Here are the two comments I received on how OSHA could measure success:

"The use of the data collected for the Site Specific Targeting Program might be a starting point since the same sic codes are used most of the time A comparision of older establishment lists with newer lists could help establish repeats and provide an indicator of improvement.
Just a thought...."

This is a good thought. We could do it in two ways (maybe concurrently?), first by looking at the industries and seeing how their injury rates change over time, and second by looking at individual sites that show up year after year. I'm just not sure how we would pull the second part off, tracking something like this is important, yet our IMIS system is so antiquated that we couldn't use it for something like this, and who knows when or if the new system will ever be rolled out.

Someone pointed out to me that the Silica NEP calls for mandatory follow-up of sites where overexposures were found, which is a similar kind of thing.

The downside to these two measures is that they are micro-measures instead of macro-measures. In other words, they measure only the direct impact of inspections and not the secondary impact or the impact of outreach.

The second comment:

"OSHA success may be so small that it is hard to measure! No one high in OSHA wants to measure this because it might cause the OSHA Administrators to have a very red face. Granted, workplace safety has improved over the decades but it might be a tough sell if the results of OSHA efforts are singled out from other workplace safety forces such as the high cost of workplace accidents from worker's comp rates, lawsuits, etc. So, I don't think OSHA management really wants the answer to this question cause they might not like it and then they would be put in the position of having to defend the OSHA program. For now, OSHA management wants to let sleeping dogs lie and to not disturb them."

Sorry, I don't buy it, or the OSHA Underground's anti-national office portion of today's post (although I do appreciate the mention). I know too many people who work in the NO, most of whom believe in what we're trying to do just as strongly as I do.

Do you know the biggest difference between the NO and an AO? It's who we fight with. As CSHOs our fights are usually with employers and our own attorneys, but the NO has to fight politicians, lobbyists and the press. Even though we're probably involved in more directly confrontational fights, I think it's still easier than fighting politicians, lobbyists and the press.

Don't misunderstand, I'm not trying to suggest that the NO should be worshiped from afar, after all, I've spent more than my share of time mocking them, sometimes because they deserve it and sometimes just because it's fun, but I do appreciate the fact that they buffer us from direct assault by politicians and the national press (I should also acknowledge that the RO also does some of this, even though I mock them almost as much as the NO).

No, I don't think the problem is that we're afraid to look at ourselves, I think the problem is we may not know how to look at ourselves.