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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

August 2010: 

Whistleblower Protection: 

Sustained Management Attention Needed to Address Long-standing Program 
Weaknesses: 

GAO-10-722: 

Contents: 

Letter: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Briefing Slides and Attachments: 

Appendix II: Comments from the Department of Labor: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Abbreviations: 

FTE: full-time equivalent: 

OSH Act: Occupational Safety and Health Act of 1970: 

OSHA: Occupational Safety and Health Administration: 

Labor: Department of Labor: 

STAA: Surface Transportation Assistance Act of 1982: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

August 17, 2010: 

Congressional Requesters: 

Workers who "blow the whistle" on prohibited or unlawful practices 
that they discover during their employment can play an important role 
in the enforcement of federal laws. However, these whistleblowers may 
also risk reprisals from their employers, sometimes being demoted, 
reassigned, or fired. Federal laws establish whistleblower protection 
processes, whereby workers who believe that they have faced 
retaliation for blowing the whistle can report their allegations to 
the appropriate federal agency, which then determines the merit of 
their claims. The Whistleblower Protection Program at the Department 
of Labor's (Labor) Occupational Safety and Health Administration 
(OSHA) is responsible for receiving and investigating most 
whistleblower complaints filed by nonfederal workers. 

For over 20 years, we have reported that OSHA has focused too little 
attention on the whistleblower program.[Footnote 1] Most recently, in 
January 2009, we reported that OSHA has struggled to provide 
investigators with the skills and resources they need to do their 
jobs, and has not developed adequate internal controls to ensure that 
criteria and standards for investigating complaints are consistently 
followed across its regions. At that time, we recommended that OSHA 
take several actions, including ensuring that investigators have 
necessary equipment and enhancing its audit program to provide for 
independence and accountability. 

In this context, you asked us to update our review of the program and 
report on OSHA's efforts to make improvements, including implementing 
our recommendations. We addressed the following research questions: 
(1) What steps have been taken to ensure that whistleblower 
investigators have the necessary training and equipment to do their 
jobs? (2) To what extent does the whistleblower program have adequate 
internal controls to ensure effective and efficient investigations? 

On June 15, 2010, we briefed your staff on the results of our 
analysis. This report formally conveys the information provided during 
this briefing (see appendix I for the briefing slides and 
attachments). In summary, we found that OSHA has done little to ensure 
that investigators have the necessary training and equipment to do 
their jobs, and that it lacks sufficient internal controls to ensure 
that the whistleblower program operates as intended. More 
specifically, we found the following: 

* OSHA enhanced its whistleblower training, establishing two mandatory 
2-week courses between 2007 and 2008, but has not ensured attendance 
or taken steps to ensure that investigators have necessary equipment 
to do their jobs. Nearly all investigators have been credited with 
taking the first mandatory course, but just over 60 percent has taken 
or registered for the second mandatory course. Additional training on 
specific, complex statutes has not been developed because of resource 
constraints, according to OSHA officials. Our last review found that 
many investigators lacked basic equipment, such as portable printers, 
to do their jobs. OSHA officials have not implemented our prior 
recommendation to establish minimum equipment and software standards, 
citing resource constraints. 

* OSHA lacks sufficient internal controls to ensure that the 
whistleblower program operates as intended due to several factors, 
including inconsistent program operations, inadequate tracking of 
program expenses, and insufficient performance monitoring. Program 
operations vary by region in significant ways, as exemplified by 
differing standards used to screen out complaints, and by some regions 
not having formally trained supervisors who approve investigation 
decisions. The whistleblower program's national office lacks 
mechanisms, such as access to accurate data and actual case files, to 
monitor compliance with policies and procedures. Although each region 
operates within a budget allocation for personnel slots (also known as 
full-time equivalents or FTEs) and other expenses, they have wide 
latitude in how they deploy resources across programs, in part because 
they do not report whistleblower expenses separately from other 
programs. Finally, OSHA has not made assessing program performance a 
priority, as evidenced by the lack of program-specific goals or 
measures in key performance documents. 

We used several methodologies to develop our findings. To describe 
OSHA's efforts to ensure that investigators have the necessary 
training and equipment to do their jobs, we reviewed program guidance 
and prior GAO studies, spoke with OSHA officials about training and 
equipment for investigators, and analyzed OSHA training data. To 
assess the reliability of the data, we spoke with program officials 
about how the training records were developed and checked the data 
with a variety of regional officials, who generally corroborated the 
information. We found the data to be sufficiently reliable for this 
report. To assess the extent to which the whistleblower program has 
adequate internal controls, we reviewed OSHA audit guidance and 
studies of the program as well as GAO's standards for internal 
controls in the federal government,[Footnote 2] queried all OSHA 
regional administrators on investigator hiring status, and analyzed 
OSHA organizational charts. In addition, to help address both 
objectives, we interviewed OSHA officials in its headquarters and four 
regional offices at various levels of management. We selected regions 
on the basis of their varying size and geography, and chose 
interviewees who were knowledgeable about ongoing initiatives. 

We conducted this performance audit from March 2010 to August 2010 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Recommendations for Executive Action: 

To improve program performance and oversight, we are recommending that 
the Secretary of Labor require OSHA to take several actions: 

* Ensure that all investigators complete mandatory training. 

* Require staff who supervise investigators to complete the mandatory 
investigator training. 

* Track whistleblower program expenses, including FTEs, separately 
from other OSHA programs, and annually report these expenses to 
Congress. 

* Develop an action plan, with specific milestones, for addressing 
identified internal control weaknesses. This plan should include 
mechanisms for strengthening the whistleblower national office's 
control over the program. 

* Incorporate strategic goals specifically for the whistleblower 
program into Labor's strategic plan, and develop performance measures 
to track progress in achieving these goals. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to OSHA for its review and comment. 
OSHA provided written comments, which are reproduced in appendix II. 
In its response, OSHA concurred with two of our recommendations and 
cited ongoing activities in areas covered by the other three. OSHA 
also expressed concern with some of our findings. 

Regarding our recommendations that all investigators and their 
supervisors complete mandatory investigator training, OSHA agreed and 
said that it was taking steps to ensure that this training was 
completed within the next 18 months. 

On the remaining recommendations, OSHA did not agree or disagree, 
noting instead its relevant ongoing activities: 

* Regarding our recommendation to track whistleblower program 
expenses, including FTEs, separately and report these to Congress, 
OSHA commented that it currently tracks hiring and staffing in the 
whistleblower program, but OSHA was silent on the recommendation to 
report expenses separately to Congress. In our review, we learned that 
OSHA's budget office maintains a database of OSHA personnel, but it 
does not track whistleblower program expenses separately. Given the 
wide latitude that regions have in deploying resources among programs, 
without centralized tracking of expenses, the budget office is not 
well positioned to ensure that resources intended for the 
whistleblower program are being used accordingly. Having such 
information is essential for effective program management and for 
safeguarding resources. Reporting this information to Congress would 
inform decision making about OSHA's budgetary needs. 

* Regarding our recommendation that OSHA develop an action plan, with 
milestones, for addressing internal control weaknesses, officials 
commented that OSHA plans more study before taking action. Officials 
noted that they are exploring a variety of issues, including internal 
control weaknesses, through its ongoing review of the whistleblower 
program. They expect this review to culminate in recommendations to 
improve program delivery and consistency. Given several reviews of the 
whistleblower program conducted over the past 20 years, OSHA's 
management already has the information it needs to address many of its 
internal control weaknesses. It is important that OSHA begin to make 
progress in addressing these issues. 

* Regarding our recommendation to develop strategic goals and 
performance measures specifically for the whistleblower program, OSHA 
commented that it is currently developing the fiscal year 2011-2016 
strategic plan. Officials noted that the plan will contain an outcome 
goal related to ensuring workers have voice in the workplace, and that 
they will incorporate related performance measures in OSHA's operating 
plan. However, it is not clear from the agency's comments what role 
the whistleblower program would play in these efforts. We urge OSHA to 
specifically cite the program in the final strategic plan and to 
include appropriate whistleblower performance measures in its 
operating plan. OSHA also provided the following comments on some of 
our findings: 

* In our characterization of OSHA's organizational structure for the 
national office, officials noted that the whistleblower program 
reports directly to the Director of Enforcement Programs. However, 
documents we obtained from OSHA in follow-up confirm a structure as we 
reported it. As a result, we have not modified our report to reflect 
the requested change. 

* On meeting investigators' equipment needs, OSHA stated in its 
comments that it will be providing new computers to all field staff, 
including whistleblower investigators, by the end of the first quarter 
of fiscal year 2011. Purchasing new computers is a good first step, 
but doing so does not go far enough in addressing some of the basic 
equipment needs of investigators. We urge OSHA to establish minimum 
standards for equipment and computer software and ensure that these 
standards are met as soon as possible, as we recommended in our 
January 2009 report. 

* On transparency, OSHA disagreed with our finding that the process it 
used to allocate the 25 FTEs was not transparent, citing the multistep 
approach it used in arriving at the final allocation. OSHA officials 
noted that the approach they used and the final allocation were 
explained to all Regional Administrators after the Assistant Secretary 
of Labor for OSHA made the final decision. OSHA officials have not 
provided documents to support this assertion, and the documents 
received from OSHA during our review support the finding that the 
process was not transparent. Moreover, as we noted in our report, some 
of the regional officials with whom we spoke during our review, 
including Regional Administrators, did not know how the final decision 
was made. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the 
appropriate congressional committees, the Secretary of Labor, and 
other interested parties. The report will also be available at no 
charge on GAO's Web site at [hyperlink, http://www.gao.gov]. 

If you or your staffs have any questions about this report, please 
contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff members who made key 
contributions to this report are listed in appendix III. 

Signed by: 

George A. Scott: 
Director, Education, Workforce, and Income Security Issues: 

List of Requesters: 

The Honorable Tom Harkin: 
Chairman: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

The Honorable Patty Murray: 
Chairman: 
Subcommittee on Employment and Workplace Safety: 
Committee on Health, Education, Labor, and Pensions: 
United States Senate: 

The Honorable George Miller: 
Chairman: 
Committee on Education and Labor: 
House of Representatives: 

The Honorable Lynn Woolsey: 
Chairwoman: 
Subcommittee on Workforce Protections: 
Committee on Education and Labor: 
House of Representatives: 

[End of section] 

Appendix I: Briefing Slides and Attachments: 

Whistleblower Protection: 

Sustained Management Attention Needed to Address Long-standing Program 
Weaknesses: 

Briefing for Congressional Requesters: 

June 15, 2010: 

Overview: 
* Introduction; 
* Objectives; 
* Scope and Methodology; 
* Summary of Findings; 
* Background; 
* Findings; 
* Conclusions; 
* Recommendations. 

Introduction: 

The Whistleblower Protection Program is intended to provide nonfederal 
workers with protection from retaliatory action when they identify 
prohibited practices at their employers' businesses. 

For over 20 years, we have reported that OSHA focused too little 
attention on the program.[Footnote 3] Most recently, we reported that 
OSHA: 

* Has struggled to provide investigators with the skills and resources 
they need to effectively do their jobs; 

* Has focused too little attention on developing internal controls to 
ensure that criteria and standards for investigating complaints are 
consistently followed. 

We recommended that OSHA take several actions including ensuring 
investigators have necessary equipment and establishing an audit 
program that provides for independence and accountability.[Footnote 4] 

[End of section] 

Objectives: 

You asked us to update our earlier review of the program and report on 
efforts to make improvements, including the status of OSHA's efforts 
to implement our recommendations. 

We addressed the following research objectives: 

(1) What steps have been taken to ensure that whistleblower 
investigators have the necessary training and equipment to do their 
jobs? 

(2) To what extent does the whistleblower program have adequate 
internal controls to ensure effective and efficient investigations? 

[End of section] 

Scope and Methodology: 

To address our objectives, we: 

* Reviewed program guidance, and OSHA and GAO studies of the program; 

* Interviewed OSHA officials in its headquarters and four regional 
offices at various levels of management; 
- We selected regions based on their varying size and geography, and 
chose interviewees who were knowledgeable about ongoing initiatives; 

* Queried all OSHA regional administrators on investigator hiring 
status; 

* Analyzed organizational charts and staffing and training data; and; 

* Reviewed GAO's standards for internal control in the federal 
government. 

We conducted this performance audit from March to June 2010 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Summary of Findings and Recommendations: 

1. OSHA established training curricula for investigators, but has done 
little to ensure that investigators attend training or have the 
necessary tools to do their jobs. 

2. OSHA lacks sufficient internal controls to ensure that the 
whistleblower program operates as intended. 

3. We recommend that OSHA ensure investigators and their supervisors 
complete mandatory training, track program expenses, develop strategic 
goals and performance measures that are specific to the whistleblower 
program, and develop an action plan for addressing internal control 
weaknesses. 

[End of section] 

Background: 

OSHA Investigates Whistleblower Complaints Across a Broad Array of 
Industries: 

OSHA currently has responsibility for investigating whistleblower 
complaints under 18 different statutes. 

* About two-thirds of complaints arise under the Occupational Safety 
and Health Act of 1970 (OSH Act). 

* Many of the other complaints arise under a broad array of other 
statutes that cover industries such as nuclear power, transportation, 
pipeline infrastructure, consumer product safety, securities, and 
several environmental areas. 

* To be effective, investigators must have a general understanding of 
the underlying working environment in the broad range of industries, 
as well as substantive provisions in each statute, according to 
program officials. 

Figure: OSHA's Responsibility for Whistleblower Complaints Has Grown 
Over Time: 

[Refer to PDF for image: line graph] 

1970: Occupational Safety and Health Act. 

1972: Federal Water Pollution Control Act. 

1974: Safe Drinking Water Act. 

1976: Toxic Substances Control Act; Solid Waste Disposal Act. 

1977: International Safe Container Act; Clean Air Act. 

1978: Energy Reorganization Act. 

1980: Federal Railroad Safety Act; Comprehensive Environmental 
Response, Compensation, and Liability Act. 

1983: Surface Transportation Assistance Act. 

1986: Asbestos Hazard Emergency Response Act. 

2000: W.H. Ford Aviation Investment and Reform Act for the 21st 
Century. 

2002: Sarbanes-Oxley Act; Pipeline Safety Improvement Act. 

2007: National Transit Systems Security Act. 

2008: Consumer Product Safety Improvement Act. 

2010: Patient Protection and Affordable Care Act. 

Note: These years represent the date that the whistleblower provisions 
were added to the relevant statutes, and not necessarily the date of 
the original enactment of the statutes themselves, or the date that 
OSHA was given responsibility for enforcement. 

Source: GAO analysis of relevant statutes. 

[End of figure] 

Figure: But the Number of Whistleblower Investigators Has Remained 
Relatively Flat: 

[Refer to PDF for image: vertical bar graph overlaid on previous 
figure] 

Year: 1975; 
Number of investigators: 12. 

Year: 1980; 
Number of investigators: 60. 

Year: 1985; 
Number of investigators: 59. 

Year: 1990; 
Number of investigators: 66. 

Year: 1995; 
Number of investigators: 59. 

Year: 2000; 
Number of investigators: 63. 

Year: 2005; 
Number of investigators: 70. 

Year: 2010; 
Number of investigators: 80. 

Note: Data since 1978 include regional supervisory investigators. 
Number for 2010 is as of April 1, 2010. 

Source: OSHA administrative data. 

[End of figure] 

Figure: OSHA Operates the Whistleblower Program Through Ten Separate 
Regions: 

[Refer to PDF for image: map of the U.S.] 

In several regions, program operations occur in multiple offices 
called area offices. 

Region 1: 
Connecticut: 
Maine: 
Massachusetts: 
New Hampshire: 
Rhode Island: 
Vermont: 

Region 2: 
New Jersey: 
New York: 
Puerto Rico: 
Virgin Islands: 

Region 3: 
Delaware: 
District of Columbia: 
Maryland: 
Pennsylvania: 
Virginia: 
West Virginia: 

Region 4: 
Alabama: 
Florida: 
Georgia: 
Kentucky: 
Louisiana: 
Mississippi: 
North Carolina: 
South Carolina: 
Tennessee: 

Region 5: 
Illinois: 
Indiana: 
Michigan: 
Minnesota: 
Ohio: 
Wisconsin: 

Region 6: 
Arkansas: 
New Mexico: 
Oklahoma: 
Texas: 

Region 7: 
Iowa: 
Kansas: 
Missouri: 
Nebraska: 

Region 8: 
Colorado: 
Montana: 
North Dakota: 
South Dakota: 
Utah: 
Wyoming: 

Region 9: 
Arizona: 
California: 
Nevada: 

Region 10: 
Alaska: 
American Samoa: 
Guam: 
Hawaii: 
Idaho: 
Oregon: 
Washington: 

Source: OSHA. 

[End of figure] 

Figure: OSHA's Organizational Structure Includes a National Office 
that Sets Whistleblower Policies: 

[Refer to PDF for image: organization structure] 

Senior Executive Service (SES) level: 

Top level: 
* Assistant Secretary of Labor for OSHA. 

Second level, reporting to Assistant Secretary of Labor for OSHA: 
* Deputy Assistant Secretary of Labor for OSHA. 

Third level, reporting to Deputy Assistant Secretary of Labor for OSHA: 
* OSHA Director of Enforcement; 
* Ten OSHA Regional Administrators. 

[End Senior Executive Service (SES) level] 

Fourth level, reporting to OSHA Director of Enforcement: 
* Deputy Director of Enforcement. 

Fourth level, reporting to OSHA Regional Administrators: 
* Organization varies by region. 

Fifth level, reporting to Deputy Director of Enforcement: 
* Whistleblower Program, National Office Director. 

Source: GAO analysis of OSHA documents. 

[End of figure] 

Internal Controls Are Key to Achieving Desired Results: 

Internal controls[Footnote 5] are an integral part of an agency's 
efforts to ensure: 

* Effectiveness and efficiency of operations; 

* Reliability of financial reporting; 

* Compliance with applicable laws and regulations. 

The internal control standards include a focus on: 

* Management's commitment to a positive, disciplined work environment 
and staff competence; 

* Activities or mechanisms to enforce management's directives; 

* Monitoring to assess the quality of performance over time. 

[End of section] 

Findings: 

Objective 1: OSHA Has Done Little to Ensure that Investigators Have 
Necessary Tools: 

Training: OSHA established training curricula for investigators, but 
has done little to ensure that investigators attend mandatory training. 

Equipment: OSHA has not ensured that investigators have the necessary 
tools to do their jobs. 

Objective 1: Training: OSHA Established Mandatory Training but 
Attendance has not been Enforced: 

OSHA enhanced its whistleblower training, establishing two mandatory 2-
week courses between 2007 and 2008. 

* Nearly all investigators have been credited with taking the first 
course, which covers basic investigation skills for OSH Act complaints. 

* Just over 60 percent[Footnote 6] of investigators have taken or are 
registered for the second course, which covers how to investigate 
complaints filed under non-OSH Act statutes. 

* Despite developing the mandatory courses, OSHA has not taken steps 
to ensure that all investigators attend the training. 

Figure: Attendance in the Second Training Course is Low in Some 
Regions: 

[Refer to PDF for image: horizontal bar graph] 

Percent of investigators who have taken or registered for the second 
mandatory course: 

Region 1: 60%; 
Region 2: 100%; 
Region 3: 45%; 
Region 4: 30%; 
Region 5: 40%; 
Region 6: 55%; 
Region 7: 100%; 
Region 8: 100%; 
Region 9: 100%; 
Region 10: 100%. 

Source: GAO analysis of OSHA data as of June 10, 2010. 

Note: To assess the reliability of the data, we spoke with program
officials about how the training records were developed and spoke with 
a variety of regional officials who generally corroborated the data. 
16 We found the data to be sufficiently reliable for this report. 

[End of figure] 

Investigators Have Identified the Need for Additional Training: 

Investigators have identified—-and officials have agreed—-the need for 
more training, particularly for some of the complex statutes where 
specialized knowledge is required. For example, 

* The subject matter of one statute necessitates that investigators 
understand complex securities and navigate complicated legal issues in 
order to conduct an investigation. 

Yet, specialized training on specific, complex statutes has not been 
developed due to resource constraints, according to officials. 

OSHA's Lack of Focus on Training May Jeopardize the Quality and 
Consistency of Investigations: 

Ensuring that staff are sufficiently trained to do their jobs is a key 
component of good internal controls. 

Program officials have been unsuccessful in ensuring participation in 
mandatory training and have not made developing more training a 
priority. 

According to one senior official, some regions are unwilling to send 
investigators to mandatory training, citing a lack of need for such 
training. 

Complexity of some investigations has increased, particularly given 
the addition of responsibilities under some complex statutes enacted 
since 2002. 

Relying solely on informal training, such as that obtained on the job, 
cannot ensure that all investigators consistently acquire needed 
knowledge to do their jobs. 

OSHA Has Not Developed Plans to Address Equipment Needs: 

Our last review found that many investigators lacked necessary basic
equipment, such as portable printers, and software to do their jobs. 

These unmet needs varied by region. 

We recommended that OSHA establish minimum standards for equipment and 
computer software and ensure that these standards are met. 

OSHA has not developed such standards and has no plans to do so, 
citing resource constraints. 

Officials told us that new laptops will be distributed to staff but 
could not tell us when. 

[End of Objective 1] 

Objective 2: OSHA Lacks Sufficient Controls to Ensure Whistleblower 
Program Operates as Intended: 

Oversight and Accountability: OSHA lacks effective mechanisms
to hold regions accountable for compliance with program policies. 

Tracking Resources: OSHA does not track whistleblower program 
resources. 

Assessing Performance: OSHA has not made assessing program performance 
a priority. 

Objective 2: Oversight and Accountability: Program Operations Vary by 
Region: 

OSHA's 10 regions operate autonomously and are able to make key
decisions with only limited oversight and accountability, including: 

* How to investigate and process cases, such as: 
- Screening complaints; 
- Docketing cases in the program's tracking system; 
- Deciding case outcomes. 

* How to allocate resources. 

* How investigators are supervised. 

We previously found that regional variation in the standards used to 
screen out complaints, for example, may have led to differing outcomes 
for whistleblowers. 

Figure: Supervisors Approving Investigation Decisions in At Least Two 
Regions Lack Formal Whistleblower Training: 

[Refer to PDF for image: illustration] 

Region A: 

Deputy Regional Administrator: 
* Assistant Regional Administrator; 
- Area Director (Approves decisions recommended by investigator); 
- Investigator (Formally trained in Whistleblower Program). 

Region B: 

Deputy Regional Administrator: 
* Assistant Regional Administrator; 
* Program Manager (Formally trained in Whistleblower Program); 
- Area Director (Approves decisions recommended by investigator); 
- Investigator (Formally trained in Whistleblower Program). 

Region C: 
Deputy Regional Administrator: 
* Assistant Regional Administrator; 
* Regional Supervisory Investigator (Approves decisions recommended by 
investigator); (Formally trained in Whistleblower Program); 
- Investigator (Formally trained in Whistleblower Program). 

Source: GAO analysis of OSHA documents. 

[End of figure] 

OSHA Lacks a Consistent Appeals Process for OSH Act Complaints: 

No statutory process exists for appeals under the OSH Act, but the 
whistleblower manual provides for the national office to decide such 
appeals. 

To improve the timeliness of appeal decisions, three regions are 
piloting a process in which OSH Act appeals are decided within the 
region, each using different methods. 

* Region 4: The Area Director who approved the original decision 
drafts a response to the appeal for the regional administrator's 
consideration; 

* Region 5: A committee of regional and area office management reviews 
the case and decides the appeal; 

* Region 6: The region's solicitor reviews the appeal and recommends a 
decision to the regional administrator. 

Some OSHA officials questioned whether appeals receive an independent 
review when decided within the region that conducted the investigation. 

The Program's National Office Has Little Ability to Ensure Regional 
Compliance with Policies: 

The whistleblower program's national office lacks the mechanisms, such 
as access to accurate data and actual case files, to ensure compliance 
with program policies and procedures. 

* Electronic data on cases exist, but we reported in 2009 that the
data on outcomes and processing times are often inaccurate. 

* We recommended that OSHA develop a mechanism to ensure that the data 
on cases are accurate and that regions are held accountable for data 
accuracy. 

OSHA has proposed triennial reviews of each region's cases to improve 
data accuracy and regional compliance with program policies, but has 
not established plans for implementing such reviews. 

We Previously Found that OSHA's Audit Program Does Not Hold Regions 
Accountable for the Quality and Consistency of Investigations: 

More than one year ago, we found: 

* The whistleblower program was not routinely or consistently audited; 

* Audits, when performed, lacked independence; 

* Audit guidance lacked clear criteria; 

* Complete audit findings were not routinely communicated to OSHA 
headquarters; 

* No mechanism existed for ensuring audit findings were addressed. 

OSHA's Audit Program Remains Ineffective: 

We made several recommendations to OSHA to bring the audit system in 
line with government standards. 

Audits are central in any effort to ensure that criteria and standards 
for investigating complaints are consistently followed. 

While OSHA has made minor changes to the audit program, the steps 
taken have not fully addressed our prior recommendations. 

Objective 2: Tracking Resources: 

Few Safeguards Exist to Ensure that Resources are Used as Intended: 

Neither OSHA's regions nor its central budget office track 
whistleblower expenses separately from other programs. 

* Although each region operates within a budget allocation for 
personnel slots (FTE) and other expenses, they have wide latitude in 
how they deploy resources across programs. 

* OSHA received funding that supported 25 additional FTEs for 
whistleblower investigators in fiscal year 2010, but some program 
officials have expressed concern that the new allocation may be used 
for non-whistleblower activities. 

* OSHA's budget office does not monitor whether new FTEs intended for 
the whistleblower program are being used for other programs. 

The Process Used to Allocate the 25 New FTEs was Not Transparent: 

OSHA's Directorate of Enforcement developed a proposal for allocating 
the new FTEs that was based on average caseloads and case complexity. 
This allocation was endorsed by the Assistant Secretary. 

The final FTE allocation was markedly different from the one endorsed 
by the Assistant Secretary.[Footnote 7] 

- Some regions received as many as 3 fewer investigators than 
proposed, and another as many as 3 more. 

- Some regional officials have expressed confusion about how the final 
decision was made. 

Objective 2: Assessing Performance: 

OSHA Has Not Made Assessing Whistleblower Program Performance a High 
Priority: 

Key performance documents do not contain specific goals or measures 
for the whistleblower program. These include: 

* OSHA's portion of Department of Labor's strategic plan. 

* Budget justifications. 

Timeliness is the only performance measure OSHA tracks for the 
program, yet such measurement has significant limitations. 

* We previously found that OSHA's data on investigation timeliness are 
unreliable. 

* Measuring timeliness alone may provide incentive to close cases 
prematurely. 

OSHA Is Planning a Review of Whistleblower Program Operations: 

OSHA officials recently stated that they would conduct a "top-to-
bottom" review of the program before addressing any of the 
longstanding issues in the whistleblower program, despite the several 
reviews already completed. 

Three OSHA mid-level employees with program familiarity are conducting 
the review in addition to their regular work. 

Senior officials expect the review to cover operations in the 
program's national office and in the regions. 

A final report, which may contain recommendations for improvement, may 
be ready by this fall, according to officials. 

[End of Objective 2] 

[End of section] 

Conclusions: 

For over 20 years, we have repeatedly found that OSHA lacks sufficient 
internal controls to ensure that standards for investigating 
whistleblower complaints are consistently followed. 

* Little progress has been made in implementing our recommendations 
[Footnote 8] and significant internal control problems remain. 

In general, "top-to-bottom" reviews can be helpful in understanding 
what needs improvement. But, OSHA management already has much of the 
information it needs to move forward. 

The problems we have identified appear systemic and sustained 
management attention is needed to address them. 

Without further action, whistleblowers will continue to have little 
assurance that a complaint filed in one region would have the same 
outcome if it were filed in another. 

Serious questions remain about whether the whistleblower program is 
appropriately structured or that the national office has sufficient 
control mechanisms to ensure the quality and consistency of 
investigations. 

In addition, without improved accountability for program resources, it 
may be difficult for OSHA to demonstrate that it is using the 
resources as Congress intended. 

Further, absent goals specifically related to the whistleblower 
program, OSHA will continue to lack the ability to gauge program 
performance. 

[End of section] 

Recommendations: 

To improve performance and oversight of the whistleblower program,
the Secretary of the Department of Labor should require OSHA to: 

* Ensure that all investigators complete mandatory training; 

* Require area directors who supervise investigators to complete the 
mandatory investigator training; 

* Track whistleblower program expenses, including FTEs, separately 
from other OSHA programs, and annually report these expenses to 
Congress; 

* Develop an action plan, with specific milestones, for addressing 
internal control weaknesses that have been identified. This should 
include developing mechanisms to strengthen the national office's 
control over the program; and; 

* Incorporate strategic goals specifically for the whistleblower 
program into Labor's strategic plan and develop performance measures 
to track progress in achieving them. 

[End of section] 

Attachment I: Status of Implementing GAO Recommendations[A]: 

GAO Recommendation (January 2009): OSHA should ensure that its new 
information system for tracking whistleblower complaints includes 
information on cases that are screened-out before they are 
investigated and the reasons for being screened-out; 
Department of Labor's Response (April 2009): OSHA is launching a new 
information system by the end of 2010 that will enable staff to enter 
screen outs and their accompanying reasons; 
Status: In progress. 

GAO Recommendation (January 2009): OSHA should establish a mechanism 
to ensure the data on whistleblower complaints are accurate and 
require that the National Office of the Whistleblower Protection 
Program holds regions accountable for the accuracy of the data; 
Department of Labor's Response (April 2009): OSHA plans to retrain 
users on the correct entry of data with the deployment of its new 
information system and is developing a quality control program; 
Status: No action yet. 

GAO Recommendation (January 2009): OSHA should revise its field audit 
directive to clarify the criteria that regions must use in conducting 
focused and comprehensive audits; 
Department of Labor's Response (April 2009): OSHA will revise the 
field audit directive to clarify the criteria that regions must use in 
conducting focused and comprehensive field audits; 
Status: Action taken does not satisfy recommendation. 

GAO Recommendation (January 2009): OSHA should revise its field audit 
directive to require that the audit be conducted by an entity outside 
the control of the regional administrator whose programs are being 
audited to ensure independence; 
Department of Labor's Response (April 2009): This recommendation has 
significant resource implications. OSHA will examine alternatives to 
ensure independence of audits; 
Status: No action. 

GAO Recommendation (January 2009): OSHA should revise its field audit 
directive to require that regions submit complete reports of the audit 
findings and recommendations to OSHA's national office upon completion 
of an audit, along with periodic updates on corrective actions taken; 
Department of Labor's Response (April 2009): OSHA will revise the 
field audit directive to require that complete audit reports are 
submitted to the national office. OSHA will reexamine its approach to 
tracking corrective actions including having regions submit periodic 
status reports; 
Status: No action. 

GAO Recommendation (January 2009): OSHA should develop interim audit 
milestones that regions must meet in order to ensure that audits are 
completed within specified time frames; 
Department of Labor's Response (April 2009): Until an automatic 
tracking system is developed, OSHA will enhance its monitoring of the 
timely completion of audits by, for example, contacting regions at the 
halfway mark to request an update; 
Status: No action. 

GAO Recommendation (January 2009): OSHA should establish minimum 
standards for equipment and computer software that investigators need 
to do their jobs, and develop a mechanism to ensure these needs are 
met; 
Department of Labor's Response (April 2009): This recommendation has 
significant resource implications and, in the coming months, OSHA will 
weigh options to meet investigators' equipment and software needs; 
Status: No action. 

GAO Recommendation (January 2009): The Administrative Review Board 
should conduct routine, systematic, independent reviews of its case 
tracking system in order to ensure that it has accurate and reliable 
information to use to monitor the program; 
Department of Labor's Response (April 2009): The cost effectiveness of 
an independent review is questionable. Improved data validity has been 
obtained through in-house efforts such as additional training; 
Status: Action taken does not satisfy recommendation. 

Source: GAO analysis. 

[A] From GAO, Whistleblower Protection Program: Better Data and 
Improved Oversight Would Help Ensure Program Quality and Consistency, 
GAO-09-106, (Washington, D.C.: January 2009). 

[End of table] 

Attachment II: Data on FTE Allocation by Region: 

Region: 1; 
New complaints in FY09: 158; 
Percent of complaints that are not OSH Act or STAA: 27%; 
On board investigators (January: 2010): 7; 
New complaints in FY09 per on board investigator (January: 2010): 23; 
Proposed allocation of new FTE (January: 2010): 1; 
Allocation of new FTE according to OSHA Administration (February 
2010): 1; 
Allocation of new FTE according to OSHA Regions (April 2010): 2. 

Region: 2; 
New complaints in FY09: 245; 
Percent of complaints that are not OSH Act or STAA: 40%; 
On board investigators (January: 2010): 11; 
New complaints in FY09 per on board investigator (January: 2010): 22; 
Proposed allocation of new FTE (January: 2010): 5; 
Allocation of new FTE according to OSHA Administration (February 
2010): 2; 
Allocation of new FTE according to OSHA Regions (April 2010): 2. 

Region: 3; 
New complaints in FY09: 168; 
Percent of complaints that are not OSH Act or STAA: 24%; 
On board investigators (January: 2010): 5; 
New complaints in FY09 per on board investigator (January: 2010): 34; 
Proposed allocation of new FTE (January: 2010): 1; 
Allocation of new FTE according to OSHA Administration (February 
2010): 1; 
Allocation of new FTE according to OSHA Regions (April 2010): 1. 

Region: 4; 
New complaints in FY09: 442; 
Percent of complaints that are not OSH Act or STAA: 19%; 
On board investigators (January: 2010): 12; 
New complaints in FY09 per on board investigator (January: 2010): 37; 
Proposed allocation of new FTE (January: 2010): 4; 
Allocation of new FTE according to OSHA Administration (February 
2010): 4; 
Allocation of new FTE according to OSHA Regions (April 2010): 4. 

Region: 5; 
New complaints in FY09: 467; 
Percent of complaints that are not OSH Act or STAA: 16%; 
On board investigators (January: 2010): 14; 
New complaints in FY09 per on board investigator (January: 2010): 33; 
Proposed allocation of new FTE (January: 2010): 3; 
Allocation of new FTE according to OSHA Administration (February 
2010): 4; 
Allocation of new FTE according to OSHA Regions (April 2010): 3. 

Region: 6; 
New complaints in FY09: 218; 
Percent of complaints that are not OSH Act or STAA: 33%; 
On board investigators (January: 2010): 7; 
New complaints in FY09 per on board investigator (January: 2010): 31; 
Proposed allocation of new FTE (January: 2010): 1; 
Allocation of new FTE according to OSHA Administration (February 
2010): 4; 
Allocation of new FTE according to OSHA Regions (April 2010): 4. 

Region: 7; 
New complaints in FY09: 124; 
Percent of complaints that are not OSH Act or STAA: 14%; 
On board investigators (January: 2010): 3; 
New complaints in FY09 per on board investigator (January: 2010): 41; 
Proposed allocation of new FTE (January: 2010): 1; 
Allocation of new FTE according to OSHA Administration (February 
2010): 3; 
Allocation of new FTE according to OSHA Regions (April 2010): 3. 

Region: 8; 
New complaints in FY09: 132; 
Percent of complaints that are not OSH Act or STAA: 20%; 
On board investigators (January: 2010): 3; 
New complaints in FY09 per on board investigator (January: 2010): 44; 
Proposed allocation of new FTE (January: 2010): 2; 
Allocation of new FTE according to OSHA Administration (February 
2010): 3; 
Allocation of new FTE according to OSHA Regions (April 2010): 3. 

Region: 9; 
New complaints in FY09: 122; 
Percent of complaints that are not OSH Act or STAA: 69%; 
On board investigators (January: 2010): 4; 
New complaints in FY09 per on board investigator (January: 2010): 31; 
Proposed allocation of new FTE (January: 2010): 5; 
Allocation of new FTE according to OSHA Administration (February 
2010): 2; 
Allocation of new FTE according to OSHA Regions (April 2010): 2. 

Region: 10; 
New complaints in FY09: 84; 
Percent of complaints that are not OSH Act or STAA: 43%; 
On board investigators (January: 2010): 3; 
New complaints in FY09 per on board investigator (January: 2010): 28; 
Proposed allocation of new FTE (January: 2010): 2; 
Allocation of new FTE according to OSHA Administration (February 
2010): 1; 
Allocation of new FTE according to OSHA Regions (April 2010): 1. 

Region: All Regions; 
New complaints in FY09: 2160; 
Percent of complaints that are not OSH Act or STAA: 27%; 
On board investigators (January: 2010): 69; 
New complaints in FY09 per on board investigator (January: 2010): 31; 
Proposed allocation of new FTE (January: 2010): 25; 
Allocation of new FTE according to OSHA Administration (February 
2010): 25; 
Allocation of new FTE according to OSHA Regions (April 2010): 25. 

Sources: OSHA, except for "New Complaints in FY09 per on board 
investigator" which is GAO analysis of OSHA data. 

Note: STAA is the Surface Transportation Assistance Act of 1982. 

[End of table] 

[End of Briefing Slides] 

Appendix II: Comments from the Department of Labor: 

U.S. Department of Labor: 
Assistant Secretary for	Occupational Safety and Health: 
Washington, D.C. 20210: 

July 16, 2010: 

Mr. George A. Scott, Director: 
Education, Workforce, and Income Security Issues: 
U.S. Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 20548: 

Dear Mr. Scott: 

Thank you for the opportunity to comment on the Government 
Accountability Office's (GAO) proposed report, Whistleblower 
Protection: Sustained Management Attention Needed to Address Long-
Standing Program Weaknesses. The following comments are submitted on 
behalf of the Department of Labor's Occupational Safety and Health 
Administration (OSHA). 

OSHA appreciates the time and effort that GAO placed in its 
evaluation. OSHA agrees with most of the recommendations and will 
continue the progress made in the year between issuance of the January 
2009 report and the initiation of this current report. The following 
represents the Agency's initial response to the GAO recommendations as 
well as a few concerns and disagreements raised with the GAO findings. 

GAO Recommendations and OSHA Responses: 

GAO Recommendation: Ensure that all investigators complete mandatory 
training. 

OSHA Response: OSHA agrees with this recommendation and will ensure 
that all investigators complete the second-level training within the 
next 18 months. 

GAO Recommendation: Require staff who supervise investigators to 
complete the mandatory investigator training. 

OSHA Response: The Agency plans during the next 18 months that all 
Area Directors who have not yet taken the mandatory training will 
receive such training. 

GAO Recommendation: Track Whistleblower Program expenses, including 
FTEs, separately from other OSHA Programs, and annually report these 
expenses to Congress. 

OSHA Response: OSHA does currently track hiring and staffing in the 
Whistleblower Program. The Department is currently analyzing the 
impact of the landmark Patient Protection and Affordable Care Act on 
the Whistleblower Program, and is exploring program improvements in 
connection to the FY 2012 budget. 

GAO Recommendation: Develop an Action Plan, with specific milestones, 
for addressing identified internal control weaknesses. This plan 
should include mechanisms for strengthening the whistleblower National 
Office's control over the program. 

OSHA Response: The Deputy Assistant Secretary for Enforcement and 
Field Operations in OSHA is exploring a variety of issues, including 
internal control weaknesses. For example, the Agency is looking at 
restructuring the office to assure better training and regional 
oversight. Currently, an evaluation team is conducting an in depth 
program evaluation assessment of the Whistleblower Program in the 
field and National Office. Their charge is to make recommendations to 
the Assistant Secretary on programmatic changes to assure that there 
is consistency and program delivery is greatly improved. 

GAO Recommendation: Incorporate strategic goals specifically for the 
Whistleblower Program into Labor's strategic plan and develop 
performance measures to track progress in achieving them. 

OSHA Response: The Department is currently in the process of 
developing the FY 2011 — 2016 Strategic Plan. One of the outcome goals 
in the strategic plan is to "ensure worker voice in the workplace." 
The Whistleblower Program currently plays an important part in the 
Department's worker voice efforts. In an effort to more fully 
implement the strategic plan when published, OSHA will develop and 
incorporate related performance measures in its Fiscal Year 2011 
Operating Plan. 

Additional Issues Raised by the GAO Report: 

Organizational Structure: The chart labeled "OSHA's Organizational 
Structure Includes a National Office that sets Whistleblower 
Policies," has the Whistleblower Program National Office Director 
reporting to the Deputy Director of Enforcement Programs. This line of 
reporting is not correct. All Office Directors in the Directorate of 
Enforcement Programs report directly to the Director of Enforcement 
Programs. 

Equipment: In the previous GAO investigation of the Whistleblower 
Program as well as this current report, GAO maintains that OSHA has 
not ensured that investigators have the necessary tools to do their 
jobs. The lack of laptop computers and docking stations is a general 
and well-recognized problem for OSHA's compliance officers and 
whistleblower investigators. Purchasing new computers for the entire 
field staff has been a significant fiscal issue. The purchase of new 
computers to provide to field staff is currently underway and will be 
completed over the first quarter of FY 2011. 

Consistency: The GAO has pointed out that the Whistleblower Program 
operations vary by Region. To address this concern by the GAO, an 
evaluation team is conducting an in-depth program evaluation 
assessment of the Whistleblower Program in the field and National 
Office. Their charge is to make recommendations to the Assistant 
Secretary on programmatic changes to assure that there is consistency 
and program delivery is greatly improved. The audit program and the 
Whistleblower Program office case file review will then assure that 
the OSHA Regions are consistent in their approach to program 
management. Additionally, once the new Whistleblower Program manual is 
completed and goes into effect, all investigators and supervisors will 
be trained on the manual. 

Transparency: The GAO maintains that the process used to allocate the 
25 new FTEs was not transparent. OSHA disagrees with this assertion. 
Various options were developed and shared with the Whistleblower 
Program Office and the Regional Administrators before a final decision 
was made by the Assistant Secretary. In order to fairly allocate the 
new FTE's, the Agency utilized a computer program similar to that used 
to assign new compliance officers. The program evaluated the number of 
cases, the number of complaints, on-board investigators, percent of 
complaints received that were not under Section 11(c) of the Act, and 
other factors to assign the whistleblower FTEs to each of the Regions. 
This model was shared with the Whistleblower Program Office which 
provided input and the program was modified. The new allocation was 
then shared with the Regional Administrators who provided additional 
input. The different options were shared with the Assistant Secretary 
who made a final decision on allocation of the whistleblower FTEs. 
This decision was then explained to all of the Regional 
Administrators. The document referenced in the report that was signed 
by the Assistant Secretary was a general program overview, not the 
official allocation that had been authorized previously. 

OSHA appreciates the opportunity to review and respond to GAO's draft 
report. 

Sincerely, 

Signed by: 

David Michaels, PhD, MPH: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

George A. Scott, (202) 512-7215 or scottg@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Dianne Blank (Assistant 
Director) and Joel Green (Analyst-in-Charge) supervised the 
development of this product. Nancy Cosentino and Rachel Frisk helped 
with data collection. In addition, Carol Henn and Melissa Wolf helped 
with conceptual development of our study; Michele Fejfar helped assess 
data reliability; James Bennett provided graphic assistance; Susannah 
Compton provided writing assistance; Alex Galuten provided legal 
support; and Amy Sweet and Kathy White verified our findings. 

[End of section] 

Related GAO Products: 

Whistleblower Protection Program: Better Data and Improved Oversight 
Would Help Ensure Program Quality and Consistency. [hyperlink, 
http://www.gao.gov/products/GAO-09-106]. Washington, D.C.: January 27, 
2009. 

Internal Control Management and Evaluation Tool. [hyperlink, 
http://www.gao.gov/products/GAO-01-1008G]. Washington, D.C.: August 
2001. 

Standards for Internal Control in the Federal Government. [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. Washington, D.C.: 
November 1999. 

Whistleblowers: Management of the Program to Protect Trucking Company 
Employees Against Reprisal. [hyperlink, 
http://www.gao.gov/products/GAO/GGD-88-123]. Washington, D.C.: 
September 22, 1988. 

[End of section] 

Footnotes: 

[1] GAO, Whistleblower Protection Program: Better Data and Improved 
Oversight Would Help Ensure Program Quality and Consistency, 
[hyperlink, http://www.gao.gov/products/GAO-09-106] (Washington, D.C.: 
Jan. 27, 2009); and Whistleblowers: Management of the Program to 
Protect Trucking Company Employees Against Reprisal, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-88-123] (Washington, D.C.: Sept. 
22, 1988). 

[2] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1], 
(Washington, D.C.: November 1999). 

[3] See GAO, Whistleblower Protection Program: Better Data and 
Improved Oversight Would Help Ensure Program Quality and Consistency, 
[hyperlink, http://www.gao.gov/products/GA0-09-106] (Washington, D.C.: 
Jan. 27, 2009) and GAO, Whistleblowers: Management of the Program to 
Protect Trucking Company Employees Against Reprisal, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-88-123] (Washington, D.C.: Sept. 
22, 1988). 

[4] See attachment I for recommendations made in January 2009. 

[5] See GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1], 
(Washington, D.C.: November 1999). 

[6] As of June 10, 2010. 

[7] See attachment II for detailed information on FTE allocations by 
region. 

[8] See attachment I for status of recommendations made in January 
2009. 

[End of section] 

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