result from other influences.

Establishing a better connection between the Consultation Program and
reductions in the number of injuries and illnesses among workers would
require having data from all state programs and all employers receiving
consultations, both before and after the consultation. Other factors, such
as new management, might affect the level of injuries and illnesses at a
workplace. Nonetheless, this information could give OSHA a better
understanding of the outcomes of the Consultation Program than it has now.
The Consultation Program currently collects data on workers? injuries and
illnesses in preparation for each consultation visit, but according to OSHA
officials, the program has been hesitant to collect the same data for the
period following the consultation.

OSHA has been reluctant to collect these data because agency officials
believe that such data may not be available and because their collection may
burden employers, be outside the agency?s authority, or raise issues
regarding the confidentiality of employer information. While these issues
need to be considered, they do not appear to be insurmountable. There does
not appear to be any prohibition against OSHA?s obtaining this information
from all 50 state programs, and several state programs collect this
information already. Also, consultants told us that they believe there are
ways for OSHA to obtain this information while maintaining its pledge of
confidentiality. For example, state program consultants could collect

Page 14 GAO- 02- 60 Review of OSHA's Consultation Program

and enter aggregate information into OSHA?s data system (i. e., compiled
into industry or statewide information) without divulging establishment
names.

OSHA also experiences difficulty in assessing the Consultation Program?s
contribution to the agency?s nationwide performance goal- reducing by 20
percent the number of worker injuries and illnesses at 100,000 workplaces
where it initiates an intervention. To measure its progress toward this
goal, OSHA conducted a study 18 in which it used two databases- one
maintained by BLS and the other in- house- to identify the number of
workplaces where injuries and illnesses had been reduced by 20 percent from
October 1995 to March 1997. This report concluded that OSHA was making
progress toward achieving this goal. However, it also noted that the study
was not designed to isolate the effects of different types of interventions.
Thus, it could not be used to evaluate the impact of the Consultation
Program.

State consultation program managers, as well as OSHA officials, expressed
concern about the burden placed on state programs by OSHA?s data reporting
requirements. This was especially true in those cases where these programs
also had state- imposed reporting requirements. State program officials said
that they believed much of the time spent on data reporting was wasted
because the reporting requirements focus more on the number of hazards
identified than on how effectively the hazards were remedied. Consultants
with the Maine consultation program stated that they devote half their time
to fulfilling reporting requirements, while New York program officials said
that, for each day spent with employers, consultants spend 2ï¿½ days in the
office complying with data reporting requirements, including the
consultation report for the employer. In California, consultation officials
estimated that the state program could increase the number of consultations
they did by as much as 20 percent if federal OSHA reporting requirements
were reduced.

In addition, the number of activity indicators that OSHA tracks- over 100
indicators that are relevant to the state consultation programs in the MARC,
CAM, and OPTMS systems- dilutes OSHA?s ability to communicate the program?s
key goals and priorities to states. State

18 See OSHA, An Estimate of OSHA?s Progress from FY 1995 to FY 1999 in
Attaining Its Performance Goal of Reducing Injuries and Illnesses in 100,000
Workplaces (Mar. 23, 2000). OSHA Relies on

Burdensome Reporting System for Measuring Program Performance

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

consultation program officials said that the large number of activity
indicators tracked by OSHA makes it difficult to determine which activities-
and associated goals- should have priority. For example, OSHA tracks the
number of consultation visits state consultation programs make. This may
signal states to give priority to conducting as many visits as possible to
many different employers. However, OSHA also tracks the number of
consultations that result in employers developing safety and health
programs. This may signal states to give priority to conducting numerous
visits to a single employer. While focusing more intensely on individual
employers may increase the likelihood that employers develop health and
safety programs, at the same time, it may potentially reduce the number of
consultations overall. State consultation program managers also said that
the sheer number of activities OSHA tracks means that state programs cannot
pursue all of the indicators. As a result, program managers tend to select
the three to five that they believe are most important. For example, one
state program manager we visited focused almost entirely on initial visits,
hazards corrected, and timeliness of the report; another placed greatest
emphasis on total visits, combined safety and health visits, and certain
targeted goals.

Finally, state consultation program officials told us that indicators used,
some of which were developed in the 1980s, do not reflect how some state
consultation programs currently operate. For example, the New York and
California programs focus on providing employers with long- term assistance
that includes, among other things, extensive follow- up, technical
assistance regarding the best ways to correct hazards, training for
management and workers, and guidance on the proper installation of new
equipment and the introduction of new processes. However, these activities
are not represented in current indicators. The California, Maine, and New
Jersey programs have placed increased emphasis on promoting the Consultation
Program within the local business community by making presentations,
participating in conferences, and utilizing electronic and print media.
Although OSHA currently collects information on activities intended to
promote the program, it does not analyze this information.

OSHA officials, as well as every Consultation Program manager we
interviewed, acknowledged that OSHA needs to replace the current performance
measurement system with a less burdensome and more relevant system. For the
past 8 years, OSHA Consultation Program officials have recognized the need
for a separate system for obtaining activity data that would operate outside
IMIS; however, resource constraints and higher priorities within the agency
have prevented this. OSHA has been attempting to improve the electronic
transfer of data from

Page 16 GAO- 02- 60 Review of OSHA's Consultation Program

the states into IMIS, and Consultation Program staff at OSHA have been told
that they cannot make any significant changes to the IMIS- based data
systems until this project to update IMIS is completed. In the meantime,
OSHA officials said that they have told the state programs that many of the
indicators, such as those in the CAM, should no longer drive program
activity. However, OSHA continues to require state programs to provide data
on all of these indicators and includes some of the indicators in newly
developed yearly program monitoring reports that each state program must
complete.

OSHA?s process for allocating federal funds to state consultation programs
does not encourage these programs to make effective use of these funds.
Because OSHA does not collect data to assess the Consultation Program?s
performance, it cannot consider such data in its allocation process. Also,
even though OSHA collects data on state program activity, it does not use
this information to allocate funds to state consultation programs. It also
does not consider state programs? ability to use allocated funds. As a
result, state consultation programs receive additional funds each year
regardless of prior performance. At the same time, OSHA?s 10 regional
offices do not pursue consistent policies for conducting fiscal audits of
consultation programs within their jurisdictions and lack ready access to
spending information needed to oversee the operations of consultation
programs.

In allocating funds to state consultation programs, OSHA does not factor in
the programs? activity levels. As a result, programs can routinely decrease
the number of consultations they conduct and the number of hazards they
identify and still receive funding that is the same or greater than they
received in the previous fiscal year. All state consultation programs
received increases in funding between fiscal years 1996 and 2000, even
though 16 consultation programs experienced often significant decreases in
activity levels, as shown in table 2. Funding Allocation

Process Does Little to Encourage Goal Achievement

Activity Is Not Considered in Allocation Process

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

Table 2: Changes in Funding for States With Decreased Activity Levels
Percentage change from FY1996 to FY2000 State Funding level Total visits
made Hazards identified

Arkansas 15 -25 5 California 25 -53 -47 Connecticut 22 -10 -49 Delaware 47
-15 -31 District of Columbia 46 -23 -55 Florida 25 -50 -63 Iowa 20 -34 -26
Maryland 32 -25 -14 Michigan 27 -5 17 New Hampshire 75 -1 12 New York 19 -17
-23 North Dakota 28 -2 43 South Dakota 42 -24 -23 Tennessee 19 -32 -56 Utah
18 -18 -4 Wisconsin 19 -3 -4

Note: This table does not include funding or activity data for Arizona,
Indiana, Nevada, and New Mexico because they only joined the Consultation
Program in fiscal year 1999.

Source: OSHA data.

Although neither OSHA nor state program officials we interviewed have
analyzed why one- third of the state consultation programs appeared to be
doing less with additional funds, they did identify several factors that
might affect activity levels. As shown in table 3, these included, among
others, data collection mechanisms that do not reflect all the activities
that programs pursue, data collection requirements that potentially decrease
time available for consultation, and hiring freezes that result in unfilled
consultant positions. However, OSHA officials agreed that, at some point,
decreases in basic program activities, such as the number of consultation
visits or hazards identified, raise questions about resource utilization.

Page 18 GAO- 02- 60 Review of OSHA's Consultation Program

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

Possible reason Effect on activity levels

Developing long- term relationships with employers These efforts require
greater levels of resources

than quick one- time consultations. Data collection mechanisms do not
reflect all the activities that programs pursue

It may appear that activity is decreasing, but resources have just been
shifted to other activities.

GPRA- imposed targeted industries or hazards Changes in areas of program
focus may require

different strategies to find new clients. Data collection requirements
Administrative requirements take consultants? time

away from consultations. State- imposed hiring or salary freezes Hurts
programs? ability to fill consultant positions,

so fewer consultants available to do visits. Source: State consultation
program management and staff.

We also found that OSHA provided increased funding to states even if they
had a history of being unable to use their funding allocations for prior
years. In total, 31 of the programs were unable to use all their funds at
least once between fiscal years 1996 and 1999. (How many state programs will
have this experience in fiscal year 2000 is unknown because they are still
reporting their expenditures to OSHA.) Table 4 identifies the 7 state
programs that were unable to use all of their funds every year during that
period. In addition, 8 other programs were unable to use all their funds for
3 of those 4 years, 10 programs had this experience for 2 of those years,
and 6 programs had this experience for 1 year.

Table 4: State Programs Unable to Spend Their Funds Each Year During FY1996-
99 Percentage of total funds unused State 1996 1997 1998 1999

Louisiana 6 11 35 13 Michigan a 8 112211 New Hampshire 10 3 5 12 New York 1
7 5 8 North Carolina 9 6 3 13 North Dakota 19 18 23 43 Tennessee 11 5 13 1 a
Michigan provided this information separately for its safety program and
health program, which at the time were managed by different agencies. We
combined this information for purposes of this analysis. Source: OSHA data.

Unused funds complicate OSHA?s ability to ensure that funds are used to
support the achievement of its strategic goals. State consultation programs

Page 19 GAO- 02- 60 Review of OSHA's Consultation Program

sometimes notify OSHA of their inability to use the funds, in which case
OSHA can reallocate those funds to other programs. However, because these
funds arrive late in the year and will not be made available in subsequent
years, OSHA instructs the state consultation programs not to use them for
salaries or fringe benefits, other than one- time bonuses. As a result,
state consultation programs generally use these funds to buy equipment or
other supplies. In other cases, state consultation programs that cannot use
the funds do not alert OSHA to that fact, in which case all unobligated
funds expire at the end of the fiscal year and are no longer available for
use.

OSHA, in partnership with the states, changed its allocation process
starting in fiscal year 1999, but did not use this opportunity to factor in
activity levels or use of funds. By not doing so, OSHA lost the opportunity
to use the funding allocation process to influence state program
performance. As noted earlier, under OSHA?s current allocation process,
state programs are ensured a level of funding equal to what they received in
the previous year, as long as the program budget has not decreased. In
addition, state programs are awarded additional funds based on their size
rather than their activity levels or a demonstrated ability to use the funds
allocated to them.

As a result of its limited monitoring, OSHA lacks the information necessary
to identify which state programs need additional guidance to achieve agency
goals. OSHA?s 10 regional offices, which are responsible for monitoring
state consultation program expenditures, have inconsistent policies
concerning when, and under what circumstances, they conduct audits of the
state consultation programs. We found that some regional offices conducted
annual financial audits of state consultation programs in their
jurisdiction, while others had not audited state programs under their
jurisdiction for as long as 5 years. As of August 2001, seven OSHA regional
offices had not audited 17 state consultation programs under their
jurisdiction for over a year. For example, Region 3 (Philadelphia) had not
audited the Maryland consultation program ($ 682,000 budget in fiscal year
2000) for 5 years. OSHA Region 9 (San Francisco) had not audited the largest
program, California ($ 4.45 million budget in fiscal year 2000), in 2 years.
Region 9 also had not audited the Guam and Hawaii programs in 2 years,
despite knowing about the significant management and fiscal difficulties
these programs have. Because the relative amounts provided to OSHA?s
Oversight of

Financial Expenditures Is Limited and Inconsistent

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

each state for the consultation program are small in comparison with other
federal programs, the expenditure of these funds is also not likely to be
audited by any other entity. 19 OSHA officials said they have not provided
guidance to regions on the appropriate interval between routine financial
audits or the conditions that might warrant an out- of- cycle audit. OSHA
officials also said that they would like the regions to conduct more audits
but the decline in staff resources in the field has adversely affected the
regions? ability to do so.

OSHA?s regional offices also do not have access to financial data
demonstrating how state consultation programs spend federal funds by object
class (i. e., salaries, fringe benefits, travel, equipment, supplies,
contracts, and other expenses) unless they conduct an audit or obtain
special authority from the Office of Management and Budget (OMB) to
routinely collect this information. 20 At the beginning of each fiscal year,
state consultation programs report how they plan to spend the funds by
object class; however, there is no requirement to provide a detailed report
showing how the funds were actually spent. Instead, they are required to
report quarterly and yearly a single figure showing only total expenditures.
OSHA officials said they would like to collect detailed information on
expenditures to improve monitoring. We found that most of the state
consultation programs we contacted had this information readily available
and did not believe it would be an onerous requirement to provide it
routinely to OSHA. To date, OSHA has not petitioned OMB to collect this
information.

Because OSHA?s regional offices do not have ready access to detailed
information on expenditures, they cannot readily monitor the actual use of
funds or state reprogramming of funds from one object class to another. This
could lead state programs to deviate from agreed- upon spending patterns
without informing OSHA or, potentially, to use funds for inappropriate
purposes. For example, of the 12 programs that experienced

19 For example, under the Single Audit Act (31 U. S. C. 7501 et seq.), any
state spending $300,000 or more in federal awards is responsible for
arranging a financial audit of its total federal accounts. Although the
states must provide to auditors a total listing of all federal grants,
auditors have some flexibility in determining which programs to evaluate in
detail. Since 1997, only four state consultation programs have been included
in detailed audit analyses performed under the Single Audit Act.

20 OMB Circular A- 102 requires grantees to file summary financial status
reports with their funding agencies. However, detailed reporting by object
class is prohibited unless OMB grants a waiver.

Page 21 GAO- 02- 60 Review of OSHA's Consultation Program

declines in their level of activity from fiscal years 1996 to 2000 and
provided us with information on actual expenditures, half reported that they
reprogrammed at least 20 percent of the funds they originally projected to
spend on salaries and benefits to other spending categories in at least 1
fiscal year. There is insufficient information to know whether these
activities violated program requirements or resulted in inappropriate
expenditures.

However, in some cases, it appears that staffing or other long- standing
limitations at the state level could raise questions about the basis for the
state consultation program?s original funding request. For example, in some
cases, state- imposed hiring or salary freezes had been in place for years,
which made it unlikely that vacancies could have been filled. However, state
program officials continued to request funds to fill these vacancies. When
the vacancies were not filled, they reprogrammed these funds into other
areas. While state consultation programs must comply with federal review
procedures to reprogram federal funds, regional office officials stated that
these were not entirely effective tools for keeping up with such actions by
state programs. As a result, OSHA lacks information on the extent to which
state programs are using the funds or potentially reprogramming them into
other areas, and it does not know whether state programs are using the funds
in the best way to achieve agency goals.

Two large consultation programs illustrate the potential problems caused by
this lack of oversight. Both programs experienced decreases in program
activity between fiscal years 1996 and 2000 and appeared to reprogram large
amounts of funding, not necessarily with the knowledge of OSHA regional
officials.

 For each of fiscal years 1996- 2000, the first of these state consultation
programs submitted to OSHA budget projections that included over $300,000
for indirect administrative charges, for a total of approximately $1.76
million. However, end- of- year information on actual expenditures showed
that, for the 5- year period, this program spent approximately $87,000 (or
less than 5 percent) of the $1.76 million on indirect administrative costs.

 Since fiscal year 1996, the second state consultation program had been
developing its planned expenditures on the assumption that the program would
be fully staffed. It did so with full knowledge that this was unlikely to
occur, given that the program was experiencing high and increasing vacancy
rates for consultants (37 percent in fiscal year 2000). As a result, the
program reprogrammed much of the federal funds slated for paying

Page 22 GAO- 02- 60 Review of OSHA's Consultation Program

salaries and benefits to consultants into supplies and equipment or
contracts to obtain promotional services. It also used some of the excess
personnel funding to make up for the shortfall in salaries and benefits paid
to existing staff who received higher than the minimum pay in their grade.
(According to officials with this consultation program, state agencies are
required to budget salaries and benefits as if all staff received the lowest
pay in their grades.)

Many believe that OSHA?s increased effort to emphasize cooperation rather
than confrontation- as signaled by the increase in funds to the Consultation
Program- is a move in the right direction. Yet OSHA has made this commitment
without establishing the performance measurement system needed to determine
how well the Consultation Program contributes to OSHA?s central mission and
resulting goals- reducing workplace injuries and illnesses. OSHA does not
know to what degree it can rely on consultation activities to achieve these
goals or the extent to which it should use consultations in combination with
its enforcement activities. Having adequate goals and measurement systems
for the Consultation Program would allow OSHA to establish a link between
voluntary, cooperative efforts at employers? workplaces and any subsequent
reductions in worker injuries and illnesses at those workplaces and
potentially increase the value of the program for employers and workers.

Although OSHA is in the process of updating IMIS, these efforts, in
themselves, will not improve the agency?s ability to assess the Consultation
Program?s performance, reduce the reporting burden faced by program
managers, or address the confusion that results from programs having too
many indicators to track. Without assessing the kind of information it needs
to measure the Consultation Program?s progress toward attainment of basic
agency goals and including state program managers in this process, OSHA will
be unable to identify those indicators that provide the best measure of
program performance and eliminate those that pose an unnecessary burden on
consultants. Moreover, it will be unable to focus state consultation
programs on those activities that best match the agency?s priorities.

OSHA has not used its funding allocation process to influence the activities
of state programs. In the absence of a link between a state consultation
program?s performance and its funding, state programs have continued to
receive funds equal to what they have received in previous years even if
they reduced the number of consultations they conduct and the number of
hazards they identify. Large programs will continue to be Conclusions

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

rewarded the lion?s share of funding simply because they are large, rather
than because they are successful. Factoring a program?s performance into the
allocation process is no easy task, nor can it necessarily be accomplished
within a short time frame. However, it is very much in line with the GPRA
goal of encouraging agencies to be results oriented and to ensure that the
Consultation Program, as part of OSHA, is doing what it is supposed to do.
Without a link between funding and performance, there can be no assurance
that federal funds are working toward the achievement of agency goals.

With regard to financial oversight, OSHA has insufficient knowledge about
how program funds are being spent. In the absence of clear guidance from
OSHA regarding what factors warrant financial audits, the frequency with
which regional offices audit state consultation programs will continue to
vary. Moreover, programs that are known to have significant fiscal and
management problems, significant declines in program activity, or who
request funds each year for one purpose and then reprogram them for another,
will be able to continue these practices unchecked. OSHA may have the
opportunity to collect the necessary expenditure information without
auditing state programs, but such action may need approval from OMB.
Correcting these problems is challenging because doing so requires
determining how much of the agency?s limited oversight resources should be
devoted to ensuring that funds are spent properly, even when the amount of
these funds might be relatively small. However, without such information,
OSHA is unable to show itself or others how well state consultation programs
are utilizing federal funds.

To strengthen OSHA?s ability to assess the Consultation Program?s progress
toward key agency goals, we recommend that the Secretary of Labor direct the
Assistant Secretary for Occupational Safety and Health to

 require state consultation programs to collect and forward to OSHA data on
injuries and illnesses from employers participating in the Consultation
Program at some period after the consultation is completed for use in
analyzing whether there is a relationship between participation in the
program and reductions in workplace injuries and illnesses and

 review reporting requirements with an eye toward eliminating indicators
that no longer reflect the program while adding new ones that do. Decisions
about which indicators to eliminate or develop should be driven by the kind
of information needed to measure progress toward goals and send a clear
message to state programs on agency priorities. Any decisions should be
accomplished in cooperation with state program managers and Recommendations
for

Executive Action

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

should ultimately contribute to reducing the reporting burden on state
consultation programs. This process should be a key component of any upgrade
the agency performs on IMIS.

To help OSHA ensure that the funding allocation process encourages state
consultation programs to work toward agency goals, we recommend that the
Secretary of Labor direct the Assistant Secretary for Occupational Safety
and Health, in cooperation with state partners, to develop a plan and
timetable for factoring incentives into the allocation process. In so doing,
OSHA may want to (1) develop performance goals for inclusion in the
allocation formula or (2) set aside up to 20 percent of consultation funds
for distribution by the Secretary in accordance with separate criteria that
reward good performance or address specific state program needs.

To help ensure better oversight of state expenditures of consultation funds,
we recommend that the Secretary of Labor direct the Assistant Secretary for
Occupational Safety and Health to

 provide specific guidance to the regional offices regarding the monitoring
of state- level expenditures of Consultation Program funds that includes
criteria or situations under which regional offices should review program
spending or conduct audits of expenditures and

 seek to routinely obtain program expenditure data by object class from
state consultation programs, either through conducting more frequent
financial audits or by obtaining the necessary authority from OMB.

OSHA generally agreed with our recommendations and said the report would
help improve the Consultation Program (see app. I). OSHA?s most significant
concern with the draft report related to the extent to which it should be
held accountable for measuring the Consultation Program?s contribution
toward achieving GPRA performance goals. Among other things, OSHA stated
that it did not believe that GPRA requires annual measurement of individual
programs? contributions toward meeting these goals. As such, OSHA noted that
it had chosen to evaluate the effect of its entire complement of programs
(consultation, enforcement, and others) on achieving performance goals
related to reducing workplace injuries and illnesses.

We did not examine whether OSHA was technically in compliance with GPRA
requirements. However, regardless of the answer to this question, we believe
that it is important for OSHA to know the extent to which the Consultation
Program is contributing to the agency?s primary mission. This type of
information is central to managing the agency?s resources. As such, Agency
Comments

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

we were pleased to note that OSHA acknowledged the need to find
opportunities to evaluate the effectiveness of its individual programs.

OSHA suggested a number of technical changes to improve the accuracy of our
report, which we incorporated as appropriate.

We are sending copies of this report to appropriate congressional
committees, the Secretary of Labor, the Assistant Secretary of Labor for
Occupational Safety and Health, and the Director of OMB. We will also make
copies available to others upon request.

Please contact me or Lori Rectanus on (202) 512- 7215 if you or your staff
have any questions about this report. Other contacts and staff
acknowledgments are listed in appendix II.

Robert E. Robertson Director, Education, Workforce,

and Income Security Issues

Page 26 GAO- 02- 60 Review of OSHA's Consultation Program List of Recipients

The Honorable Edward M. Kennedy Chairman The Honorable Judd Gregg Ranking
Member Committee on Health, Education,

Labor, and Pensions U. S. Senate

The Honorable Paul Wellstone Chairman The Honorable Michael Enzi Ranking
Member Subcommittee on Employment,

Safety and Training Committee on Health, Education,

Labor, and Pensions U. S. Senate

The Honorable John A. Boehner Chairman The Honorable George Miller Ranking
Minority Member Committee on Education and the

Workforce House of Representatives

The Honorable Charlie Norwood Chairman The Honorable Major Owens Ranking
Minority Member Subcommittee on Workforce Protections Committee on Education
and the

Workforce House of Representatives

Appendix I: Comments From the Occupational Safety and Health Administration
Page 27 GAO- 02- 60 Review of OSHA's Consultation Program

Appendix I: Comments From the Occupational Safety and Health Administration

Note: GAO comments supplementing those in the report text appear at the end
of this appendix.

See comment 1.

Appendix I: Comments From the Occupational Safety and Health Administration
Page 28 GAO- 02- 60 Review of OSHA's Consultation Program

See comment 2.

Appendix I: Comments From the Occupational Safety and Health Administration

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

The following are GAO?s comments on the OSHA letter dated September 26,
2001.

1. We clarified report language concerning the purpose of this study. 2. We
modified our recommendation to recognize the importance of state

participation in deliberations leading to changes in the funding allocation
process. GAO Comments

Appendix II: GAO Contacts and Staff Acknowledgments

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

Lori Rectanus (202) 512- 7215 Joseph J. Natalicchio (202) 512- 7215

In addition to those mentioned above, Patrick J. diBattista, Dennis M.
Gehley, Julian P. Klazkin, Leslie E. Pastrano, John G. Smale, Jr., and Wayne
J. Turowski made key contributions to this report. Appendix II: GAO Contacts
and Staff

Acknowledgments GAO Contacts Staff Acknowledgments

(130015)

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