tag:blogger.com,1999:blog-3229665665713225060.post2637441121137045330..comments2019-10-17T11:23:02.046-04:00Comments on OSHA Aboveground: Evaluations, Yet Again.Abelhttp://www.blogger.com/profile/14667692714141701019noreply@blogger.comBlogger19125tag:blogger.com,1999:blog-3229665665713225060.post-52361962452319455342009-07-22T00:04:35.006-04:002009-07-22T00:04:35.006-04:00The previous post made an excellent point! Too man...The previous post made an excellent point! Too many folks in power don't understand statistics. Unfortunately, they are the ones that do our performance evaluations based on faulty concepts about the role their individual programs play in reducing fatalities, injuries, and accidents in general. On their behalf though, they have to answer once again to the folks that use raw quantitative Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-79766526488605523012009-07-20T13:27:03.288-04:002009-07-20T13:27:03.288-04:00And even if you control for all of the variables, ...And even if you control for all of the variables, the small individual numbers involved make it impossible to determine whether the CSHO made an impact. After all, the worksites that had fatalities this year wil have fewer fatalities next year. Every time. Without fail. And without any intervention. It's simply a matter of statistical probability (both the issue of small numbers and of &Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-35756583282320360672009-07-18T17:52:06.797-04:002009-07-18T17:52:06.797-04:00Sorry for all the spelling errors above, but my dy...Sorry for all the spelling errors above, but my dyslexia got the better of me, and I didn't spell check, hence I will do so in the future.<br /><br />O'ShamanAnonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-32656449007891121172009-07-18T17:47:47.439-04:002009-07-18T17:47:47.439-04:00All of the comments posted on the Evaluation Issue...All of the comments posted on the Evaluation Issue are excellent! Nevertheless, I would like to point out the obvious,i.e., the previous commentor indicated that a particular region reduced fatalties by about 40%, and that Managers in this Region utilize performance metric # 6 presumably for the individual evaluations for CSHOs. However, there is a difference between evaluating the agencies Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-36100294795316041042009-07-16T17:48:04.703-04:002009-07-16T17:48:04.703-04:00RE: Abels's comment about how should we measur...RE: Abels's comment about how should we measure ourselves... it is how well we reduce injuries, illnesses and deaths. If you don't think we effect that, then you're in the wrong business. There is a region in the country which reduced fatalities by more than 40% in 2008 and then an additional 40% so far in 2009. The managers in this region have a performance element, #6, Special Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-40913582960978189052009-07-15T10:41:39.486-04:002009-07-15T10:41:39.486-04:00To the last commenter who said, "I'd like...To the last commenter who said, "I'd like to work in Abel's or RT's office; I'm not so sure about Kane's or Annie's."<br /><br />All I can say is AMEN!Abelhttps://www.blogger.com/profile/14667692714141701019noreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-24834142480740679152009-07-14T20:50:10.014-04:002009-07-14T20:50:10.014-04:00Bottom line, I think, is that a good manager ought...Bottom line, I think, is that a <i>good</i> manager ought to be able to objectively evaluate the work of their CSHOs. First, they should know who is working, who is slow, and who is just skating by. <br /><br />Then come the questions: Whose files don't need constant correcting? Whose citations can be easily defended during an informal due to the amount of documentation? Whose files doesAnonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-47685051890567785092009-07-14T17:47:14.264-04:002009-07-14T17:47:14.264-04:00And it's not as though they didn't have a ...And it's not as though they didn't have a proposal that would have prohibited inspection quotas. The original versino of the bill said `(d) The Secretary shall not establish for any employee within the Occupational Safety and Health Administration (including any regional director, area director, supervisor, or inspector) a quota with respect to the number of inspections conducted, the Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-44970918902496510142009-07-14T17:33:37.004-04:002009-07-14T17:33:37.004-04:00I still don't see it. Inspections are not the...I still don't see it. Inspections are not the results of enforcement activity. They ARE enforcement activity. And the comments at the time talked about it being inappropriate to have quotas for "citations and penalties." There is a difference between telling me you expect me to average 50 or 100 or 10 inspections a year and telling me that you expect me to find serious Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-46247116244225526722009-07-14T14:24:46.010-04:002009-07-14T14:24:46.010-04:00The last snippet in the legislative commentary:
&...The last snippet in the legislative commentary:<br /><br />"H.R. 2877 simply prohibits the Secretary of Labor from using the results of enforcement activities, such as the number of citations issued or penalties assessed, to evaluate its compliance personnel. The bill also prohibits the setting of goals or quotas with regard to enforcement activities by OSHA. The bill does not prohibit or RT Jonesnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-37748191577000334512009-07-14T14:23:07.603-04:002009-07-14T14:23:07.603-04:00In short, the amendment to the Act tells OSHA to &...In short, the amendment to the Act tells OSHA to "stop using numbers," but doesn't propose any solutions, either.<br /><br />So how do we implement a system that remedies the issue of CSHOs worried about walking away from an inspection empty-handed?<br /><br />OSHA could target industries with high injury rates and then, if and when the rates go down, OSHA can proclaim success. ButRT Jonesnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-39766407778230125902009-07-14T14:09:22.053-04:002009-07-14T14:09:22.053-04:00And here's a couple more interesting comments:...And here's a couple more interesting comments:<br /><br />"Many employers have complained that OSHA inspectors care less about worker safety than they do about meeting perceived quotas for citations and penalties. While OSHA has not used quotas, it has used citations and penalties as performance measures. I have put a stop to this practice. OSHA's performance is now measured by its RT Jonesnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-36837011182356014292009-07-14T14:06:17.586-04:002009-07-14T14:06:17.586-04:00Well, the comments to the Act suggest these proble...Well, the comments to the Act suggest these problems were around ten years ago:<br /><br />"OSHA seems to suffer an identity crisis. The Administration calls upon OSHA to reinvent itself. OSHA's response is long on rhetoric and short on substance. During its life, OSHA has accumulated the baggage of an enforcement agency preoccupied with quotas and citations and penalties. Despite RT Jonesnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-53311464746688528642009-07-13T18:12:09.213-04:002009-07-13T18:12:09.213-04:00RT back on my May 26 post I asked how we should me...RT back on my May 26 post I asked how we should measure success, so far I haven't heard any good answers. I have no problem reinventing ourselves again, but we need to have goals that are measurable, otherwise how do we know if we're meeting those goals? So what should our goals be and how do we measure them?Abelhttps://www.blogger.com/profile/14667692714141701019noreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-58719187053488326082009-07-13T17:45:03.565-04:002009-07-13T17:45:03.565-04:00To answer the anonymous commenter who asked "...To answer the anonymous commenter who asked "Food for thought: what's the CSHO's remedy if his or her AD imposes a quota?" The answer is that evaluations are covered under the union contract and if a CSHO (or any one covered by the contract) has an issue with their evaluation they can file a grievance.Abelhttps://www.blogger.com/profile/14667692714141701019noreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-66234158913626475732009-07-13T16:00:15.034-04:002009-07-13T16:00:15.034-04:00Even more interesting to read the Congressional co...Even more interesting to read the Congressional comments and views on this from back in '98:<br /><br />http://thomas.loc.gov/cgi-bin/cpquery/?&sid=cp105pOPWa&refer=&r_n=hr445.105&db_id=105&item=&sel=TOC_1135&<br /><br /><br />Over the past three years, the Committee has held numerous hearings on issues surrounding the OSHAct and how OSHA operates. In a series of RT Jonesnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-2641791317296414732009-07-13T15:24:21.718-04:002009-07-13T15:24:21.718-04:00For what it's worth, the law is codified at 29...For what it's worth, the law is codified at 29 U.S.C. 657(h). <br /><br />Food for thought: what's the CSHO's remedy if his or her AD imposes a quota? Can the CSHO file a lawsuit? Or take it up with another agency, kind of like an EEOC claim?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-33919285136939042272009-07-13T14:02:12.944-04:002009-07-13T14:02:12.944-04:00I think, right or wrong, the argument is that thos...I think, right or wrong, the argument is that those managers aren't "directly" involved in the enforcement action.Abelhttps://www.blogger.com/profile/14667692714141701019noreply@blogger.comtag:blogger.com,1999:blog-3229665665713225060.post-15256164683315471282009-07-12T21:48:23.051-04:002009-07-12T21:48:23.051-04:00Every manager is evaluated by inspections so that ...Every manager is evaluated by inspections so that law is useless.Anonymousnoreply@blogger.com