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Pilot OSHA Citation Process Increases Employer Responsiveness

G Chojnacki

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hrough a nationwide randomized controlled trial, we tested whether employers who were cited for health and safety violations would be more responsive if OSHA changed the way it issues and follows up on citations. Employer responsiveness is a critical component of fulfilling OSHA’s mission; when employers do not respond to citations, the agency cannot verify that workplace hazards have been corrected, and local offices must refer unresolved citations to the national office for enforcement and debt collection, a costly and burdensome process.As part of the new process, OSHA staff: (1) gave employers a new handout as part of the preview of the citation process when they conducted their inspections, (2) used a new cover letter for citations, and (3) provided timely reminders, including a postcard and follow-up phone call, to employers about their response options and the corresponding deadlines. With the new process, OSHA staff also had access to Spanish-language versions of all materials, which had never been provided consistently on a national scale. The new process was based on insights from experienced field staff combined with findings from behavioral research, and aimed to address possible behavioral factors that may prevent employers from responding to citations.About half of the nation’s local OSHA offices began implementing the new citation process in June 2015, while the other half continued their normal process, which involves only sending a comprehensive, written citation package. (The test included 27 states in 8 of OSHA’s 10 regions, and excluded two regions in which nearly all of the states operate their own job safety and health plans.) We then used OSHA records collected at the end of November 2015 to determine whether employers had positively engaged with OSHA in response to a citation.