In a post the other week, Celeste Monforton at The Pump Handle gives a great example of health/safety protection being evaluated the wrong way ("Contractor racks up mine safety violations and unpaid penalties, also wins safety awards.") Monforton points to a large construction company that seems to be collecting safety awards while simultaneously being cited for numerous safety violations (and in January, an employee was killed at a work site).
Sure, whether workers sustain an injury is something to pay attention to, no doubt. But, with some employers' policies that discourage injury reporting, workers' reticence about telling their boss about a chronic work-related health problems, or workers' comp rules that compel workers to return to work before they are fully healed, lost-time injury rates alone don't cut it.
Laws like the Occupational Safety and Health Act set out goals; to what extent are they being met? Evaluating success or progress in the health and safety contexts -- workplace injuries stopped, toxic chemical exposures reduced, food less contaminated, water de-polluted -- is important, and complicated. We need to measure better.
I'm talking here both about evaluations being done by private actors as well as by the government itself. CPR Member Scholars Sid Shapiro and Rena Steinzor have proposed that agencies adopt "positive metrics" to evaluate performance. With the guidance of independent experts, agencies would develop comprehensive lists of statutory mandates and the tasks associated with those mandates. The metrics would lay out the who, what, and when of the tasks that support agencies’ achievement of their statutory missions. Those elements would help Congress and other resource managers identify the causes of regulatory shortfalls.
We've got one of our own evaluation projects going currently: CPR scholars devised a set of metrics to evaluate the Chesapeake Bay Watershed states' "Phase I Watershed Implementation Plans" for decreasing pollution into the Bay. Those plans, we've argued, need to show not just a path to achieving the needed pollution reductions, but also be transparent to the public. It's not about just one estimated pollution reduction number -- it's a broad array of technical, financial and administrative factors that will determine the plans' success. (As for the current health of the Bay, that's something that's been measured fairly well).