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).
The problem:
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).
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Ben Somberg | November 8, 2010
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 […]
Yee Huang | November 4, 2010
Today CPR President Rena Steinzor and I submitted comments to EPA and each Chesapeake Bay Watershed jurisdiction regarding their draft Phase I Watershed Implementation Plans. The states, we find, need to improve their plans significantly. After more than 20 years of haplessly stumbling toward restoration, often in fits and starts, EPA and the Bay jurisdictions—Delaware, […]
Rena Steinzor | November 4, 2010
There’s a lot of punditry left to be committed about whether and how the GOP majority in the House and the enhanced GOP minority in the Senate will work with the Obama Administration. I’m not optimistic. But even if the President and House Republicans are able to find some small patch of common ground, the […]
Catherine O'Neill | November 3, 2010
Economics professors at two major universities just issued their reviews of industry-funded assessments of the costs of EPA’s proposed boiler rule (via NRDC). The professors’ conclusions: “the methodology is fundamentally flawed;” “the resulting estimates of job losses are completely invalid;” “the results reported are useless;” “if I were grading this, I would give it an F.” These […]
Ben Somberg | November 3, 2010
Tomorrow, Thursday, the American Constitution Society will host a midday panel discussion about the issues and ideas presented in Regulating from Nowhere: Environmental Law and the Search for Objectivity, by CPR Member Scholar Douglas A. Kysar. The panel includes CPR Board Member Amy Sinden. Drawing insight from a diverse array of sources, including moral philosophy, […]
Alice Kaswan | November 2, 2010
As “Cap-and-Trade Is Dead” continues to echo through the empty halls of Congress, California rolled out its proposed greenhouse gas (GHG) cap-and-trade program on Friday. The proposed regulations send a powerful message that, notwithstanding political paralysis at the federal level, the states are proceeding with meaningful climate action. The proposed cap-and-trade program, to be voted on […]
William Funk | November 1, 2010
Cross-posted from ACSblog. The Supreme Court will hear arguments on November 3 in a potentially important preemption case, Williamson v. Mazda Motor of America. In Williamson, a child was fatally injured in a collision when she was sitting in the center rear seat of a Mazda van, secured by a lap belt. The two other […]
Ben Somberg | October 29, 2010
Over at Grist, CPR Member Scholar Frank Ackerman explains why the economic calculations used by the Yes on 23 campaign in California are rather fishy.
Yee Huang | October 28, 2010
On November 7, the National Geographic Channel is premiering Great Migrations, a seven-episode series that chronicles the movements of animals on every continent, from the magnificent monarch butterfly migration from Mexico to northern Canada to the impressive wildebeest migration across the plains of the Serengeti. A report by the United Nations concluded that climate change […]