^®: CRE Regulatory Action of the Week

OSHA Data Initiative Offers Opportunity to Enhance Data Quality

OSHA recently announced in the Federal Register (65 Fed. Reg. 39944, June 28, 2000) an opportunity for the public to comment on its Data Initiative, which is designed to collect employer-specific data on injuries and illnesses in the workplace. Previously, OSHA data collection efforts had been industry-wide, and this aggregation of information tended to mask the experiences of individual employers.

A primary goal of the OSHA Data Initiative is to use government resources more effectively, by identifying and targeting agency interventions to those employers with serious workplace problems. This data will also allow OSHA to shift its performance measures under the Government Performance and Results Act (GPRA) from number of inspections to actual impacts on worker health and safety. This redirection of focus is in keeping with the mission of OSHA and would demonstrate that the agency's efforts are having a real impact.

However, as CRE points out in its comments, the OSHA Data Initiative also provides the agency with an additional opportunity, namely to incorporate and implement a full-fledged Data Quality program. CRE believes that whenever the government gathers information for public dissemination or internal policy purposes, the information should be put through a Data Quality screen. CRE recommended that OSHA develop a Data Quality program which would consist of, at a minimum:

1. Standards for Data Quality;
2. A mechanism for correcting data, be it data collected by OSHA or data published by OSHA in reports, guidelines, scientific studies and risk assessments, industry-wide studies, or enforcement actions;
3. A schedule and plan for substituting improvements in worker health and safety for the number of inspections as a measure of agency performance.

This Data Quality effort would be in keeping with congressional efforts to advance Data Quality principles across the federal government. Particularly, we refer to language accompanying the FY 1999 Omnibus Appropriations Act which asked OMB to issue government-wide standards for Data Quality. The OMB rule envisioned by Congress defines four key terms (quality, objectivity, utility, and integrity) and sets up a mechanism, whereby interested parties could petition agencies for correction of information which does not meet OMB's standard. The Act also requested agencies to issue "conforming" regulations based upon those of OMB. These "conforming" regulations would allow each agency, or component thereof, to tailor OMB's generic regulations to their specific programs. The Data Initiative could be a means to help fulfill OSHA's requirements under the Act.

CRE shared with OSHA its own draft Data Quality rule and offered to assist the agency in the development of its own Data Quality program. CRE strongly supports OSHA's effort to develop meaningful and high-quality information.

View the OSHA Federal Register notice for the Data Initiative.

View the OSHA clearance package for the Data Initiative.

CRE invites all interested parties to submit comments on these issues to CRE's Interactive Public Docket.

Please click below to submit comments regarding OSHA Data Initiative.

OSHA Data Initiative: Interactive Public Docket

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